Startup Norway AS
Ethical guidelines Code of Conduct

Date of Version: 3 March 2022

Startup Norway  is committed to help advance and develop the Norwegian startup ecosystem. And in doing so, we aim to apply the highest standards of ethical conduct, and fully integrate ethical principles in the decisions we take. 

All employees and attendees to participate in SN programs and activities should be guaranteed an environment free of harassment, discrimination, sexism, and threatening or disrespectful behaviour. We are taking active steps to prevent and disencourage participants and employees from being responsible for or victim of these behaviours in any Startup Norway hosted arena. If any such event occurs, Startup Norway will act to stop the incident, prevent its recurrence and discipline and/or take other appropriate action against those responsible. 

As a company, SN is conducting all operations, programs and business activities with integrity and respecting cultures, dignity and rights of individuals where we are present. 

Our Ethical Guidelines apply to all stakeholders categories: startups, investors, employees, partners, board members. Additionally, it also extends to everyone who participates in Startup Norway programs and activities including affiliates providing services to SN such as mentors, invited speakers,  volunteers, and other third parties, such as contractors, vendors, and visitors. Failure to do so can result in the termination of employment, their relationship with SN or their expulsion from the program.

Integrity and compliance to our ethical guidelines is a commitment that must direct our behaviours beyond mere compliance with law and regulation, driving us to make the right choices facing any situation.

Startup Norway’s Ethical Guidelines outlines commitments and requirements regarding ethical business practices as well as personal conduct.

Startup Norway will not compromise on its values, commitments and expectations established by the Ethical Code of Conduct. Any known breach of the Ethical Code of Conduct must be reported immediately. 

Our Values

These are the values we apply to our everyday business practice and what we believe are synonymous with startup environment/ecosystem values. 

1. Community first

2. Give back

3. Empower startups

4. Have impact

Startup Norway was born with the mission to support the Norwegian Startup Ecosystem and to promote more successful Norwegian entrepreneurial stories. We believe in the power entrepreneurs have to shape the future and in the positive impact they can have on the development of societies. But we also understand that success stories are built collectively and that requires a strong and healthy entrepreneurial community that embraces innovation and empower founders.   

Startup Norway supports the Norwegian startup ecosystem by supporting the startups and the supporters of startups. We understand that startup initiatives can only lead the change and have a visible impact if they are given the opportunity and means to do so. And most importantly, if they are prevented from avoidable mistakes and protected from unprofessional behaviours. Supporting startups is about believing in people and giving them a chance to succeed with their ideas and dreams. But it is also about participating in the development of your community and searching for a positive impact.

With our programs and with every step we take with Startup Norway, we are aiming to have that positive impact on the startup community. We are educating the present and future generation of Norwegians to support founders with their knowledge and capital. We are teaching them selflessness, challenging to give back to the community and to take an active role in its changes and development. We are building a safe and healthy startup community by promoting good practices and raising concern about the social responsibility the supporters and startups bear. 

Responsibility & Implementation

Personal Responsibility

As a Startup Norway employee, you shall aim to practice good judgment, familiarize yourself and act following the principles of the Ethical Guideline Code. If you will experience an ethical dilemma, you can consult your direct manager, HR or the appropriate authority. 


Managers are in charge with communicating clearly the Ethical Guidelines Code of Startup Norway to all of their direct reports, as well as extending it over any external area and / or stakeholders that fall under their responsibility.

Board of Directors

The Board of Directors at Startup Norway as well as the CEO is directly responsible for implementing and overseeing that the Ethical Guidelines Code is up to date, freely available for internal and external stakeholders, along with necessary training to clarify all its parts and structure, so that everyone understands it properly and applies it accordingly.

Declaration of Compliance

Every employee (including temporary hires and / or contractors) need to be familiarized and asked to confirm both, the comprehension and their compliance with the Ethical Suppliers, partners, investors, mentors, and all other relevant parties shall also get familiarized with the Ethical Guidelines Code and confirm compliance of their actions throughout the collaboration period. 

Measures to prevent disrespectful behaviours

Acting with Integrity

  • Anti-Money Laundering 
  • Confidentiality
  • Conflict of Interest 
  • Fair Competition

Startup Norway & People

  • Personal Conduct
  • Anti-Harassment & Intimidation 
  • Material Reviewing 
  • Speak-up Policy
  • Gender Equilibrium
  • Diversity & Equal Opportunities

Environment & Finances:

  • Protecting the Environment 
  • Transparency & Financial Reporting

Startup Norway is taking active steps to prevent and disencourage participants and employees from, voluntary or involuntary, taking part in disrespectful or illegal behaviours towards other participants during the course of the program. 

