EXECUTIVE SUMMARY Following an investigation into potential bribery in its Danish subsidiary, Atea has undertaken a self-cleaning process in accordance with EU law. Version 1.0.- published July 2017 EXECUTIVE SUMMARY 2 EXECUTIVE SUMMARY Following an investigation into potential bribery in its Danish subsidiary, Atea has undertaken a self-cleaning process in accordance with EU law. Introduction sufficiently effective. Consequently, Atea A/S and Compliance regime 2. Implementation of a compliance programme Since June 2015, Atea in Denmark (Atea A/S) the Atea group have since 2015 implemented The top management of the Atea group has of high international standard, including has been the subject of a police investigation due a comprehensive compliance regime and updated the group’s compliance regime to high the implementation of a thorough risk to a suspicion that former Atea employees have organisational measures to avoid that similar international standards. Atea has been assisted assessment bribed public employees in a period from 2009 cases may occur again. on the compliance work by Deloitte and Nielsen The risk assessment identified a list of special until 2014. No current Atea A/S employees are Nørager law firm. risk areas such as sponsorships, donations, charged, indicted or convicted, nor does the case The following is a summary of those measures. events, travels, samples and demo products. include the Atea group. The work has included the following elements: It also revealed the following: Organisational measures - The need to update the internal rules so Atea A/S has fully cooperated with the Danish Atea A/S has introduced an accounting proce- 1. A detailed and thorough review and they are now more operational for Atea police in the investigations. dure allowing more efficient control with mapping of existing procedures, routines employees in daily use. transactions and accounts, giving both and culture - The need to establish a strengthened Atea A/S and the Atea group take the strongest Atea A/S and the customers far better control This review revealed that Atea A/S has been compliance organisation in each country. possible exception to any kind of bribery and options. Atea A/S has phased out a cash sales subject to serious abuse of power by former - The need to establish more effective control similar unethical and illegal conduct and have thus account, and invoices must always be issued, executive employees involved in the case. of approval processes in the risk areas. undertaken substantial measures to counter the including for demo products, replacements and Atea A/S and the group have consistently - Suppliers should be required to comply with risk of such occurrences. the like. had procedures and practices in place to the group’s Code of Conduct. counter such actions, but these procedures Before the case arose, Atea A/S had internal Further, the guidelines concerning internal authori- have turned out not to be strong enough to rules and processes establishing bribery and sations has been updated, stating for example prevent and catch such serious violations of similar conduct as unacceptable. Unfortunately, that salesmen have no authority to approve the internal rules. the case has shown that those measures were not business arrangements or sponsorships. EXECUTIVE SUMMARY 3 3. Design and implementation of an updated 4. Design and upgrade of policies, procedures 6. Insertion of contractual provisions in compliance organisation and guidelines employment and cooperation agreements The group and Atea A/S have worked The Atea group has had ethical guidelines stating that bribery is a material breach. intensively on upgrading the compliance in place prior to the occurrence of the case. organisation, including underlying policies. These have now been upgraded, clarified The group and Atea A/S now continually work A compliance function has been established and implemented in a new Code of Conduct. with compliance, including regularly upgrading through the appointment of a Compliance All employees are examined in the Code of and improving the compliance regime. See more Officer in each country, who reports to the Conduct. details in the full report. Atea Group Compliance Committee, which is supervised by Atea ASA’s Audit Committee. 5. Design and implementation of monitoring, The purpose of the Compliance Committee is control and follow-up procedures to “facilitate the development, implementation To ensure that procedures, guidelines and and operation of an effective compliance policies are followed in all parts of the regime for the group”. organisation, Atea A/S has introduced a structure for comprehensive monitoring of the identified risk areas. Holding Norway Sweden Denmark Atea ASA Atea AS Atea AB Atea A/S Atea ASA Brynsalleen 2 Kronborgsgränd 1 Lautrupvang 6 Brynsalleen 2 Box 6472 Etterstad Box 18 DK-2750 Ballerup Box 6472 Etterstad NO-0605 Oslo SE-164 93 Kista Tel:+45 70 25 25 50 NO-0605 Oslo Tel: +47 22 09 50 00 Tel: +46 (0)8 477 47 00 O rg . n o 25 5114 8 4 Tel: +47 22 09 50 00 Org.no 976 239 997 Org.no 556448-0282 [email protected] Org.no 920 237 126 [email protected] [email protected] atea.dk [email protected] atea.no atea.se atea.com Finland Lithuania Group Logistics Group Shared Services Atea Oy Atea Baltic UAB Atea Logistics AB Atea Global Services SIA Jaakonkatu 2 J. Rutkausko st. 6 Smedjegatan 12 Mukusalas Street 15 PL 39 LT-05132 Vilnius Box 159 LV-1004 Riga FI-01621 Vantaa Tel: +370 5 239 7899 SE-351 04 Växjö Tel: +371 67359600 Tel: + 358 (0)10 613 611 Org.no 122 588 443 Tel: +46 (0)470 77 16 00 Org.no 40003843899 Org.no 091 9156-0 [email protected] Org.no 556354-4690 [email protected] [email protected] atea.lt [email protected] ateaglobal.com atea.fi atealogistics.com.