This Conduct Policy is a supplement to the Ethical Principles for employees of Norges Bank (laid down by the Executive Board on 19 October 2011, last amended on 20 November 2024). The boxes do not contain specific requirements but highlight matters which require particular attention.

1. Purpose and general principles

As an employee of Norges Bank you are expected to have a high level of ethical awareness and integrity. You have an individual responsibility to contribute to safeguarding Norges Bank’s reputation. As an employee you are responsible for understanding and following the Conduct Policy. The Conduct Policy expresses the expectations Norges Bank has for you and is intended to support you in undertaking wise choices. The compliance function can always be contacted with questions or if help is needed to understand the Conduct Policy.

Norges Bank, as central bank and manager of the Government Pension Fund Global, is given considerable authority and trust.

The purpose of this Conduct Policy is to ensure that employees perform their duties in a professional and independent manner and act with loyalty to Norges Bank as their employer. The regulations shall contribute to safeguarding Norges Bank’s reputation and maintaining public trust in Norges Bank.

Employees shall perform their work according to high professional standards and a high level of integrity, and comply with sound business practices.

Employees shall contribute to a positive, health-promoting, safe and inclusive working environment. Employees shall, through their own conduct and by complying with the Bank’s security measures, also contribute to upholding a sound security culture.

All employees have an individual responsibility to contribute to safeguarding Norges Bank’s reputation. Employees are required to act in an ethically responsible manner, comply with applicable laws and regulations and persistently maintain high ethical awareness.

Employees must also refrain from engaging in acts that they should understand may damage the Bank’s reputation, even if they are lawful. This also applies to acts that provide, or may appear to provide, a personal benefit related to their employment.

Employees shall use Norges Bank's resources in a prudent and efficient manner and protect the Bank’s assets from loss or theft.

The Conduct Policy contains guidelines of an overarching nature, intended to provide general guidance which requires employees to reflect. The Conduct Policy, together with the Bank’s values, shall govern the handling of ethical issues, also those not directly regulated herein.

2. Scope

This Conduct Policy applies to all permanent and temporary employees in Norges Bank Central Banking. For the Governor and Deputy Governors, these rules apply to the extent they are suitable as a supplement to the Impartiality Rules laid down by the Ministry of Finance.

For part-time employees and the Bank’s subcontractors, the applicable parts of the Conduct Policy will be stipulated in the employment or service contract. The Conduct Policy should in particular be taken into account when entering into contracts for independent contractors and consultants and also outsourcing of the Bank’s activities. Detailed guidelines on implementation of this paragraph will be laid down by the compliance function.

3. Definitions

“Financial instruments” is defined as in Section 2-2 (1), of the Securities Trading Act.

“Related party” is defined as in Section 2-5, Nos. 1, 2 and 4 of the Securities Trading Act:

1. The spouse of such person or another person with whom the said person lives in a relationship akin to marriage,
2. The under-age children of such person, as well as the under-age children of another person as mentioned in no 1 with whom the said person cohabits,
3. an undertaking over which the said person or entity or any person or entity mentioned in nos. 1, 2 or 5 exercises such influence as mentioned in the Private Limited Companies Act section 1-3 subsection (2), the Public Limited Companies Act section 1-3 subsection (2) or the General and Limited Partnerships Act section 1-2 subsection (2).

“Close personal relations” includes related parties and other close relatives or friends of the employee and any other closely personally associated parties that are apt to impair confidence in the employee’s impartiality.

"Financial sector undertakings” should be understood as in section 2 (2) of Regulations of 16 January 2020 No. 53 on the implementation of duty of disclosure pursuant to Section 5-3 of the Central Bank Act.

“Inside information” is information of a precise nature, which has not been made public, relating directly or indirectly to one or more issuers or to one or more financial instruments, and which, if it were made public, would be likely to have a significant effect on the prices of those financial instruments or on the prices of related derivative financial instruments. The term is further defined in Article 7 of the Market Abuse Regulation (MAR).

“Business relations” are external relations with whom the Bank does business when carrying out its activities.