As educators of the future generation of supporters and entrepreneurs, we believe our biggest contribution to mitigate these bad behaviours that threaten so much of our community is in the preventive measures we can put in place. We are a point of reference for the ecosystem and therefore, we have the moral responsibility to set an example of good practice and the obligation to educate investors and entrepreneurs in the values of respect and diversity.

We have set ambitious gender equilibrium plans and we demand an observance of our code of conduct as a precondition to join in our program, in order to encourage a climate of respect, openness, and trust. We have set transparent and measurable selection criterias to prevent all types of biases and secure the same opportunities to all participants.  We will continue sharing and promoting our values by including new lessons in Business Ethics and founder friendly behaviour as a part of our program curriculums. As well as by empowering participants to take care of each other  in the event of disrespectful behaviour and always to speak up.

Specific measures

1. Anti Corruption: 

Startup Norway actively forbids any form of offering or acceptance of bribes towards any employee, person that is public or private directly or through a third party. A bribery is considered any offer that equates to a pay, a benefit of some sort or gift that will serve as an advantage and / or influence the course or outcome of business or decision. 

Taking direct or indirect part in bribery can result in liability on both, personal and company level. 

2. Anti-Money Laundering

Any money laundering that supports criminal activity, corruption and tax evasion is strictly prohibited. This includes, but not limited to money, physical assets, as well as intangible assets. Startup Norway will exclusively conduct business with only reputable partners and stakeholders that operate legal activities. 

Startup Norway will always conduct all necessary due diligence to have the overview and business background for all new partners, to ensure the origin and destination of money. 

3. Confidentiality

Startup Norway assures all stakeholders that it will protect confidential information, and that it won’t misuse any type of information that belongs to it and / or any of the stakeholders and partners. 

Startup Norway will keep all information confidential to ensure that no third unauthorized parties will have access to it. 

4. Conflict of Interest

To ensure that no business operations are affected by a conflict of interest (personal

relationships, external activities or a potential interest in another venture that can influence a decision / project / collaboration), Startup Norway monitors and asks to be informed in advance about it, by employees, partners, stakeholders or any other relevant third parties. 

In situations where a conflict of interest can’t be reasonably avoided, it needs to be reported to all parties involved, and have management evaluate the next course of action, to ensure the best course of action. 

5. Fair Competition

Startup Norway ensures a fair competition applied to all levels of its activities and its business operations. We are open to fair and open competition through all programs and activities. All our operations comply with antitrust laws. We ensure that no activity uses access to receive, obtain or share nonpublic competitive information or commercially sensitive information that may put any other parties at a disadvantage. 

6. Personal Conduct 

Participants in the Startup Norway programs are expected to become familiar with the applicable Norwegian regulation and Startup Norway Ethical guidelines and to comply with both their letter and spirit. Prior to enrolling in any program or activity run by Startup Norway, participants, employees and third parties will state in a written document their conformity to the SN Ethical guidelines and their personal responsibility to incorporate the principles of this Code during their participation within the Startup community. 

7. Anti-Harassment & Intimidation 

At Startup Norway people is treated with respect, fairness and dignity regardless of their nationality, race, gender, age, customs, culture, sexual orientation, disability, political opinions, religion or ethnic background etc. 

At SN we do not accept nor tolerate any form of abuse, harassment, intimidation or sexually offensive behaviour. Comments, jokes, messages or any other form of communication that are aimed at harassment and / or intimidation are not accepted and are taken immediate action against. 

8. Material reviewing

All materials submitted by the startups, investors, mentors, speakers and other third parties, with the purpose of being shared or used for the program can be banned from use if it is understood that it could cause disruption during the event or make the environment hostile for any participants. 

9. Speak up policy

We systematically encourage our participants, employees and affiliates to speak up in order to help us build an inclusive environment and protect the reputation of the whole startup community. Participants subject or witness to any misconduct or illegal behaviour, or with concerns that any of these actions could take place, are encouraged to comment directly or to report the incident directly to the SN team, who will take active measures to address it. 

With this policy we aim to encourage members of the startup community to take care of each other by reacting and speaking up whenever they are witness to disrespectful behaviour and to create awareness of the importance of correcting these behaviours collectively. 

Moreover, Startup Norway Program Managers and employees are aware that they have a special responsibility to encourage participants and other third parties to communicate openly about program issues and to create an environment that encourages discussion at all levels of the organization. 

10. Gender Equilibrium

We are aware of the present gender imbalance in the startup community and we are taking active measures to address it and achieve gender equality in our initiatives. We are proud to note that we currently have a 50% female ratio inside our organization. 

