Our sustainability strategy
Ethics and integrity
Trust is a critical building block for our business and we recognise this in our vision ‘to be a trusted voice to tackle global transformations’. Trust in our brand, our products and services, and our knowledge and technical expertise is vital, as is trust that we run our business in the correct way.
Ethical conduct, legal compliance, and business and personal integrity are essential ingredients for building trust with customers and stakeholders. Alongside our purpose, vision and values, our Code of Conduct defines what we consider ethical, responsible and sustainable behaviour. It applies to everyone involved in DNV’s business and we strictly adhere to its standards. Our approach to ethics and compliance is not simply to impose a set of rules, but to raise DNV’s collective awareness of the practical implications of ethical behaviour and compliance.
Our focus in 2021 was on maintaining high levels of employee awareness on ethics and compliance-related topics. This included publishing our fully revised Code of Conduct and providing web-based and virtual classroom ethics and compliance training. Our Code of Conduct and global compliance programme protects against the diverse landscape of compliance and ethical risks we face as a Group operating in more than 100 countries across multiple sectors.
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Code of Conduct
Our Code of Conduct has been restructured and the content has been fully updated, including new chapters on human rights and diversity to emphasize the importance we place on these topics. It provides a framework for expected behaviour at all levels in DNV and includes clear requirements related to responsibilities, behaviour and decision making by employees, sub-contractors and managers.
To help our employees familiarize themselves with the new Code of Conduct, its launch was accompanied by a new Groupwide mandatory training. The training explains the Code’s main principles and expectations, and how to apply DNV’s ethical standards and decision-making process. As part of the training, every employee needs to sign a personal commitment to follow the Code of Conduct. 96% of DNV employees completed the training. The new Code of Conduct can be downloaded here.
To evaluate the effectiveness and impact of the Code of Conduct training we conducted a feedback survey, which was completed by around 2,800 employees. The survey showed that, overall, employees were satisfied with the content. We will continue to explore the impact of the new Code in 2022 with an awareness survey covering a representative group of employees.
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Anti-corruption
We updated and simplified our anti-corruption guidelines and instructions in 2022 to align with the new Code of Conduct. We also amended our gift guidelines in China to reflect new laws.
The US compliance programme was further strengthened through regular web-based network meetings where actions and experiences were shared, and network members were updated on anti-corruption and other compliance topics in the Americas region.
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Training and awareness
DNV places a strong emphasis on continuous training for employees, and this is particularly important to reinforce our high ethical standards. We monitor completion rates related to on the available trainings for employees and subcontractors and and have achieved completion rates above 90% for mandatory trainings.
A training on personal data handling for line managers, rolled out in Q4 2020, was completed by 90%, and a training on unstructured personal data was completed by 93%. We continued to deliver integrity training as part the leadership essentials programme for line managers throughout the year.
We also developed a guideline for line managers in high-risk countries on handling misconduct reported by employees. Supporting the guideline, new line manager training has been prepared focusing on ethical practices to achieve a culture of integrity. Line managers will also receive materials enabling them to provide integrity training to their teams. Completing the e-learning and delivering team training will be mandatory for line managers in high-risk countries as of Q1 2022.
We also developed a new concept for an ‘ethical employee journey’ to help us communicate the standards we expect from DNV employees. (see case study below).
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High-risk countries
DNV identifies countries that are considered high-risk for potential breaches of our business ethics and applies increased anti-fraud and anti-corruption actions. In 2021, a new network of employees responsible for compliance in high-risk countries was set up to discuss, promote and coordinate awareness measures, and to support initiatives and activities in high-risk countries. The network met four times in 2021 to discuss anti-corruption measures. They received supporting material to conduct local training. Completion of mandatory trainings was followed-up and local challenges were discussed.
The network were also informed about internal audit findings and the new ‘Enterprise Compliance Model (ECM)’ initiative launched by Group finance. The ECM initiative involves a gap analysis to identify local legal requirements relating to Legal, HR and Finance functions within DNV companies in high-risk countries.