“Potential business relations” are contractors that have been thoroughly assessed as likely service providers for Norges Bank.

Requirements applicable to “departmental directors” apply to directors of departments and directors who report directly to the Governor of Norges Bank.

4. Managing conflicts of interest

4.1 General principles

Employees shall not behave in a way that may create or appear to create a direct or indirect conflict of interest between the employees' private interests and the interests they are to manage and protect as employees of Norges Bank.

Employees must exercise sound judgement in considering conflicts of interest. As an aid, employees can ask themselves some control questions:

• Could this be perceived externally as personal advantage I receive because of my position?
• What does the other party wish to achieve?
• Is the contact transparent?
• Would I experience discomfort if colleagues or superiors became aware of this?
• How would I react if my colleagues had done the same?
• How may this be presented if someone wanted to criticise my decision?
• Could this damage Norges Bank’s reputation if it were to become public?

4.2 Secondary occupations, impartiality and private relationships

Employees must inform their immediate superior as soon as possible if there is a risk of conflict of interest. You can also seek advice from the compliance function. The general rule is that Norges Bank must pre-approve paid work or paid positions outside the Bank. The same applies to unpaid secondary occupations or positions of trust that are above a low scale.

4.2.1 General principles

In their work, employees must avoid dependence on or closeness to persons, enterprises or institutions if the nature of such relationship is that it may compromise trust in Norges Bank’s independence and integrity. Employees may not hold external positions of trust, secondary occupations or ownership interests that are, or may appear to be, in conflict with the interests they are to manage and protect as employees of Norges Bank. Employees must not act in a manner that may be in conflict with the performance of their duties at Norges Bank. Employees must inform their immediate superior[1] as soon as possible if there is a risk of conflict of interest, including conflicts of interest relating to external positions, ownership interests, close personal relations both within and outside the Bank[2] and regarding potential conflicts of interest when transitioning to a new position etc. Potential conflicts of interest should be handled as early as possible before appointment or when appointment occurs, and in an ongoing manner should the risk of conflicts of interest arise later. Employees can also seek advice from the compliance function.

Employees must not give undue emphasis to their employment at the Bank vis-à-vis private business relations.

4.2.2 Impartiality 

Employees shall not participate in the handling of cases where they are partial. An employee is deemed partial upon the existence of conditions that are likely to weaken confidence in their impartiality in the handling of a case. If such conditions exist, the impartiality rules (cf Section 6-10 of the Public Administration Act) require that the employee does not participate in the decision-making process or have the final say in that specific case.

Employees of Norges Bank must not hold a position whereby they evaluate, approve, supervise or in any other way assess the work of close personal relations in or outside the Bank.

An employee must not prepare, facilitate, decide on, supervise or in any other way process any matter in which the employee or a close personal relation of the employee has a direct or indirect economic or other personal interest.

Employees are obliged to obtain factual information about circumstances necessary to assess their own impartiality. Regarding related parties, this applies in particular to any ownership interests or other financial circumstances of a spouse or another person with whom the employee lives in a relationship akin to marriage. Due care must be exercised in relation to other close personal relations and may – depending on the situation – require that the employee make further enquiries.

4.2.3 Secondary occupations

The provisions in this section do not apply to duties performed by the employee on behalf of or on assignment for Norges Bank.

The general rule is that paid work or positions of trust other than in the Bank require prior approval. Employees must submit an application in writing in eGRC to the departmental director. This does not apply to academic secondary occupations on a modest scale, such as lectures, participation in assessment committees, supervising students and marking examination papers etc. In such cases it is sufficient for the employee to inform his or her immediate superior in writing in advance.

Even when they are unpaid, positions of trust that are above a low scale require prior approval. Examples of positions that do not require prior approval are positions of trust on a modest scale in a housing cooperative, social associations, employee organisations, political activities, sports clubs or in connection with their children’s education etc.

