INTRODUCTION

This “Code of Conduct” applies to Consat AB and its subsidiaries and applies to all employees and co-workers.

CODE OF CONDUCT PRINCIPLES

As a company, we are responsible and committed, which we also expect from those we work with. Therefore, we place the following demands on ourselves and our business partners:

-to conduct their business in accordance with applicable laws and regulations as well as the principles set forth in this document; and

– that we ensure that our employees and subcontractors are made aware of and comply with applicable laws and regulations set out in this document. To conduct our business partners must in turn choose suppliers with the same responsibility as well as the principles are followed.

This document covers how we work and the demands and expectations we have on ourselves and our business partners when it comes to working conditions, human rights, caring for the environment and doing business with integrity. There may be times when the text of this document differs from local laws or guidelines in a particular country. If this is the case and local legislation or guidelines have higher standards than those set out in this document, local legislation and guidelines should always apply. However, if this document prescribes a higher standard, this should apply, unless it results in illegal activity.

This document contains requirements based on recognized principles that we stand behind, such as:

– Internationally accepted principles including, but not limited to, human rights, working conditions and rights, children’s rights etc. fight against anti-bribery and anti-corruption.

– working in a way that is positive for our environment.

 

WORKING CONDITIONS AND HUMAN RIGHTS

Our customers expect us and our business partners to ensure that our employees have working conditions that meet the laws and other requirements that exist where we operate. For instance, that we have the right to join a trade union, that we follow the working time rules that apply in the country and for the industry, that we follow rules for human rights and children’s rights. (supports the demands of the ILO, the organization’s goal is to promote social justice and humane working conditions as a precondition for peace between and within nations against child labor and human trafficking).

Child labor We and our business partners need to work to prevent all forms of child labor. Under no circumstances may employment be offered to a person under 15 years of age (or 14 years of age in the national law that allows it) or younger than the legal minimum age of the countries, if it is higher than 15 years.

 

FORCED LABOR

There must be no forced labor of any kind related to our business or our business partners, products, and services. Therefore, business partners may not use forced labor, regardless of form. This prohibition covers indebtedness, human trafficking, and other forms of modern slavery.

 

TERMS OF EMPLOYMENT

We and our business partners must be able to guarantee that the working conditions of their employees meet all applicable legal requirements. In addition, every employee should have the right to receive written information in a language that they can easily understand regarding their terms of employment.

 

SALARIES AND BENEFITS

We and our business partners need to pay salaries and have benefits that meet or exceed the legal minimum requirements, collective agreements, or appropriate prevailing industry standards.

Wage deductions are only accepted in accordance with applicable laws or collective agreements. Deductions from salaries as a disciplinary measure are not permitted. Information about salaries and benefits must be available to all employees, and in accordance with applicable laws. We provide our employees with a total compensation that is sufficient to cover basic needs and enable a decent standard of living. Our business partners are also advised to systematically strive to ensure fair wages.

 

WORKING HOURS

We and our business partners need to comply with applicable legislation on working hours and rest rules.

 

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

We and our business partners shall respect the rights of our employees’ right to lawfully form, join or exclude themselves employer-employee relationship-related associations and to bargain collectively, where permitted by local law. We must also ensure that employees are given the opportunity to discuss their working conditions with management without fear of retaliation.

Health and Safety Safety shall always be one of the most important factors in any decision. We and our business partners must always provide and maintain a safe and healthy work environment that meets, applicable standards and legal requirements.

 

NON-DISCRIMINATION AND EQUAL OPPORTUNITIES

We and our business partners may not engage in any form of discrimination based on gender, ethnicity, religion, age, disability, sexual orientation, nationality, political opinion, trade union, social background or other characteristics protected by applicable law. All employees must be treated with respect, dignity, and general courtesy.

 

CARING FOR THE ENVIRONMENT

We and our business partners are responsible for complying with the laws and regulations that apply to our environment. In addition, we must protect the environment and limit our total environmental impact throughout the value chain by working proactively to reduce the environmental footprint of our operations, products, and services, such as reducing our emissions and making choices that save our resource, for example by reusing and working for a circular economy.

We have an environmental management system that monitors and measures so that we have control over and work to continuously improve our environmental performance while we manage any risks. We request the same from our business partners. This can apply to reduced emissions, reduced use of natural resources or reduction of energy consumption or conversion to renewable energy, etc.

Our chemicals must always be handled in a safe way and if there are more environmentally friendly alternatives, we shall use them.

We have a continuous dialogue with our customers and business partners to find good solutions.

We communicate our environmental performance to those who are in need of it, or for some other reason have the disclosure rights.

 

THE PRECAUTIONARY PRINCIPLE

We and our business partners always apply the precautionary principle, which means that we are always expected to take precautionary measures when there is reason to believe that a potential measure may affect the health or safety of a person, society or the environment.

RESPONSIBILITY WHEN HANDLING MINERALS AND METALS

We and our business partners are only expected to use minerals and metals that have been extracted and traded in such a way that it does not contribute to human rights violations, unethical business practices (e.g. corruption), environmental damage or conflict financing.