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Case study - Focus on measures in high-risk countries
Our compliance team worked with Global Shared Services in Pune, India, to develop an ‘ethical employee journey’ to reinforce the high expectations as to ethics and integrity that DNV expects from all employees. The training is adapted different phases of employment, including pre-onboarding, onboarding, continuous employee engagement and exit from DNV. Based on this concept, Group compliance defined actions, including declaring conflicts of interest in the pre-onboardingphase and a train-the-trainer approach, to improve local training initiatives.
These new initiatives include a stronger focus on cultural differences and on areas of concern, such as conflicts of interest and personal data protection. This approach will be extended to all countries identified as high-risk in 2022.
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Export control laws and sanctions
In 2021, we focused on the interpretation of sanctions and increasing awareness of export control laws and sanctions. We took actions to identify export control law risks in Netherlands and UK and prepared new local processes and guidelines for transparency on legal requirements as well as roles and responsibilities. We continued monitoring sanctions’ developments to determine any impact on DNV´s business. Internal guidelines were continually updated, and we held frequent web-meetings with internal stakeholders.
We are introducing a tool designed to improve our due diligence checks for screening potential business partners, including scanning adverse media reports.
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Legal actions
No critical integrity concerns leading to legal actions or disclosure to authorities were registered in 2021. This is in line with the trend seen in previous years. No legal actions related to anticompetitive behaviour or antitrust and monopoly legislation were pending or completed during the year. There have been no significant fines or non-monetary sanctions for non-compliance with laws and/or regulations relating to environmental, social or economic issues. In a few cases, we have taken disciplinary action at the employee level.
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Awareness
To continue to maintain high levels of awareness on all topics in the compliance programme, we will focus on new initiatives identified for the ‘ethical journey’ using a new approach to training and awareness measures including pre-surveys and tests. We will use learnings from compliance cases and questions directed to the Group compliance unit to guide our approach.
To measure awareness within DNV on the topics covered by our revised Code of Conduct, we will complete a survey on compliance in 2022 with a representative group of employees.
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Whistleblowing
We will strengthen DNV’s process for reporting misconduct by introducing a new web-based system, available 24/7.
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Data protection
Personal data protection will remain in focus in 2022. We will improve our organizational setup for data protection with formalized roles and responsibilities, follow up on ‘Schrems-2’ ruling (including risk assessments) and implementation of new standard contractual clauses, and update and improve DNV’s Binding Corporate Rules and internal instructions, such as access to email accounts and employee files.
Improvements are also planned for our process on handling third parties and the approach for mapping and documenting record of processing activities. We will also support the setup of our internal governance for digital channels (see the Data privacy section).
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Export control and sanctions
We will continue to monitor sanctions and their interpretation in 2022 and will develop new processes in countries where export control-relevant services are provided. We will also continue discussions with DNV’s business areas to identify the need for local export control processes and implement them where necessary.
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Norwegian Transparency Act
As of July 2022, the Norwegian “Transparency Act” will come into force. The act requires Norwegian companies to carry out due diligence activities, in line with the OECD Guidelines for Multinational Enterprises, to ensure responsible operations, respecting both human rights and decent working conditions. We have initiated a review of our current procedures to ensure that we comply with new act.
As a global company operating in over 100 countries across multiple sectors, we work within a wide range of legislative, business and cultural environments. This results in a diverse landscape of compliance and ethical risks. Based on our Code of Conduct, our global compliance programme protects against these risks. Our approach is not simply to impose a set of rules, but to raise DNV’s collective awareness through communication and training explaining the background and practical implications of ethical behaviour and compliance.
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Code of Conduct
The DNV Code of Conduct outlines our requirements and expectations for ethical conduct. It clearly expresses what is expected from DNV as a business and from every individual working for, or on behalf of, DNV. The Code of Conduct can be downloaded here.