When considering whether to approve an employee’s position of trust or secondary occupation, the departmental director will assess whether there is or may appear to be a conflict with Norges Bank interests or damage the Bank’s reputation. This means that positions of trust or secondary occupations are not permitted in eg undertakings within the financial sector or with the Bank’s business relations. On the same basis, the departmental director may decide that the external activity must cease. A copy of the decision must be sent to the compliance function as soon as possible.

If employees in such positions participate in investment decisions, the Bank’s rules for personal trading apply.

4.2.4 Exemptions from prohibitions

The Governor may grant exemptions from the prohibitions in Section 4.2, provided that such exemptions are deemed unobjectionable. Assessments shall give particular weight to the purpose of the Conduct Policy (see Section 1).

4.3 Gifts

The general rule is that employees are not permitted to accept gifts or other benefits from external parties when performing work or service for Norges Bank.

4.3.1.     Accepting gifts etc

Employees are generally not permitted to accept gifts or personal advantages for themselves or others in connection with their work. The prohibition also applies to duties performed outside Norges Bank, for example serving as a board member, when the duties are connected with the employee’s position at the Bank.

“Gift” means all forms of benefits and advantages, such as services, physical gifts, commissions, discounts and benefits in kind (eg meals, free entry to events etc). The general prohibition applies irrespective of whether a gift in such situations is deemed customary in the relevant social setting, country or culture.

Under the prohibition on gifts, bonus points and the like earned from official travel cannot be used for private purposes.

However, modest gifts can be accepted if an objective assessment concludes that they cannot be considered to compromise trust in the employee and Norges Bank. The purpose of the gift must clearly not be to obtain contracts with or special benefits from Norges Bank. Gifts that by nature are considered a polite gesture, such as flowers, bottles of ordinary wine, chocolate or gift cards, can normally be accepted when presented in a connection where such gestures are natural, such as when employees give lectures etc. Gifts given by external parties to employees in connection with Christmas, birthdays etc must be avoided. Accepting money or objects that can function as money, such as cash, deposit money, loans, discounts etc. is always prohibited. Gifts covered by this paragraph shall be reported in eGRC, and gifts with an assumed value in excess of NOK 500 become the property of the Bank and must be turned over to the compliance function.

Working lunches and normal meals in connection with meetings can generally be accepted. Accepting food, drink, entertainment etc. included as part of official event programmes (courses, seminars etc.) will generally not be prohibited. The same applies to typical advertising material of modest value (calendars, almanacs, pens etc), as well as other items of modest value in connection with seminars or educational events. For gifts covered by this paragraph, no reporting is required.

Gifts from other central banks, international organisations or other public authorities may be accepted if the gift has modest value and it would in the circumstances be considered inappropriate and unusual if the Bank’s representative did not accept the gift. Physical gifts covered by this paragraph shall be reported in eGRC and gifts with an assumed value in excess of NOK 500 must become the property of the Bank and be turned over to the compliance function.

Employees may receive public awards or academic honours and decorations bestowed by universities, colleges, research funds etc. The compensations are accrued to the employee, who themselves must ensure compliance with tax rules and other rules for such compensation.

4.3.2 Gifts from Norges Bank to external parties

The general rule is that Norges Bank does not give gifts to business relations or potential business relations. If this would seem impolite for reasons of culture or custom in the country in question, a modest gift may be given.

4.3.3 Loans to and deposits from employees and related parties

Employees may have loans and deposits on ordinary market terms with a business connection of the Bank whose ordinary activities include lending and deposit taking. Employees may nevertheless have loans and other financial services through schemes negotiated by employee organisations and offered to their members.

If related parties have loans and/or deposits with a business connection of the bank, employees of Norges Bank may be co-signers for such loans or have such deposit accounts if they are a standardised part of a customer loyalty programme based on the related party’s employment.

4.3.2 Exemptions

The compliance function can decide on exemptions from the rules on gifts in section 4.3 where this is deemed unobjectionable.

4.4 Invitations to seminar, meetings etc

As a general rule, Norges Bank covers all costs incurred by employees’ participation at external seminars, meetings and events.