In spite of this, we are aiming to achieve a 50% ratio of female members for all aspects of our programs and activities: Startup Norway team, investors participating, startup founders or representatives, invited speakers and Board members. In order to achieve this, we are currently working on a plan of action to recruit and attract more female figures in all levels of our organization and in all aspects of our programs.

At Startup Norway we implement an open and welcoming culture for all people, with diversity at its core. This allows us to create a balanced, rational and a highly representative environment within our organisation, programs and partners. This starts from the Commitment of the HR to embed and encourage the presence of different perspectives and values. 

Our cultural norms are rooted in values of authenticity and egalitarianism through relationships and autonomy, which serves as a northern light to guide all actions within our organisation.

The Gender Expertise is at the centre of all of our Human Resource initiatives and guidelines, programs and all external partnerships. 

Through a gender balanced decision making team, we aim to bring gender expertise that gets implemented at length through the entire operation systems of the company (recruitment, career advancement, equality of opportunities, internal & external programs, events etc.)

Work Life Balance + Organisational Culture 

At Startup Norway we express compassion and concern for each other, which can be seen as the ethical glue that holds the team together. Each team member is rooting for the others to succeed, and in turn, that creates a collaborative approach in our work. 

We give credit to each other and celebrate the team’s success. This creates a high level of psychological safety in the organisation, which is related to creative thinking and a challenging environment. In order to achieve this culture, we have several team building activities throughout the year, such as cabin trips and afterwork events. We also include people in other activities and value ideas and suggestions.

Startup Norway is committed to ensure that everyone can make full use of their experience, background and talents. We encourage, employ and work with everyone, regardless of their nationality, race, gender, age, sexual orientation, disability, race, political opinions, religion or ethnic background or any other basis prohibited by law. 

We understand that work and home exist as a whole, and we strive to achieve a good balance between work and personal life. In Norway, we are obligated to give 25 days of paid vacation and encourage our employees to take 4 weeks in summertime. During this time, business activity normally slows down for people to enjoy time with family, friends and enjoy some time off. 

On workdays, we also value a good work-life balance, where we give flexibility to our employees. Our core working hours are between 09 and 15, and outside these hours people choose when to work. We trust our employees and do not clock in and out. Employees also have the choice where they want to work.

Other work-life balance measures are paid parental leave, where we are obligated by law to give up to 12 months leave. By law, the mother must use 9 weeks of leave after the child is born and the father must use at least 14 weeks of leave before the child is 3 years old. When it comes to the rest of the parental leave, many favour the model of individual choice. We encourage our male employees to use their share of leave, but we respect all our employee’s choice of how they choose to use it. In addition to parental leave, we also provide study and sick leave.

We also have affordable childcare and a great educational system in Norway, which makes it easier for people to succeed in their careers. These measures are implemented to strengthen men’s ties to their families and to include them in the parenting, which promotes gender equality and empower women to enhance their careers on the same basis as men.

11. Diversity & Equal Opportunities 

Startup Norway is committed to ensure that everyone can make full use of their experience, background and talents. We encourage, employ and work with everyone, regardless of their nationality, race, gender, age, sexual orientation, disability, race, political opinions, religion or ethnic background or any other basis prohibited by law.

We base all work-related decisions exclusively on merit.

Gender Balance in leadership & Decision Making

Together with a flat organisational structure, Startup Norway’s decision-making power lies in the lower levels of the organisation. Often several people are involved in the decision making process, while also ensuring there is a gender balance within decision making actors. We base all work-related decisions exclusively on merit, while also encouraging and promoting a high level of awareness in both, gender equality as well as awareness of unconscious biases.

We are aware of the present gender imbalance in the startup community, and we are taking active measures to address it and achieve gender equality in our initiatives. We are proud to note that we currently have a 50% female ratio inside our organisation. Relatedly, our CEO is female, and the rest of the management and the board has a big share of female leaders.

In spite of this, we are aiming to achieve a 50% ratio of female members for all aspects of our programs and activities: Startup Norway team, investors participating, startup founders or representatives, invited speakers and Board members. 

In order to achieve this, we are currently working on a plan of action to recruit and attract more female figures in all levels of our organisation and in all aspects of our programs. 

Measures Against gender biases, including sexual harassment

The measures we have in place to prevent gender biases are activities that include sessions for all employees on expectations, policy and processes, as well as practical advice on how to deal with different situations. 

In addition to that, our internal code of conduct sheds light on employee relationships’, what is considered (or not) harassment, with clear mechanisms in place to ensure that potential victims or witnesses of harassment are not deterred from reporting incidents. 


Awareness on gender Equality

Awareness of unconscious bias  for A.staff & B. Decision makers

In addition to our own internal gender balance and constant reinforcement of these principles, we ensure equality in our all programs and educational material, and value the importance of the topic, as well as the benefits for startups and society.

