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. 


Management

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. 


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.



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.


Measures


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. 


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