Anti-Corruption and Bribery Policy v. 1.2

Anti-corruption and Bribery Policy

 

SalMar Tenet

Focus on the Solution  

CSRD Reference

G1 - Business Conduct 

Purpose

SalMar is committed to conducting business with integrity and transparency. This policy ensures zero tolerance for corruption, bribery, and money laundering across all operations and business relationships. 

Scope

This policy applies to all SalMar employees, board members, and any third party acting on behalf of SalMar. 

 

Governance and Accountability

Roles and Responsibilities

The Board of Directors holds ultimate responsibility for compliance with anti-corruption standards. The Senior Management ensures implementation of this policy across all operations.  

Employees must never offer, promise, give, or accept bribes, unlawful gifts, or improper benefits to gain advantage for themselves or SalMar. All benefits received from business partners must be reported to the company. Managers are responsible for approving invitations or events and ensuring compliance with this policy. 

Monitoring and Reporting

Corruption and bribery risk assessments are conducted regularly. All breaches or suspected breaches must be reported through SalMar’s whistleblowing channel, which is managed by an independent third party and available 24/7. Failure to report breaches will be considered a violation of SalMar’s Ethical Guidelines. 

 

Strategic Framework and Targets

SalMar enforces zero tolerance for corruption, bribery, and money laundering. All transactions must comply with the “arm’s length” principle, ensuring fair market terms. The company only trades with suppliers conducting legal business and applies risk-based screening to prevent money laundering and terror financing. 

The following sections outline the Group’s most material impacts and risks, along with strategic targets established.  

Impacts

Anti-corruption and bribery training 

The ability to identify and understand risks is essential to preventing and mitigating incidents of corruption and bribery. Targeted training is therefore provided to key personnel, including the Board of Directors and Executive Management. 

Familiarisation with the Group’s Anti-Corruption and Bribery Policy and Anti-Competitive Behaviour Policy also constitutes an important component of the Group’s training programme. 

Risks

Incidents and accusations   

SalMar’s global presence brings an increased risk of incidents related to corruption, bribery and anti-competitive behaviour. There is also risk of misunderstandings or misinterpretations that could lead to false claims and accusations of wrongdoing. 

False representation 

False representation refers to the act of an individual falsely and maliciously claiming to represent SalMar or SalMar’s products. This may occur in corporate contexts, such as negotiations or commercial dealings, or through the falsification of product labels intended to imitate SalMar’s established products. 

Targets

SalMar maintains zero tolerance for corruption, bribery, and money laundering. All employees must complete compliance training, and all high-risk transactions must undergo due diligence and approval by the Senior Management. 

 

Operational Measures

SalMar prohibits any form of bribery or corrupt practices. Employees may not accept gifts, benefits, or invitations without prior approval from the company. All benefits must be reported. Due diligence and background checks are mandatory for agents and representatives in high-risk countries. Conflicts of interest must be disclosed immediately. All transactions follow the “arm’s length” principle.