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Code of Conduct

1             Introduction

Borregaard shall operate in accordance with responsible, ethical and sound corporate and business principles and comply with all applicable laws and public regulations. This requires the collective effort of all employees.

This Code of Conduct applies to all Borregaard employees and board members in entities owned by Borregaard. Borregaard wants the rules also to apply to consultants, intermediaries and others acting on behalf of Borregaard. The document provides a framework for what Borregaard considers to be responsible conduct, and defines the individual responsibilities of employees through a combination of broad principles and specific requirements based on the Company’s core values described in this document, in company culture, in the core values document “The Borregaard Way” and in other documents on corporate governance.

This Code of Conduct is not exhaustive. The responsibility to act in accordance with law and ethical norms will always remain an individual matter.

2         General principles

2.1    Comply with laws and regulations

All employees and board members shall comply with public laws and binding international requirements in all their activities for Borregaard.

All the companies in the Group and all employees and board members shall always comply with local laws. In addition, all employees shall comply with internal company policies. In some cases, our policies are stricter than legislation.

2.2    Act in the best interest of Borregaard

All employees and board members shall be loyal to and serve the best interest of Borregaard.

Loyalty means working to promote the best interest of Borregaard, and, within the framework of public law and Borregaard’s policies, giving Borregaard’s interests priority over other interests. We should always use our best judgement to enhance Borregaard’s value creation, protect the Company’s interests and contribute to continuous improvement.

2.3    Act with integrity

All employees and board members shall act with integrity in their activities for Borregaard.

Personal integrity means “doing the right thing”, even when nobody is watching. We shall always be honest, truthful and reliable. We shall act in consistency with Borregaard’s core values and promote these values by acting responsibly towards colleagues, business associates and society at large.

2.4    Act with respect and concern for others and for the environment

All employees and board members shall treat other human beings and the environment with respect and due concern.

Borregaard shall foster a corporate culture characterised by respect and concern for other people, their property and the environment. We shall behave in a way that inspires confidence in colleagues, suppliers, customers, authorities, or others in contact with our activities.

3              Specific principles

3.1 Protect Borregaard’s property and reputation

All employees and board members shall protect Borregaard’s property and reputation.

The reputation of Borregaard is important for our ability to succeed. Employees and board members shall avoid activities or behaviour which could damage Borregaard’s reputation.

All employees shall act responsibly and with caution to protect all our property from misuse, theft, damage or destruction. Intellectual property such as patents, designs, trademarks, recipes, know how, ideas and information shall also be protected. Borregaard’s property and assets shall not be used for the employee’s own purposes without special permission.

3.2    Contribute to realising Borregaard’s environment, health and safety vision

All employees shall contribute to achieving Borregaard’s vision of inflicting no harm on people, the environment and society.

Employees shall help to realise this vision by cooperating with the management, complying with Borregaard’s EHS policies and by exercising sound judgement. Employees shall notify their immediate superior of important issues related to health and safety in the workplace and the Company’s impact on the environment. We encourage employees to give direct feedback to colleagues on EHS issues based on the principle “Thank you for caring!”

3.3    No discrimination or harassment

All employees shall avoid behaviour which may be seen as discrimination or harassment.

Borregaard aims for a workplace characterised by diversity and anti-discrimination. To reach this goal, all employees shall treat colleagues, customers, business associates and others with respect. Any form of harassment or other behaviour which may be perceived as insulting to colleagues or business associates or which may be perceived as threatening or degrading is prohibited. No discrimination, regardless of whether based on gender, sexual orientation, age, ethnicity or religious belief shall take place. Employees should also be sensitive to and respectful of cultural differences.

3.4    Handle business information with care

All employees and board members shall treat information about Borregaard with due care, and treat non-public information confidentially.

A trustful relationship with customers, business associates, colleagues and society is built by engaging in dialogue and sharing perspectives. At the same time, disclosure of confidential information may harm Borregaard’s business or reputation. By confidential information we generally mean information which is not, or should not be, known to the public, such as business plans, budgets, marketing and sales programmes, recipes, design specifications, customer records and the like.

Employees and board members shall never disclose confidential information to anyone outside the Company, unless such disclosure is explicitly permitted by an authorised superior or is required by law.