The psychologically safe environment at Startup Norway makes it easier for female employees to and report gender-based violence. Employees are listened to and taken seriously if there is any occurrence of such behaviour. We have a zero tolerance for gender-based violence, and reinforce this message on several occasions. 

Our Training materials reflect through several lenses the importance of awareness towards gender equality. This manifests through the fact that all our programs:

  • Aim to have an equal gender split of participants
  • Have speakers from both genders, with multiple occasions where women are in majority on experts panels, keynote speakers or fireside chats 
  • Have both staff and decision makers where the gender parity is always top of mind  
  • Have external partners where we, at minimum have gender balance or predominantly programs that are aiming to bring more female actors into traditionally men dominated areas (i.e investing)

In addition to that, Startup Norway reinforces at all times through training and post programs overviews any opportunities to overcome and / or address any unconscious biases that may have protruded in the execution of those programs. 

We deploy Empowerment programmes to strengthen the concept and applications that will reflect in the gender equality representations on both internal and external levels.

Data Collection

  • Sex / gender on personnel
  • Annual Reporting based on indicators 

Constant monitoring, reporting and data collection is key to ensure the gender equality ambitions of both the staff and all stakeholders that interact and / or participate in our programs. 

This reflects on both visible key metrics like gender split in the team and program participants, as well as internal conscious effort to proactively reach it (be that from keeping open registrations for women only or outreach female potential participants).

12. Selection criteria

We believe not only in gender equality but also in equality related race, color, nationality, ethnicity, class, religion, disability, age and sexual orientation, and we act in accordance by building selection processes based purely on merit. 

For the purpose of recruiting and selecting the startups that will participate in our programs we will establish transparent and measurable selection criterias based on proven achievements and merit of the candidates. The selection criterias will be made public and shared with the partner prior to the opening the application process for startups.  Non-selected startups will be given the opportunity to receive feedback about their candidacy and reasons for not being selected.

13. Protecting the Environment

Startup Norway shall act and conduct business to ensure profitable programs and products, while adhering to relevant local laws and standards, to strive to minimize our environmental impact. Startup Norway takes a sustainable approach in our daily operations that include responsible usage of resources, reducing produced waste, as well as improving and continuously educating an environmental mind-set amongst our employees. We aim to understand the environmental impact in our area of business and minimize our impact on a continuing basis. 

14. Transparency & Financial Reporting

Startup Norway shall communicate relevant business information in full and on a timely basis to its employees and relevant external stakeholders. All accounting and financial information, as well as other disclosure information, must be accurately registered and presented in accordance with Norwegian laws, regulations and relevant accounting standards.

Response in case of incident

Next to our preventive measures, we have set a standardized procedure to collect incident reports from participants and employees and to respond immediately. 

We currently have a form available on our website where any participant can report and provide details of the incident, both personally and anonymously. The form is designed in a way that does not require the participant to provide contact details in order to submit a response. Participants can also make a personal report by directly notifying  the SN staff present at the moment or by contacting an emergency number that will be provided to all participants. 

Each of our staff members are prepared and empowered to raise concerns of misconduct. Any SN staff member can issue a verbal warning to a participant whose behaviour goes against the program Ethical guidelines. They are obliged to raise every issue they experience or are witness to and we ensure that participants bringing forward concerns are protected from acts of retaliation. Participants asked to stop any disrespectful behaviour are expected to comply immediately. 

Our CEO, Maja Adriaensen, is responsible for receiving the incidents, taking immediate measures to stop or minimize them and submitting a report to an internal investigation. 

Opportunity to rectify

We believe in the power of dialogue and in the opportunity to rectify. Therefore, the offender will be identified and be given the opportunity to justify their acts by contributing to the investigation. However, we take misconduct seriously and we are determined to take corrective and disciplinary actions against any individual who has deliberately engaged in serious misconduct or illegal behaviour based on the findings of the internal investigation.


Startup Norway retains the right to take any actions to keep preserving the decency of the event and maintain a welcoming environment for all participants.

We expect all of our employees, Board members, speakers and other third parties to know and follow the Ethical guidelines in connection to their work with us. Failure to do so can result in disciplinary action, including the termination of employment or their relationship with SN. For other program participants that engage in such conduct, we reserve the right to warn the offender or exclude them from the program, without notice or refund, and ban them for any future event or activity.

Internal investigation

Startup Norway will investigate allegations of misconduct in accordance with a pre-set process, which promotes confidentiality, dignity and respect, objectivity, promptness and non-retaliation. 

Approved by: CEO Maja Adriaensen 

Date: Sept 2022. 

Maja Adriaensen