The Code is firmly linked to DNV’s Values and clearly sets out the expected behaviour and responsibilities of employees and managers in each chapter and gives guidance on ethical decision making. Separate instructions and guidelines for employees are in place for all issues covered in the Code of Conduct.
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Zero tolerance
We do not tolerate any violation of applicable laws, including those on anti-corruption, privacy and export control, nor of our Code of Conduct or internal instructions. Violations can result in disciplinary procedures, including termination of employment or contract, as well as potential legal proceedings.
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Compliance programme
Our compliance programme is based on the Code of Conduct which is owned by the Board of Directors. All focus areas – anti-corruption, antitrust, export control law and sanctions, and personal data protection – are based on the ISO standard 37301 for compliance management (see above). This creates an integrated and tailormade approach to compliance. Lessons learned are used to build competence and resilience, enabling our employees to understand the structure and requirements of the compliance management system and meet customer requirements.
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Training
Training and raising awareness are at the core of our approach. Awareness is key to reducing compliance risks and we continually invest in new and updated training on a number of compliance topics (see 'Progress in 2021' earlier in this section).
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Governance
Effective compliance is based on the global governance of our compliance programme and clear reporting lines. The Group Compliance Officer reports directly to the Board of Directors Audit Committee and to the Group CEO, with both receiving quarterly updates on compliance cases and the latest initiatives. The Board of Directors of DNV Group AS and Control Committee of Stiftelsen Det Norske Veritas receive annual updates.
The compliance programme is governed and managed at Group level. It involves close cooperation through a global compliance network incorporating our Group compliance function, all business areas and Global Shared Services. The global compliance network communicates on the compliance programme and raises awareness of compliance issues in the countries where we operate.
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Anti-corruption
We manage corruption and fraud risks through our Group risk management process and the Group compliance officer is a member of DNV’s Group risk forum. All business areas conduct an annual risk assessment using the DNV risk management tool, which includes identified and active fraud and corruption risks.
In addition, we review risks reported by high-risk countries through a separate risk reporting process.
The risks are evaluated and discussed annually in the Group risk forum. Actions to mitigate identified risks are developed based on these discussions.
For employees, anti-corruption is part of our mandatory training programme, our leadership essentials training and, for targeted groups, we provide webinars.
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Antitrust
Commercial policy and pricing are set independently and never agreed with competitors or other non-related parties. Competing vigorously and fairly, and in full compliance with all applicable antitrust and competition laws, is a fundamental corporate principle of DNV Group AS and its subsidiaries. Any obstruction of free and open competition is strictly prohibited.
For employees, antitrust is part of our mandatory training programme and our antitrust instructions are supplemented by a guideline on the ‘dos and don’ts for competition law’.
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Supply chain
We expect our suppliers and subcontractors to uphold the same standard of business ethics as we do and we have a Supplier Code of Conduct outlining our requirements (available here). Training is available for suppliers, emphasizing the ethical and sustainability standards that extend to our relationships with suppliers.
We continue to advise on and actively monitor implementation of our Group-wide instruction on subcontractors and intermediaries, as well as conducting risk-based due diligence checks in all business areas. The Sustainable supply chain section provides more details on how we work with suppliers.
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Reporting misconduct
Our employees, customers and suppliers are encouraged to report actual or suspected misconduct and all employees are required to complete an e-learning on reporting misconduct. Reports could include concerns related to bribery, fraud, labour grievances, discrimination or other ethical issues or breaches of our Code of Conduct concerning colleagues, suppliers, subcontractors or agents working on behalf of DNV.
We have an ethical helpline available to employees and an anonymous channel for reporting concerns. These and other channels to contact DNV are set out in our instruction on reporting misconduct, the Code of Conduct, the DNV intranet and on our website.
The number of financial misconduct cases remained steady in 2021. An increase in reported breaches of data protection was observed in 2021. We attribute the rise in the number of reported data protection breaches to an increased awareness among employees following internal campaigns.
