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Business ethics

Code of Conduct


Lerøy Seafood Group (the Group) has a strict policy to promote and ensure compliance with all applicable laws and regulations. Failure to comply with relevant requierments can result in legal penalties, fineas and reputational damage.

Compliance ensures that the organization is operating in an ethical manner and thus becomes more attractive to customers, investors and business partners.

Consistent compliance ensuring has positive impact on the organization. It reduces risk, builds trust, improves reputation, strenghtens business relationships, promotes evidence-based decision making and provides competative advantage.  

Lack of compliance can have several negative impacts on the organization and its business relationships. This includes legal and financial penalties, reputational damage, increased risk, lack of trust as well as negative impact on the economy, environment, people and their human rights such as violation of fundamental rights, discrimination, injustice and overall negative impact on the society. 

The Group constantly determines, and monitors compliance requirements related to its business activities and evaluates how these should be applied to the organization. Relevant compliance requirements such as ensuring and enabling anti-corruption, anti-bribary, anti-money laundering, environmental protection, compliance with health and safety requirements etc. are taken into account when planning, implementing and maintaining the Group’s compliance obligations as well as assessing its compliance performance.

The Group strongly believes that an ethical business culture and behavior is key for creating and maintaining a sustainable company. The Group is committed to working ethically, with integrity and always lawfully everywhere we operate and with everyone we do business with.

The Group is a signatory of UN Global Compact and has committed to both avoiding corruption as well as developing policies and implementing measures to address corruption internally and within our supply chain. Every effort shall be made to safeguard local, regional and global environmental aspects. Aspects regarding animal ethics shall also be given full consideration. 

Compliance Reporting 

In order to monitor if Lerøy is involved with negative compliance-related impacts through its activities or as a result of its business relationships, all companies within the group complete detailed compliance reporting quarterly. Significant instances of non-compliance are identified through this reporting.

Significant instances of non-compliance are occurrences or events that have an actual or potential impact on an outcome of an instance. The significance of an instance is determined by its relevance to the particular situation and its potential to form the future course of events.

The impact of significant instances can range form minor to major, depending on the context and stakeholders involved. All instances that meet the criteria above shall be reported.

The reporting covers such issues as compliance breaches, business code of conduct, whistleblowing, concerns regarding customers, credit policy, potential corruption cases and other issues of concern. In case of discrepancies an appropriate action is taken. The nature of the action taken is defined by the nature and severity of the discrepancy.  

Compliance reporting helps providing knowledge and insights from past compliance failures and successes. Lerøy is constantly working with developing strong compliance culture – through risk assesments and information campaingns which are aimed at explaining compliance requirements and expectations as well as be aware of potential compliance-related risks. 

Lerøy provides frequent compliance-related training to its employees and workers to ensure that they are equipt to identify problematic compliance issues and report them. The content/focus areas of the information campaigns/training can be defined by the nature of recent and relevant compliance-related cases. 

Lerøy is aiming at strenghtening its compliance reporting by providing clear and transparent information the company’s compliance-related activities to its stakeholders. Transpartent compliance reporting is important to building trust and credibility as well as demonstrate that the company is commited to ethical and responsible behaviour. 

Total number of significant instances of non-compliance with laws and regulations during reporting period: 
Instances for which fines were incurred Monetary sanctions Non-monetary sanctions
Penalty for breach of the obligation to declare when exporting (issued by Norwegian Customs) - Lerøy Seafood AS NOK 12 430 -
Penalty for incorrect VAT reporting (issued by Turkish Revenue Administration) - Lerøy Turkey TRY 36 000 -

Number of instances for which fines were incurred: 2

Monitary value:

NOK 12 430

TRY 36 000

There were no instances of non-monetary sanctions in 2023.

Information regarding previous reporting periods (2022)

NB! 2022 was the first year the company reported the number of significant instances of non-compliance with laws and regulations.

Instances for which fines were incurred Monetary sanctions Non-monetary sanctions
Infringement fee – personal injury in 2020 Lerøy Norway Seafoods AS (1) NOK 400 000 -
Infringement fee – personal injury in 2020 Lerøy Norway Seafoods AS (2) NOK 400 000 -
Infringement fee – fatality in 2021 Lerøy Norway Seafoods AS NOK 700 000 -
Infringement fee – an employee/ worker did not have a residency permit in the country, Lerøy Smøgen (Sweden) SEK 94 600 -

Number of instances for which fines were incurred: 4

Monitary value: 

NOK 1 500 000

SEK 94 600

Reporting of Critical Concerns

Concerns regarding compliance and business conduct can be reported anonymously via an independent whistleblowing channel (for more information, please, visit chapter on Whistleblowing).  

