Compliance procedures

We must all work to ensure prompt and consistent action against violations of this Code. However, in some situations, it is difficult to know right from wrong. Since we cannot anticipate every situation that will arise, it is important that we have a way to approach a new question or problem. These are the steps to keep in mind:

Make sure you have all the facts. To reach the right solutions, we must be as fully informed as possible.

Ask yourself: What specifically am I being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced with, and the alternatives you have. Use your judgment and common sense; if something seems unethical or improper, it probably is.

Discuss the problem with your manager. This is the basic guidance for all situations. In many cases, your supervisor will be more knowledgeable about the question and will appreciate being brought into the decision-making process. Remember that it is your manager's responsibility to help solve problems. If you are uncomfortable discussing the problem with your manager you can talk to your Division director or human resources manager.

Seek help from Visma resources. In a case where it may not be appropriate to discuss an issue with your manager, or local management, call on +47 46 40 40 00 which will put you in contact with the Head of Administration at Visma headquarters. If you prefer to write, address your concerns to the Head of Administration or the Audit Committee of the Board of Directors.

You may report violations in confidence and without fear of retaliation. If your situation requires that your identity is kept secret, your anonymity will be protected. Visma does not permit retaliation of any kind against employees or officers for good faith reports of suspected violations.

Always ask first, act later: If you are unsure of what to do in any situation, seek guidance before you act.

All employees and officers are subject to Visma's Code, which describes procedures for the internal reporting of violations of the Code. All employees and officers must comply with those reporting requirements and promote compliance with them by others. Failure to adhere to this Code by any employee or officer will result in disciplinary action, up to and including termination.