Employees may, as part of Norges Bank’s activities, participate at external seminars, meetings and events that are relevant for Norges Bank's business and where participation is in the interests of Norges Bank. Such participation shall be cleared in advance with the employee’s immediate manager and the reasons for participation must be exclusively work-related.

Costs related to travel, meetings, seminars etc. incurred in the performance of professional duties for Norges Bank shall be covered by the Bank unless otherwise follows from common practice for representation in public contexts, common practice among central banks or international organisations, academic institutions etc. When the employee contributes with external lectures etc. the host organisation may also cover seminar fees etc. and meals included in the seminar fee if the lecture etc is part of the seminar. See also Section 4.3 on gifts.

In special cases, the departmental director can provide prior written approval for additional expenses to be covered by the host organisation if it is deemed unobjectionable by the director to make an exception. In assessing this, particular emphasis shall be given to the purpose of the policy, see Section 1. A copy of the approval must be sent to the compliance function as soon as possible.

4.5 Employees’ personal trading

As an employee of Norges Bank, you are subject to many internal rules regarding personal trading in financial instruments, foreign exchange products and fixed-rate products. These include rules on lock-in periods and reporting requirements. For some employees there are also limitations for which products can be traded and when trades may be carried out. If you wish to engage in personal trading, you must become well acquainted with the relevant rules. You can always seek advice from the compliance function.

4.5.1 General principles

The purpose of the personal trading rules is to reduce the risk of conflicts of interest while allowing employees to make private investments to manage long-term savings.

The term personal trading includes trading conducted by the employee for their own account or for the account of others, including related parties (see section 3).

Employees may trade privately in financial instruments, foreign exchange products and fixed-rate products within relevant laws, regulations and the restrictions and requirements laid down in internal governance documents.

When engaging in personal trading, employees must always endeavour to avoid harming Norges Bank's reputation. Employees must exercise caution even if a transaction is not prohibited under these rules. This applies, for example, to trading in cryptocurrencies.

The personal trading rules apply even if trading takes place through a private limited company or other form of business organisation when the employee participates in investment decisions.

4.5.2 Lock-in periods

Employees may not sell, redeem or refinance financial instruments, foreign exchange products or fixed-rate products (typically fixed-rate deposits or fixed-rate loans) [3] until twelve weeks have passed from the time of acquisition. The same lock-in period applies to transactions in Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs) ^[4] and similar exchange-traded products (ETPs).

The lock in period does not apply to personal trading of assets under active management by a portfolio manager under contract where the employee is not involved in individual investment decisions. Nor is there a lock-in period for amending active management agreements. The prohibition on trading pursuant to section 4.5.4, first and second paragraphs, does not apply to active n management agreements.

Some products include the option of determining the financial instruments to be traded under the agreement (for example Unit Link products as well as some active management agreements). If direct trading in an instrument would have been subject to a lock-in period, the same lock-in period will apply when the instrument is traded by decision of the employee, as part of the contract, cf. also section 4.5.3 on the reporting obligation.

The lock-in period and reporting obligation do not apply to units in securities funds.

Employees without Norwegian citizenship may have pension and savings agreements that include investments in financial instruments without this entailing a lock-in period or reporting obligation. A requirement is that the financial instruments in question are not denominated in NOK.

Foreign exchange products refers to loans in foreign currency. Foreign exchange products also include trades where the primary underlying purpose is currency or interest rate speculation. Typical examples of this are purchases of foreign exchange that are to be kept as deposits or similar and are not intended for specific purchases or other "use".

The lock-in period for foreign exchange therefore does not apply, for example, to necessary exchange in connection with travel, studies abroad or relocation between countries using different currencies, the purchase and sale of holiday homes or valuables abroad, online shopping in foreign currency, and coverage of current liabilities or investment returns in foreign currency. Such transactions are not considered foreign exchange products. Nor is in currency-hedged securities funds considered foreign exchange products.

Employees without Norwegian citizenship may have loans and deposit accounts in their home country's currency without being subject to the provisions on lock-in periods and reporting obligations.

The compliance function may decide on exemptions from the rules on fixed-rate products and foreign exchange products where this is considered unobjectionable.