Critical concerns are reported to the Management team and the Board quarterly as a part of the Group's Compliance report.

Compliance is an ongoing process which it requires coninuous monitoring and improvement measures to ensure that the organization remains compliant with all relevant requirements. 

Anti-Competative Behavior

Main outcomes of completed legal actions, including any decisions or judgements:

In 2019 The European Commission started an investigation relating to suspicions of anti-competitive cooperation in the salmon market. The Commission has announced that is sends to Lerøy and several other large salmon exporters a "Statement of Objections" (SO) setting out its preliminary finding that these companies, in some instances, may have exchanged commercially sensitive information in relation to spot market sale of whole Norwegian farmed salmon to the EU in the period 2011 to 2019.

Lerøy strongly rejects the Commission's allegations. We are now reviewing the SO carefully and will defend our position strongly.

The SO is not a final decision. The SO rather sets out the Commission's preliminary conclusions, and we and the other involved companies have a right to respond to the allegations.

Lerøy’s Business Code of Conduct 

The Group has developed a Business Code of Conduct which outlines the Group’s fundamental standards and principles for business conduct and ethics, human and labour rights, environment, anti-bribery and anti-corruption, whistleblowing and data privacy protection.

The commitments in the Code of Conduct stipulate applying the precautionary principle.

We require both our employees, workers and our business partners to respect, support and comply with the Business Code of Conduct as applicable.

All Lerøy employees and workers (6013 persons, 2023), as well as governance body members (7 persons, 2023), in all operating regions across the globe, shall be able to apply the principles laid out in the Business Code of Conduct and have received Business Code of Conduct and Ethics training (incl. relevant policies and procedures) to raise awareness of various compliance related issues and challanges. The information provided in the training consists of following topics: Group’s fundamental standards and principles for business conduct and ethics, human and labour rights, environment, anti-bribery and anti-corruption, whistleblowing and data privacy protection.

All new employees and workers have to familiarize themselves with the Business Code of Conduct and the Group’s set of values. Existing employees as well as others who are required to respect and comply with the Business Code of Conduct can suggest changes and updates in the Code. All employees and workers are invited to revisit and review The Group’s Business Code of Conduct annually.  

The Code of Conduct is reviewed by the Board annually. It is a permanent agenda item of the first Board meeting of each year.

All Lerøy's business partners have to read and confirm that they will comply with the Company's Business Code of Conduct

The Group’s Compliance Officer is responsible for coordinating and ensuring that The Code is implemented in the organization.The Business Code of Conduct is reviewed annually in order to evaluate its relevance and appropriateness with regards to organizational context changes, social developments, particular cases as well as feedback form relevant stakeholders.

If appropriate and necessary, the Business Code of Conduct is amended, updated or explained in greater detail in case there is a necessity for more clarity regarding how an issue should be handled or resolved.  

Lerøy's Code of Conduct is available on the company's website.

Supplier Code of Conduct 

The Business  Code of Conduct  is complemented by the Group’s set of values which define our behaviours at work. The Group has developed a new Lerøy Supplier Code of Conduct and a Lerøy Supplier Declaration Form that can be found on the Group`s website, see link below. 

In order to verify whether and to what extent the Leroy’s Business Code of Conduct is applied by the Group’s suppliers, they are requested to fill out a questionnaire which requires the suppliers to explain in detail how the Business Code of Conduct is applied and complied with.

The questionnaire addresses such issues as governance, certifications, digital infrastructure and cybersecurity, supply chain, sustainability practices, human and labour rights and other subject specific requirements.   

All our suppliers are informed of and have to commit to our Business Code of Conduct, and they are expected to conduct their business in an ethical and manner as well as act with integrity complying with international and local laws and standards.   

Supplier agreements shall contain requirements stating  the principles in the Business Code of Conduct  shall be followed. Particular care must be taken when engaging intermediaries and associated payments.  


Corruption refers to abuse of power for personal gain. The negative effects of corruption are wide-ranging. Corruption affects individuals, organizations, and society as whole. Corruption increases inequality, decreases accountability and political responsiveness. Corruption and bribery are harmful for business. 

