Ntg Nordic Transport Group A/s · OMXCOP:NTG
Ntg Nordic Transport Group A/s — PowerPoint-in person
15 slides from Ntg Nordic Transport Group A/s's investor presentation, September 2025
Slide 1: Group Legal – In person compliance training: Anti-Corruption
Group Legal – In person compliance training Anti-Corruption Sept. 2025 – Joe Simon
Slide 2: Case studies – giving gifts and supplier credit note
Case studies – 1) giving gifts and 2) supplier credit note You consider giving an important Your department receives a credit note from a customer a gift valued at EUR 300 as a supplier which was hired by the procurement mark of your appreciation at the department of your company to provide road con
Slide 3: Case studies – gifts to agent's family and hearing about this
Case studies – 3) gifts to agent‘s family and 4) hearing about this An agent representing a large state-owned A senior manager at NTG HQ hears rumors about potential customer in Asia requests expensive the agent case above and some similar cases in gifts and meals for her family – “it is common coun
Slide 4: What are the consequences in case NTG is involved in improper business practices?
What are the consequences in case NTG is involved in improper business practices? • Civil and criminal Liability for NTG • Civil and criminal liability for NTG employees involved in improper business practices • Fines for NTG • Fines for NTG employees involved in improper business practices • Invest
Slide 5: What is corruption?
What is corruption? In short: corruption is paying someone to do what they should not do, or not do what they should do 1 In detail: corruption in 2 Anything of value includes business means ▪ Cash ▪ …the offer, promise or receipt of ▪ Gifts anything of value… ▪ Entertainment ▪ Travel ▪ ...to or fro
Slide 6: Scope of Anti-Corruption legislation
Scope of Anti-Corruption legislation Rules apply to: 1 Legal entities – NTG A/S 2 Directors, managers, employees 3 Third parties acting on NTG‘s behalf and global subsidiaries - anyone facilitating bribery HQ must know what subsidiaries do Window dressing – not protection and take action – no willfu
Slide 7: Anti-Corruption legislation applicable to NTG
Anti-Corruption legislation applicable to NTG Seal of the Department of Justice United States – The Foreign United Kingdom – International Conventions, Corrupt Practices Act - FCPA The UK Bribery Act local laws & customers • Anti-Bribery provisions • Anti-Bribery provisions • OECD Convention on Comb
Slide 8: Be careful when interacting with government officials
Be careful when interacting with government officials A government official is any member, employee or person acting on behalf of: 1 Government department 2 State-owned or 3 Members of political 4 International or agency, e.g. Port agency controlled companies, parties or royal families organizations
Slide 9: When could NTG be impacted? Risks and mitigating measures
When could NTG be impacted? Risks Mitigating measures • NTG can be responsible for third parties interacting on our • Due diligence on the third party behalf with governments, e.g., • Integrity due diligence questionnaire to be filled out by the third party • brokers, agents, consultants, advisors,
Slide 10: Don't forget company to company bribery – cashbacks, kickbacks, etc.
Dont‘ forget company to company bribery – cashbacks, kickbacks, etc. Example: Supplier sales manager and Customer Example: procurement manager agree that Local finance team receives undetailed EUR 2K • Supplier charges Customer above-market invoice from unknown company, Mary Jones Ltd. prices for se
Slide 11: But that's just how people always do business here!
But that‘s just how people always do business here! Worn-out arguments often used to try to justify corruption, e.g., • It’s part of the local business culture – and always has been! • Different countries have different business customs – we need to follow them Does the argument work? NO! ▪ Anti-cor
Slide 12: NTG's policy on Anti-Corruption
NTG‘s policy on Anti-Corruption • NTG’s Policy on Anti-Corruption sets out required actions and procedures to ensure compliance with anti-corruption laws – Find the Policy on NTG’s Intranet or here • NTG enforces the policy - violators risk severe employment consequences, e.g., dismissal • NTG will
Slide 13: Case study – giving gifts and supplier credit note
Case study – giving gifts and supplier credit note You consider giving an important Your department receives a credit note from a customer a gift valued at EUR 300 as a supplier which was hired by the procurement mark of your appreciation at the department of your company to provide road conclusion
Slide 14: Case study – gifts to agent's family and hearing about this
Case study – gifts to agent‘s family and hearing about this An agent representing a large state-owned A senior manager at NTG HQ hears rumors about potential customer in Asia requests expensive the agent case above and some similar cases in gifts and meals for her family – “this common countries in
Slide 15: Thank you!
Thank you! www.ntg.com 15 www.ntg.com |