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SUSTAINABILITY LIBRARY 2022 Policies Policy: Sanctions

Policy: Sanctions

Sanctions policy

Owner/approver: CEO Lerøy Seafood Group

Valid from: 2022-04-24


The purpose of Lerøy’s sanctions policy is to outline clear expectations and requirements related to compliance with sanctions, including export control, which is also considered to be encompassed by the concept of sanctions.

The policy provides a concise and principle description of how Lerøy works to comply with the applicable sanctions regulations.

Lerøy is obliged to conducting its business with integrity and in accordance with the applicable laws and regulations of the countries in which it operates.

It is Lerøy’s policy to forbid and actively work to prevent any activity that conflicts with the applicable sanctions regulations.

Lerøy implements the necessary measures in line with a risk-based approach in order to ensure compliance with the relevant sanctions regulations, including ensuring that goods/services that are sold/bought are not subject to sanctions, whether directly or indirectly, and that Lerøy does not transfer or make available funds or assets to sanctioned parties. Lerøy also actively works to prevent sanctions evasion.

Lerøy structures and organises its operations in a manner that reduces the risk of sanctions violation to a minimum. Lerøy has established secure processes to prevent, identify and manage any risks associated with this work. These processes are described in more detail in Lerøy’s underlying procedures.

Lerøy provides training and guidance to its own employees and hired staff with regard to Lerøy’s Code of Conduct, as well as customised sanctions training for relevant positions. A differentiated and up-to-date training programme ensures that Lerøy’s own employees and hired staff are able to recognise conditions that can represent a risk of sanctions violation.


Applies to

The policy applies to Lerøy Seafood Group ASA and its subsidiaries (Lerøy), including all of Lerøy’s own employees and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way. Lerøy’s business partners are required to comply with the Supplier Code of Conduct.


  • Sanctions – refers to non-military national security and foreign policy instruments aimed at government authorities, companies, groups, organisations or individuals in the form, for example, a weapons embargo, travel restrictions, financial freeze measures or other financial measures, such as import and export restrictions or trade restrictions for specific goods or services.

  • Export control – refers to rules that can be implemented on the national or international level in order to regulate, ban or require licensing for the export of goods.

  • Sanctions evasion – refers to activities with the purpose or effect of evading sanctions regulations, such as acting as a proxy for physical or legal persons included in sanctions lists. Intentional sanctions evasion is a criminal offence under Norwegian law. Counties associated with frequent sanctions evasion represent an increased evasion risk.


Framework and principles

Sanctions are implemented by way of various sanctions regimes, including in the EU, Norway, UN, U.S. and Great Britain. These regimes include different sanctions programmes. A sanctions programme may be aimed at a specific country or regime and define restrictions on trade with or in such countries or with persons/companies in such countries. There are also sanctions programmes that are not country-specific, such as programmes aimed at gross human rights violations or corruption. Sanctions can define restrictions associated with trade with countries and areas, as well as certain types of products/services or certain types of companies, individuals or organisations/groups.

Lerøy is exposed to different sanctions regimes through its geographical presence, employees, third parties, products or other factors, such as currency use. Different sanctions regimes may be relevant for a specific activity or transaction, and the types of regimes and underlying sanctions rules that apply must be examined specifically for each activity or transaction. Lerøy Seafood Group ASA has its headquarters in Norway and consequently, will always make every effort to comply with sanctions regulations issued by Norway, the EU and UN, as well as other sanctions regulations that apply to individual transactions or trade.


Roles and responsibilities

All employees of Lerøy and hired staff, as well as anyone who carries out work on behalf of Lerøy or represents Lerøy in any way, are required to comply with this policy.

The Group management of Lerøy Seafood Group ASA and local management at all subsidiaries are responsible for ensuring that the company has staff with the skills required to ensure compliance with sanctions.


Ownership and implementation

  • The CEO of Lerøy Seafood Group is the owner of the policy and responsible for all updates.

  • The policy has been approved by the corporate management of Lerøy, submitted to the Audit Committee and approved by the Board of Directors.

  • The CEO of Lerøy Seafood Group ASA has overall responsibility for the policy.