The lock-in period applies separately to each acquisition in situations where the same financial instrument or currency is acquired in several trades. The lock-in period does not apply to personal trading carried out prior to the commencement of employment at Norges Bank.

4.5.3 Reporting obligation

When a trade is subject to a lock-in period (see Section 4.5.2), the acquisition or disposal must be immediately reported (at the latest before the end of two business days after completion of the transaction) to the compliance function. This also applies if the acquisition of instruments that are subject to a lock-in period has taken place in the form of gifts, probate settlements or inheritance. The compliance function obtains the necessary assessments from, and gives necessary information to, the employee’s immediate superior.

The reporting obligation applies upon completion of the transaction (trade date), not when the buy or sell order is submitted. The transaction is considered to be completed once a binding agreement is entered into, even if the transaction should be settled at a later date (value date). The trade shall be reported by the deadline even if not all documentation is available.

The same applies to the subscription of equities: the reporting obligation applies once there is a binding agreement, ie only when a decision has been made to allocate purchased equities. In connection with a subscription of equities it can be difficult in practice to report the allocation within two business days, and in such cases, the compliance function may approve reporting later where this is regarded as unobjectionable.

Reports must be submitted using eGRC, with documentation of the transaction (for example the contract note) attached. If documentation is not available by the two-day reporting deadline, it may be attached later. If eGRC is unavailable, the transaction shall be reported in the meantime to the compliance function, preferably by e-mail.

Agreements and amendments to active management agreements must be reported to the compliance function. Employees must also on the request of the compliance function provide supplementary information on asset holdings that are under active management.

4.5.4  Special restrictions applying to Norges Bank’s leader group and employees with access to inside information concerning a financial institution, the policy rate setting process etc.

The Governor, Deputy Governors and other employees who have access to inside information concerning the policy rate setting process or the process for setting the countercyclical capital buffer may not purchase, establish, sell, submit trading orders, redeem or refinance foreign exchange products, fixed rate products or financial instruments denominated in NOK during the 21 calendar days immediately preceding the date of publication of the policy rate decision. This quarantine period is extended until the decision on the countercyclical capital buffer is published in the instances where this occurs after the publication of a policy rate decision. The prohibition on trading is not an impediment to trading during the "quarantine period" in units in securities funds where more than 95% of the fund is comprised of financial instruments in currencies other than NOK. Nor is the prohibition on trading an impediment to pre-determined fixed payments through an existing savings instrument during the “quarantine period”.

The members of the Norges Bank’s Central Bank executive group, other directors who report to the Governor and employees who may have access to confidential information concerning a financial institution[5] are not permitted to acquire or dispose of Norwegian transferable securities[6] that are issued by financial sector undertakings or derivatives of such securities. Trading in units in securities funds is permitted, provided financial sector securities funds hold a broadly diversified portfolio at the time of acquisition[7]. The compliance function may issue an exemption for securities held by an employee when they take up a position to which the prohibition on trading applies.

The prohibition on trading in the first and second paragraph does not apply to transactions that do not involve an independent decision by the employee, such as in the case of inheritance, a gift, administration of an estate, stock redemptions in connection with write-downs, forced redemption, forced sales, involuntary conversion, bond redemption or similar. The same applies to corporate events such as mergers, demergers, stock splits and reverse stock splits, "forced" distribution of dividend shares and similar. Nor does the prohibition on trading prevent the normal exercise of any option or forward/futures contracts previously entered into upon the expiry of such contracts.

The compliance function can in special cases grant exemptions from the provisions in the first and second paragraph provided that such exemptions are not deemed inadvisable.[8]

Departmental directors must at all times maintain a list of those units or employees and temporary staff to which the restrictions in the first and second paragraphs apply. If an employee is included in the list, departmental directors have a responsibility to notify the employee.