Information about Borregaard which has not become public shall be regarded as Borregaard’s property. Consequently, the non-disclosure obligation continues without time limit and after the termination of employment or the term of service as a board member.

3.5    Avoid conflicts of interest

All employees and board members shall be loyal to Borregaard by avoiding any conflict of interest.

Employees and board members shall not seek to obtain advantages for themselves or others, if these are improper or may harm Borregaard’s interests. No one shall take part in, or attempt to influence, a decision if a conflict of interest may arise. Particular attention must be paid to situations where the employee or board member has a personal interest in the matter, either economic or otherwise, or when a close relative has such an interest.

Employees shall not have assignments outside Borregaard without notifying their immediate superior. Assignments shall not conflict with Borregaard’s interests. A careful assessment should be made to avoid activities which may be perceived to advance the interests of a competitor, a supplier or other stakeholders at the expense of Borregaard. Employees or board members are not allowed to market products or services that compete with Borregaard’s business activities or other interests.

Employees or board members who become aware of a possible conflict of interest shall, without delay, notify their immediate superior.

3.6    Use written agreements

Borregaard’s agreements with employees, suppliers, customers and business partners shall be in writing and be properly filed.

All Borregaard companies enter into agreements on a regular basis. These agreements are vital to the company’s business. Oral agreements can be difficult to verify and may sometimes lead to suspicions that something illegal or unethical has taken place. Therefore, all agreements entered into by any Borregaard company shall be in writing, and the agreements shall be properly filed.

3.7      Be accurate in accounting

Borregaard’s financial records shall always be accurate.

Borregaard’s financial records are crucial for the management of the business and for the fulfilment of the Group’s obligations. Therefore, Borregaard’s financial records shall always be complete and accurate. Employees involved in financial transactions or accounting shall ensure that all transactions are fully and accurately documented and recorded in accordance with applicable law, good accounting practice and internal requirements. False or misleading entries are under no circumstance acceptable.

3.8    No to corruption and bribery

All employees and board members shall refrain from corruption and bribery in all forms.

Borregaard employees and board members are not allowed to engage in any form of bribery or corruption. This requirement is based on legislation and ethical rules which all Borregaard companies must adhere to, and applies to all of Borregaard’s activities worldwide. Individuals involved in acts of corruption may be exposed to civil and criminal liability. If a challenging situation arises in connection with work for Borregaard, the employee shall seek immediate advice from his or her superiors about how to handle it in a legal manner. Such discussions are an important part of the Company’s efforts to prevent corruption and bribery.

Offering or accepting personal courtesy gifts may be allowed provided they have a minimal economic value, are infrequent and clearly appropriate under the circumstances. It is not allowed to give or receive cash or gifts which are given in return for a favour. Gifts shall not be given in a context or a way that might give reason to suspect that the recipient will keep such gift or benefit hidden from his or her superior. For example, gifts from Borregaard shall be addressed to the recipient’s official working address.

Events for customers shall always have a specific and relevant business purpose and can only be accepted if they are reasonable and appropriate with respect to both value and frequency. If someone is invited, this must be cleared with the person’s superior if Borregaard is to pay in whole or in part. The same principle applies to participation in such events organised by others, and transportation and accommodation must be paid by Borregaard. Employees or board members who have been offered or who have received gifts or favours shall immediately notify their immediate superior, who will determine whether or not the gift needs to be returned.

For further guidance, please see the Borregaard Anti-Corruption Manual

3.9    Act fairly in competition

Employees shall contribute to fair competition in compliance with competition laws.

Borregaard shall always compete in the market place in compliance with competition law. Employees who are involved in marketing, sales, purchasing or logistics activities shall ensure that they are familiar with applicable laws and internal rules and guidelines related to marketing and sales.

For further guidance, please see the Borregaard Competition Law Manual.

3.10      Never engage in insider trading

Employees and board members shall refrain from insider trading.

It is prohibited and punishable by law to trade in the securities of Borregaard (or other listed companies) or give advice to others about trading in such securities on the basis of non-public information which is likely to influence the price of the securities.

If an employee or a board member is in doubt concerning how to apply or interpret Borregaard’s requirements or public laws on insider trading, Borregaard’s Legal Director shall be consulted.

