Antibribery manual

1: Plany’s guidelines for antibribery

Plany shall conduct their business based on proper, ethical and sound business principles and abide by all laws and regulations. Plany will not allow or tolerate involvement in any form of corruption. It is a requirement for all Plany’s employees to fully comply with the company’s antibribery policy, and no Plany employee can give another Plany employee authorization to deviate from this. Any violation of relevant anti-corruption legislation will be considered a gross breach of the employee’s duties towards Plany, and will most likely result in termination of employment or other appropriate sanctions.

2: About this manual

This manual provides an overview of Plany’s guidelines for anti-corruption and explains the basic legal and ethical requirements Plany’s employees must follow to avoid being involved in corruption when they perform tasks on behalf of Plany. Department managers are responsible for making the rules of the manual known in their organization and for promoting a culture of awareness and compliance with the rules. They are further responsible for verifying that the rules are actually being complied with. All Plany’s employees are required to comply with the principles that are reviewed in this manual and shall also take appropriate steps to ensure that Plany’s independent business partners, including suppliers and clients, do not partake in corruption or other illicit or unethical activities in connection with their business with Plany.

3: Guidance and reporting

In your daily work you should seek guidance from and direct any issues regarding corruption to your manager. You can also contact the administration of Plany by Managing Director Jan Erik Våge Klepp, phone + 47 986 96040 if you have any questions regarding this manual or corruption legislation in general.

Non-compliance with the corruption legislation and Plany’s anti-corruption policy is a serious breach of the Plany’s business principles and can inflict Plany great damage. If you have reason to believe that employees or agents who represent Plany are involved in, or intends to involve themselves, in corruption this should be reported to the relevant manager.

4: What is corruption?

International conventions and agreements within the United nations, the World bank, The International Monetary Fund (IMF), The WTO, the organization of U.S. states, the OECD and the European Union impose countries to implement extensive national legislation against corruption. Corruption is forbidden in most countries in the world. It is important to note that Norwegian and other national corruption laws apply regardless of the country in which the actions are conducted, and regardless of whether corruption is lawful under the country’s national law. In practice, people and companies may be prosecuted by national corruption laws for actions committed anywhere in the world. In particular, the U.S. government enforces additional territorial jurisdiction to pursue corruption anywhere in the world, according to U.S. Foreign Corrupt Practices Act (FCPA).

According to Plany’s antibribery manual, corruption will include any attempt directly or indirectly (through intermediaries):

  • To give or offer someone an undue advantage on the basis of employment, commissions or assignment (active corruption), or
  • To claim, receive or accept an offer of an undue advantage on the basis of employment, office or assignment (passive corruption)    

5: Consequences of Non-compliance

The possible consequences of non-compliance with the corruption laws are severe:

  • Companies may be prohibited from doing business in certain countries or industries or with certain governments or be prohibited from participating in public tenders
  • Companies may be held liable for claims from third parties who have suffered damage due to the corrupt activity, e.g. competitors who may have missed out on business opportunities
  • Corruption often results in negative publicity which can be very detrimental to a company’s reputation and business associates
  • Persons involved in corruption will risk criminal penalties, including fines and imprisonment


6: Relationship with customers, suppliers and public servants

Plany shall act in an open, ethical and lawful manner towards all potential or existing customers, suppliers and government officials. Plany shall always carry out their contractual obligations in accordance with the terms of the current contract, unless minor deviations are approved by the appropriate line managers and duly documented in the company’s archives. Cash payouts, if any, or payments to unauthorized recipients or account numbers are not accepted.

All sales and marketing activities, coverage of third party expenses, payments and contract execution on behalf of Plany shall be open and transparent both internally and towards Plany’s counterparts. Any invitation to individuals to participate in events or activities that are wholly or partially paid by Plany shall be directed to the relevant level of management in the relevant legal entity or public office. Special care must be taken in relation to civil servants and in situations where the recipient at the current time has a position where he or she can make discretionary decisions or actions that may be beneficial to Plany. Plany’s employees must consult their supervisor if there is any doubt if special marketing or service activities are in accordance with Plany’s or the appropriate third party’s anti-corruption policy.

All expenses shall be approved according to the company’s standard procedures and documented and registered in accordance with the appropriate accounting standard. Plany’s employees shall not, under any circumstances, receive from or give to a supplier or business partner any kind of undue benefit, including personal discounts, commissions, undocumented price discounts, etc.

7: Travel and entertainment expenses

Payment for reasonable and real expenditures relating to seminars, travel, meals, accommodation and events for potential and existing customers may be allowed if these expenses are directly related to marketing or demonstration of the Plany product portfolio and services or for contract fulfillment purposes.

Payment of expenses for travel, meals, accommodation or events for family members or friends of public servants or business associates is not permitted.

Although exchange of gifts with customers, suppliers and business partners is a common part of international business, Plany shall under no circumstances offer gifts in the form of money. Gifts, except money, may be allowed, however, if:

  • They have minimal economic value, are a rare occurrence and are given in situations where it is clearly appropriate
  • They are not granted in a context or in a manner that gives reason to believe that the recipient will hold such a gift or benefit hidden from their superiors. Gifts should, for example, be sent to the recipient’s office address at the appropriate legal entity or public authority
  • They are not given as a counter-performance for any benefit

8: Relationship with agents and other representatives

Plany does not tolerate corruption from any of their agents or representatives. Agents and other representatives acting on behalf of Plany, shall act in accordance with Plany’s antibribery manual. Plany should always act with the necessary care and take the necessary steps to ensure that Plany’s agents and other representatives comply with the antibribery manual.