 4.5.5   Special restrictions applying to employees with access to the management of financial instruments

The departmental director responsible for the management of the foreign exchange reserves must draw up a list of units or employees and temporary staff who in their work normally have access to, or whose work involves, the management of financial instruments or foreign exchange for Norges Bank Central Banking Operations. If an employee or a contractor employee is included in the list, the departmental director also has a responsibility to notify the relevant employee or temporary member of staff. It is prohibited for persons on this list to:

• trade in derivatives or exchange-traded notes (ETNs),
• use counterparties that regularly and on a significant scale provide services for Norges Bank Central Banking Operations in personal trading in financial instruments or foreign exchange products, unless trading takes place electronically and is based on standard terms and conditions. The departmental director responsible for the management of the foreign exchange reserves must ensure that a list of counterparties is drawn up.

Employees who in the performance of their duties manage portfolios or conduct transactions in financial instruments or otherwise take decisions concerning financial instruments are not permitted to conduct transactions for their own account in the same financial instruments specified in the management mandate.

Other employees who have – or have access to – information about Norges Bank’s decisions concerning trading in financial instruments are not permitted to conduct transactions for their own account in the same type of financial instrument until the information has been made publicly available.

4.5.6   Special restrictions applying to employees with access to NBIM’s investment activities

Employees in possession of insider information or other confidential company information regarding NBIM’s investment activities shall in all circumstances avoid using such information for personal trading or for providing investment advice to others or passing on such information to unauthorised persons (cf also Section 5.3).

The compliance function may lay down further requirements.

5 Financial misconduct

 5.1 General principles

Norges Bank does not accept any form of financial misconduct or crime such as corruption, money laundering or terrorist financing.

5.2 Stopping and preventing financial crime

5.2.1 Fraud

Fraud is the process of engaging in intentional acts to achieve an improper benefit or inflict loss or damage on an enterprise. Examples include bribery, corruption, kickbacks, theft, embezzlement, unlawful cooperation and leaking of information, market manipulation and insider trading, falsifying expenses and fraudulent misrepresentation in eg accounting.

Employees must avoid engaging in acts that may constitute fraud. Employees shall also not contribute to fraud

5.2.2 Anti-corruption

Corruption is the act of bribing or accepting bribes and thereby giving or receiving an improper advantage in connection with one’s employment.

Employees must avoid becoming involved in activities or transactions in which someone demands, receives or accepts an offer of an improper advantage by virtue of their position, either as employee of the Bank, or as external consultant, contractor or subcontractor. Employees must also not give or offer anyone an improper advantage in connection with a position, office or assignment[9].

Whether an advantage is or is considered improper will depend on an overall assessment. A number of factors may be of importance, such as:

• the value of the advantage
• whether the advantage is in breach of internal guidelines, cf for example Section 4.3.1 above
• the purpose of the advantage
• whether the advantage has been kept hidden
• the relationship between the giver/provider and the recipient

Norges Bank can also be held responsible in the event of corruption by third parties acting on behalf of Norges Bank.

5.2.3 Anti-money laundering and terrorist financing

Money laundering is preserving the proceeds of criminal acts by concealing the criminal origin of the funds or assets. Money laundering entails supporting criminal activities such as corruption, tax evasion and terrorism.

Employees must avoid that they, or Norges Bank, receive proceeds of crime or become involved in activities or transactions that may be related to the proceeds of crime or in any other way contributing to the financing of crime or terrorist activity.

5.3 Market abuse and handling inside information and other confidential company information

As an employee you must protect all market-sensitive information. In case of doubt as to whether the information is market-sensitive, the information must not be shared with unauthorised persons until this has been clarified with your immediate manager or the compliance function.

Employees shall not participate in or contribute to market manipulation, such as price fixing, front-running, misleading market participants or other illegal market activities.

Norges Bank processes market-sensitive information, such as information related to forthcoming policy rate decisions and auctions, decisions concerning the countercyclical capital buffer, confidential information concerning specific institutions, investment decisions or the like by NBIM, information relating to extraordinary measures for specific banks or market-oriented measures taken by the government or by Norges Bank during financial crises. Such market-sensitive information may have an impact on government bond markets (fixed income markets) or on securities markets in general.