3.11      Never engage in money laundering

Employees and board members shall not in any way become involved in money laundering.

Money laundering is defined as arrangements implemented in order to make money acquired through criminal activities look as though it has been lawfully earned. Money laundering is prohibited by law, and will not be tolerated by Borregaard. Should an employee observe activities which may indicate that money laundering is, or has been, taking place in connection with company activities, the employee shall without delay report this to Borregaard.

The same rules apply to arrangements with the intent to avoid paying taxes, customs or other duties.

3.12      Say no to the purchase of sex services

Employees and board members shall not purchase sex services when representing Borregaard.

The purchase of sex services is prohibited by law in some countries. Even in countries without a legal prohibition, Borregaard does not permit such activities in connection with work or assignments for the Group.

3.13      Do not work under the influence of drugs and alcohol

Employees and board members shall not work under the influence of intoxicating substances and/or alcohol. 

The use of narcotic drugs is prohibited by law in most countries. Borregaard does not accept the use of narcotic drugs in connection with work. This also applies while at work on assignments and business trips for Borregaard. Alcohol may be served as part of corporate hospitality or company events, provided that the consumption is moderate, and provided it will not be combined with operating machinery, driving or any other work incompatible with the consumption of alcohol.

4         Compliance and implementation

4.1    The duty to comply

All Borregaard employees and board members have a personal responsibility for complying with all the requirements specified in this Code of Conduct. Employees and board members shall not act, or encourage others to act, contrary to the Code of Conduct. This requirement applies even when violation of a principle may appear to be in the interest of Borregaard.

Any uncertainty as to whether a particular activity is in accordance with the principles of this Code of Conduct, should, insofar as is practicable, be discussed in advance, primarily with the immediate superior. Borregaard believes in the value of discussions about responsible conduct in an improvement-oriented and informal manner. Nevertheless, breaches of the requirements set out in this Code of Conduct may lead to internal disciplinary action and in serious cases to dismissal or even criminal prosecution.

4.2    Whistle blowing

Observations of conduct which is illegal or represents a breach of the principles in this Code of Conduct should be reported either orally or in writing to the employee’s immediate superior. If the employee finds it difficult to report to his or her immediate superior, the report may be addressed to the head of the Company’s Human Resources Department, other leaders, the Managing Director/CEO or the Chairman of the Board. 

If the employee so wishes, a report may be given on a confidential or anonymous basis. All persons who have received such confidential report, or information about such report, shall keep the information strictly confidential in order to protect the whistle blower. Any report concerning illegal activities or breach of this Code of Conduct shall be taken seriously, and be appropriately investigated. Borregaard will not accept any retaliation against employees or board members who, in good faith, have reported a violation, or suspected violation, of applicable law or of this Code of Conduct.  An employee or board member who feels that a report has in any way been used against him or her by anyone in Borregaard may report this to his or her immediate superior or directly to the persons mentioned above.

In all cases, concerns and reports can also be submitted to Borregaard’s Legal Director, who in this function works independently from our line organisation, at the following e-mail address or telephone number:, +47 69 11 83 15.

4.3    Implementation and monitoring

The Senior Vice President of Organisation and Public Affairs is responsible for this document.

The responsibility for implementing this Code of Conduct in each company in the Group lies with the company CEO in collaboration with the HR function. The Code of Conduct shall be distributed to all employees, managers and board members. The Code of Conduct shall also be referred to in the company’s employment contracts and Personnel Handbook.

All employees, managers and board members shall carefully read this Code of Conduct. They shall also participate in training offered by Borregaard and/or the individual company.

Borregaard shall develop relevant support material, and may also assist the companies in training and awareness. The status of the companies’ activities related to this Code of Conduct will be reviewed annually as part of the business areas’ board meetings and Borregaard’s sustainability reporting.

This Code of Conduct is a statement of certain fundamental principles that apply to the conduct of employees and board members. It does not provide legal rights for any customer, supplier, competitor, shareholder or any other third party.



  • Corporate Responsibility
  • Code of Conduct
  • Human Rights
  • Anti-Corruption Manual
  • Competition Law Manual
  • Responsible Sourcing 
  • Whistle Blowing
  • Environment, Health and Safety