Stray Partners Anti-Bribery and Corruption Statement

Last Updated: 25.07.2025

At Stray Partners AS, we are committed to the highest standards of ethical conduct, transparency, and accountability in all aspects of our business. We maintain a zero-tolerance policy toward bribery, corruption, and any form of unethical influence.

Our Position

Stray Partners prohibits:

  • Offering, giving, requesting, or accepting bribes or facilitation payments in any form

  • Attempting to improperly influence business decisions, whether public or private

  • Using third parties, agents, or consultants to engage in bribery or corruption on our behalf

  • Concealing improper payments or falsifying accounting records for unethical purposes

We uphold this standard in every jurisdiction in which we operate, regardless of local practices or customs.

Our Principles

Stray Partners is:

  • Independent, objective, and neutral; our work is guided solely by data, facts, and ethical principles. We serve what is correct and right, without secondary interests or influence.

  • Transparent and accountable; we design systems and agreements that enable traceability, auditability, and ethical clarity.

  • Proactive in prevention; we train employees, screen partners, and implement internal controls to ensure compliance with anti-corruption laws and international good practice, including the Norwegian Penal Code, UK Bribery Act, and U.S. Foreign Corrupt Practices Act (FCPA).

  • Diligent in relationships - through Know Your Customer (KYC) and Know Your Supplier (KNS) practices, we aim to work only with parties who demonstrate integrity, transparency, and compliance. We verify beneficial ownership, governance structures, and ethical histories before formal engagement.

  • Diligent in relationships - through our internal Know Your Customer (KYC) and Know Your Supplier (KNS) survey and verification process, we assess ethical standing, beneficial ownership, and reputational integrity before entering into any formal collaboration. This ensures we only engage with individuals and organizations that align with our values of transparency, compliance, and ethical business conduct.

Our Expectations

We expect the same commitment from:

  • All employees, subcontractors, consultants, and board members

  • All suppliers, collaborators, and third parties acting on our behalf

Any breach of this policy may result in disciplinary action, termination of contracts, and reporting to relevant authorities.

Raising Concerns

If anyone becomes aware of suspicious behavior, unethical offers, or improper practices relating to Stray Partners, we encourage immediate reporting through internal channels or designated external authorities. Reports can be made confidentially and without fear of retaliation.

Signed on behalf of Stray Partners: Adrian Stray CEO, Stray Partners AS 20.07.2025