When trading in financial instruments, foreign exchange products or fixed income products, employees must not misuse inside information[10] or other confidential information they acquire knowledge of through their work. Whoever is in possession of inside information must not[11]:

• engage or attempt to engage in insider dealing[12]
• recommend that another person engages in insider dealing or induce another person to engage in insider dealing, or
• unlawfully disclose inside information, ie not as a part of the normal exercise of an employment, a profession or duties.

6. Information management and external communication

6.1 Duty of confidentiality

Anyone performing services or work for Norges Bank shall be obliged to prevent unauthorised persons from gaining access to or knowledge of any information that comes to his or her knowledge in the performance of his or her duties with regard to the business affairs of the Bank or others or the personal affairs of anyone (cf. Section 5-2 of the Central Bank Act).

Information employees gain access to or knowledge of in the performance of their duties must not be used to achieve a personal advantage.

6.2 External communication

6.2.1 General principles

Employees have a fundamental freedom of expression.

Norges Bank takes a positive view of employees’ participation in external professional activities.

Employees may participate and represent Norges Bank at external gatherings and contribute by giving lectures etc, where such participation is consistent with the ongoing activities of Norges Bank and where it is deemed appropriate in light of Norges Bank's activities and interests. Prior approval of the relevant line manager is required.

With regard to the right to receive remuneration etc, and compensation for expenses for such participation, see section 4.3.1 on gifts and section 4.4.

6.2.2 Social media

Employees must not link their personal statements on social media with their employment at Norges Bank in a manner that may be disloyal, contrary to the Bank's ethical rules or damage the Bank's reputation.[13]

6.3 Data protection

Norges Bank shall protect the personal data of individuals. Employees must handle personal data with care and only for specific, expressly stated purposes necessary to perform the Bank's tasks. Employees who handle personal data shall familiarise themselves with and comply with external and internal requirements relating the processing of such data.

7 Inclusion and non-discrimination

7.1 Diversity and non-discrimination

Employees shall foster a culture that provides and contributes to diversity, inclusion and equal opportunities for all. At Norges Bank, different experiences, opinions and views are valued. This requires employees to respect and trust each other.

7.2 Discrimination and harassment

Norges Bank does not accept any form of discrimination, harassment, including unwanted sexual attention, or bullying of its own employees or others involved in Norges Bank's activities. The Bank does not accept any violations of human dignity in connection with any services. Discrimination includes all unjustified differential treatment, for example on the basis of ethnicity, gender, age, disability, sexual orientation, religion, political opinion, national origin or other similar circumstances that are contrary to the principle of equality. Sometimes, however, it may be legal and justifiable to use positive discrimination to prevent discrimination and promote equality and diversity.

7.3 Intoxicating substances

It is not permitted to use or be under the influence of intoxicating substances in normal work situations or abuse intoxicating substances when employees represent Norges Bank. This also applies outside working hours when this results in absence or has a negative impact on the performance at work.

7.4 Whistleblowing

Employees are encouraged to contribute to openness and good communication within the Bank. Employees are generally expected to report behaviour or circumstances that may be in violation of ethcial rules and norms or laws and regulations etc, that apply to the business.

If it is not appropriate to report such circumstances to an immediate superior, it can be reported through alternative internal whistleblowing channels[14]. It shall be safe to report any concerns, and Norges Bank will not tolerate any form of retaliation.

8 Duty to report and to disclose

Employees have a duty to report circumstances of which he or she becomes aware, and which may cause loss or damage for Norges Bank, employees or the surrounding environment, so that measures can be taken to avoid or mitigate loss or damage.

Employees have a duty to provide necessary information to their line managers or relevant control units of issues regarding compliance with this Conduct Policy or other relevant rules.

At the start of the employment relationship, the employee must inform the compliance function of secondary occupations and holdings of financial instruments (with a lock-in period), foreign exchange products and fixed-rate products.

All new and existing employees must, upon request, sign a declaration in which the employee confirms that this Conduct Policy is read and understood, and that the employee understands the consequences of any non-compliance.