Corruption has significant negative impacts on human rights such as undermining the independence and integrity of the judiciary, it can negatively impact freedom of expression, freedom of association, right to education, right to health, right to basic services and right to workIt is therefore important to contribute to fighting corruption.

Working actively with fighting corruption can help upholding the rule of law, promoting economic growth, protecting human rights, ensuring fair competition and building trust in institutions.

The Group has zero tolerance for corruption and money laundering. Lerøy has developed Anti-Corruption policy and procedures which expresses the company’s core values of integrity and responsibility as well as aim to effectively counter corruption and money laundering. Taking appropriate measures targeting the two has been defined as one of the priorities of the Group.

Implementing anti-corruption measures is an integral part of our corporate responsibility. It helps to protect our reputation and the interests of our stakeholders.

Lerøy has completed risk assessment for risks related to corruption for all (100%) its operations.

The company has defined the following (significant) risks through the assessment:

  • The business and its profile (global sales in countries with high corruption risk);
  • Customers/ distribution channels (large, global customer base with complex owner structure);
  • Suppliers (large, global customer base with complex supply chain structures).

Risk assessment is completed annually or more frequently if necessary.

Lerøy reports compliance-related matters quarterly and, to the best of our knowledge, the company has not been involved with any negative impacts through our activities or as a result of our business relationships.  

I 2023 there were zero confirmed incidents of corruption and no employees were dismissed or disciplined for corruption.

In 2023 there were no confirmed incidents where business partners were terminated or not reviewed due to violations related to corruption. No public legal cases regarding corruption were brought against the organization or the employees/ workers during the reporting period.  

The Group does not support individual political parties or individual politicians but does engage in public debate when in the interests of the Group. 


Lerøy is committed to cooperate in the remediation of negative impacts. One of the mechanisms to ensure this is whistleblowing. 


Internal whistleblowing channel: 

The Group has established an (anonymous) whistleblowing channel to ensure that there is a low-threshold reporting arena for anonymous reporting, making sure that those reluctant to speak up also have an opportunity to express their concerns.

The Group guarantees that the reporting person can remain anonymous, and that all data is processed and stored in an encrypted way and that the person who has submitted the report (the employee or worker) is protected against reprisals. 

The reported whistleblowing cases are initially handled by an independent third party – consulting firm Ernst & Young. All employees reporting concerns shall receive feedback regarding their report no later than 14 days after submitting the whistleblower report. 

Lerøy has established a Whistleblowing Committee which consists of representatives from different departments of the company. The Committee coordinates case handling as well as ensures that necessary measures regarding cases are implemented. 

All cases are registered, investigated and handled according to the Group’s Whistleblowing policy and internal routines. The investigation shall include all parties involved. 

How different cases are handled and followed up will depend on the type of case, scope and degree of its seriousness. Various matters will be followed up with resources such as the local management, the COO for the particular segment the CEO or in special cases - the Board. Notification matters are reported to Group management team and the Board. 

 Internal whistleblowing cases in 2023: 9

Total number of internal whistleblowing cases 


Workplace harassment cases 


Sexual harassment cases 


Cases related to breach of Code of Conduct/ Policies 



8 cases are completed. 

1 case is still being investigated. 

All of the cases (9) have been communicated to the Board. 


The Group is working continuously to improve the current situation regarding various whistleblowing cases by conducting manager training (as a part of Lerøy Leadership Program), further developing the Leadership handbook as well as professional gatherings. The HR department is also providing guidance and support to help identify and handle cases.  

All employees and workers receive regular information regarding the Business Code of Conduct, values as well as regular training on our policies and routines. 

Grievance Mechanisms

External whistleblowing Channel

The Group has established a digital channel for whistleblowing, for all our stakeholders or other external persons who wish to contact the Group, or report a matter of concern.  

They can contact the Group through the Group's web pages, via the link below, which directs them to an external whistleblowing channel. 

External Whistleblowing cases are initially processed by an independent third party and further follow-up is coordinated by the Group's local whistleblowing committee. 

It is also possible to contact the Group via its website using the same address to report other matters, complaints or ask questions. 

Both external whistleblowing channel and the contact form are available to all interested parties. If they wish to give their feedback regarding available grievance mechanisms, the same contact form on the company’s website can be used. 

Effectiveness of both external and internal grievance mechanisms is measured on regular basis. All reported cases are handled according to relevant procedures. Necessary changes and updates are made continuously. 

External whistleblowing cases in 2023: 22

External whistleblowing cases 


Cases related to Norwegian Transparency act


Number of neighbour complaints