Anti-Bribery & Corruption Policy

1. What does this policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of Northern Partners including – but not limited to – Board members, Partners and Employees, in regard to observing and upholding our Zero-tolerance position on bribery and corruption.

1.2 The policy also exists to act as a source of information and guidance for those working for Northern Partners. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 Northern Partners is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. Northern Partners has zero-tolerance for bribery and corrupt activities. We are committed to act professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 Northern Partners will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the local laws of Denmark – as stipulated in the Danish Criminal Code – in regard to our conduct.

2.3 Northern Partners recognises that bribery and corruption are punishable by up to six years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all Board Members, Partners and employees (whether temporary, fixed-term, or permanent) or any other person or persons associated with Northern Partners (including third parties)

3.2 In the context of this policy, third-party refers to any individual or organisation Northern Partners meets and works with. It refers to actual and potential clients, business contacts, and government and public bodies – this includes their advisors, representatives and officials and public parties.

3.3 Any arrangements Northern Partners enters into with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly or passively (as described above.

5. Employee Responsibilities

5.1 As an employee of Northern Partners, you must ensure that you read, understand, and comply with the information contained within this policy.

5.2 All employees are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

5.3 If an employee has reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, he/she must notify the compliance manager.

5.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Northern Partners has the right to terminate a contractual relationship with an employee, if they breach this anti-bribery policy.

5.5 If an employee is a victim of bribery or corruption, is offered a bribe or asked to make one, or has any reason to believe that he/she is a victim of another corrupt activity. the compliance manager must be informed as soon as possible.

6. Protection

6.1 If an employee refuses to accept or offer a bribe or reports a concern relating to potential act(s) of bribery or corruption, Northern Partners understands that this employee may feel worried about potential repercussions. Northern Partners will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

6.2 Northern Partners will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

6.3 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

6.4 If an employee has reason to believe he/she has been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, he/she should inform the compliance manager immediately.

7. Training and communication

7.1 Northern Partners will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

7.2 This anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors and business partners.

8. Record keeping

8.1 Northern Partners will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made.

9. Monitoring and reviewing

9.1 Northern Partners` compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis and will assess its suitability, adequacy, and effectiveness.

9.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

9.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy, if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.

9.4 This policy does not form part of an employee’s contract of employment and Northern Partners may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

Last updated: July 2021

Issued by: Simon Kröger Kronmose – Head of Compliance