In connection with monitoring and control in relation to the provisions in Section 4.2 and 4.5, employees are required, when requested to do so by the compliance function, to provide information about secondary occupations, holdings of financial instruments (with a lock-in period), foreign exchange products and fixed rate products or other factors.

In monitoring employee compliance with these rules, the compliance function may search for and use publicly available information such as data on the ownership of Norwegian equities and information on employee roles in the business sector.

9 Training

The compliance function shall provide targeted and regular training on the ethical framework. The training is to be adapted to employee’s tasks and relevant conflicts of interest. Upon appointment, new employees are to receive appropriate training. As a minimum all employees are required to complete annual training and confirm that they are up to date on all reporting and that they have read and understood the Conduct Policy.

10 Consequences of a failure to comply

Failure to comply with the Conduct Policy may in serious cases have consequences for the person’s employment or engagement with Norges Bank. Employees can always seek advice from the compliance function.

Failure to comply with this Conduct Policy may result in disciplinary actions or claims for compensation. In serious cases, failure to comply may have consequences for the person's employment or contract with Norges Bank. Repeated violations of the Conduct Policy may be regarded as a serious violation even if the individual violation in isolation is not serious.

In the event of a violation of a requirement in the Conduct Policy by an employee, the compliance function will notify the employee with a description and assessment of the violation by email copied to the employee’s line managers up to and including departmental director. HR will be engaged in the matter before sending an email about conditions that can result in legal reaction regarding employment.

Violations of certain provisions of the Conduct Policy are punishable under the Penal Code or the Securities Trading Act. If serious criminal offences are suspected, the case must generally be reported to the police for criminal follow-up[15].

Footnotes

[1] The Governor should report to the General Counsel or the compliance function.

[2] See definition in Section 3. Possible risks of conflicts of interest relating to close personal relations may, for example pertain to relationships with individuals among suppliers or other third parties that have ongoing work with Norges Bank or directly with the employee. Another example is when employees become family members with or become close personal relations with another employee. See also Section 4.2.2 on impartiality.

[3] For example, mortgages or student loans with a fixed interest rate. The use of a standard financing solution of the type "buy now and pay later" for ordinary consumer purchases is not considered a fixed-rate product, even if the solution has credit elements that can be perceived as – or that have similarities to – "fixed-rate loans".

[4] "Employees and contractor employees who, in the course of their work, normally have access to or whose work involves management of financial instruments or foreign exchange for Norges Bank" are not permitted to trade in ETNs, cf. section 4.5.5.

[5] This includes access to Norges Bank’s settlement system (NBO) data.

[6] Cf Section 2-4 (1) of the Securities Trading Act.

[7] The rule is intended to prevent trading in securities funds with a portfolio that is primarily limited to Norwegian securities in the financial sector. Thus, the rule is not an impediment to trading in units in securities funds with a “narrow” portfolio in another sector.

[8]  Exemptions that are not deemed inadvisable pursuant to the first or second paragraph can include the sale of allocated subscription rights before the rights expire or become worthless, or the disposal of securities acquired through inheritance, as a gift, or in the administration of an estate, or Norwegian transferable securities that an employee holds upon commencement of employment at Norges Bank. Another example is the exercise of subscription rights assigned on the basis of existing holdings. The compliance function may obtain advice from departmental directors.

[9] Cf. Provisions on corruption in sections 387 and 388 of the Penal Code.

[10] See section 3.

[11] See Articles 10 and 14 of MAR.

[12] Insider dealing arises where a person possesses inside information and uses that information by acquiring or disposing of, for its own account or for the account of a third party, directly or indirectly, financial instruments to which that information relates. See Article 8 of MAR.

[13] For more guidance, employees can refer to the "Vær varsom -plakat for sosiale medier” [Careful on social media] poster (in Norwegian only) available on the intranet.

[14] See “Guidelines for whistleblowing within the Governor's area of responsibility”

[15] For the responsibilities regarding criminal follow-up, see “Generelle fullmakter i sentralbankvirksomheten” [General authorisations in Central Banking Operations] (in Norwegian only).