We are expected to ensure that our suppliers exercise due diligence in their operations to ensure that metals and minerals are procured responsibly. We will do due diligence and be able to show it on request to customers and other stakeholders. If we are to handle Conflict minerals 3TG (tin, tantalum, “tungsten” and gold) and Cobalt, complete transparency and traceability is required in the entire supply chain.

 

BUSINESS INTEGRITY

Since the business relationship between us and our business partners must be based on trust, openness, honesty and accountability, business partners are expected to conduct their business ethically and with the utmost integrity.

 

ANTI-CORRUPTION

We and our business partners and third parties must conduct our business and transactions in accordance with applicable laws and regulations related to bribery and corruption. In line with our zero tolerance for bribery and corruption, we and our business partners and third parties should never engage in, or tolerate any act that may be construed as bribery or corruption.

Consequently, we shall ensure that no one are offered or receive any form of inappropriate benefit (gift, service, or hospitality) with the intention of improperly influencing a business decision, whether it be government officials or private individuals. We encourage special attention to be paid to the following situations, which are generally considered to be riskier regarding bribery and corruption:

– interaction with public officials: certain stricter rules apply when dealing with public officials; for example, simpler payments are always prohibited.

– use of intermediaries, in particular agents: many cases of bribery involve third party intermediaries (sales consultants, agents, brokers, etc.) who may use part of their compensation to provide bribes, intermediaries must be selected on the basis of appropriate selection criteria and due diligence.

– donations to charities, associations or political parties and sponsorship activities: these activities can be avenues for bribery and corruption.

If an employee of a company with whom we do business requests incorrect payment or incentives in violation of this code, we will notify the company, even if the request is denied. We and our business partners must ensure that all reports, registers and invoices are correct and complete and that they do not contain any false or misleading information.

 

CONFLICT OF INTEREST

All situations that may involve a conflict of interest or the emergence of a conflict of interest between us and our business partners must be avoided: professional assessment, performance or decision-making for an employee with us or the business partner must remain independent of considerations that do not involve the business and cannot be influenced by private interests.

Consequently, the interests of us and / or the business partner and the personal interests of our respective employees must be kept separate. Our business partners are expected to let us know if you see something that seems unethical or suspects crime.

 

FAIR COMPETITION AND BUSINESS PRACTICES

We strive to always act as a fair and responsible player in the market and expect the same from our business partners. We and our business partners are therefore obliged to comply with applicable competition laws and regulations.

If a business partner has a partnership with a competitor to us, they may not share any sensitive information with the competitor and vice versa, even via third parties.

Business partners are expected to compete fairly and ethically for all business opportunities.

 

TRADE SANCTIONS AND EXPORT CONTROL

We and our business partners must comply with all trade sanctions applicable to us as well as relevant export control laws and regulations. Trade sanctions restrict trade and financial transactions with certain countries, companies, organizations, and individuals, while export controls restrict the export and re-export of certain “controlled” goods, software and technology without the necessary licenses or other permission from the relevant authority. It is our responsibility to check that we and our business partners as well as third party follow the trade sanctions and the export control. Violation of these rules can have significant penalties and negative consequences for us.

 

PROTECTION OF CONFIDENTIAL INFORMATION AND INTELLECTUAL PROPERTY

The confidential information and / or intellectual property rights that we and our business partners share during a business relationship are always covered by confidentiality until there is a written decision that it is official or may be shared with a particular party. Only those people who need the information to do their job get the information, and only to the extent necessary. Should any unauthorized person become aware of confidential information and / or intellectual property rights, the parties concerned shall be informed immediately and start an investigation. Upon completion of work, it must be clear what information may be shared with whom.

 

DATA PROTECTION

We and our business partners are obligated to comply with applicable data protection laws and regulations when we process personal data in connection with our operations.

“Personal data” is defined as all information relating to an identified or identifiable natural person; an identifiable natural person is one that can be identified, directly or indirectly, by reference to an identity such as: a name, an identity number, local data, an online identity or to one or more factors specific to the physical, physiological, genetic, mental, cultural or social identity of that natural person.

In addition, business partners performing a processing activity on behalf of us are required to comply with the agreed upon specific contractual provisions. Business partners have a responsibility to protect personal data from improper disclosure, theft or misuse at all times and must immediately report to concerned parties any incident involving data.

 

AUDIT RIGHT

We and our business partners always can revise or be audited by second or third parties. Partly to see how compliance with our collaborations is managed, partly to ensure, for example, the quality of an assignment. This can be done at short notice but should be done as far as possible by agreement between the parties. On these occasions, everyone involved must work together for the best results and provide relevant information and demonstrate what is required.

 

COMPLAINTS AND COOPERATION

We think it is important to have an open and honest relationship with our business partners and therefore want us to have a continuous dialogue. If any party discovers irregularities, this must be immediately referred to appropriate authority. If it should be of such a nature that legal action may be required, it is of the utmost importance to act urgently. If you want to be anonymous when providing information, it is allowed, but it is always easier if you can return with follow-up questions to an identified person if an investigation is required. The identity of the person shall be kept confidential as far as possible. All concerned parties are expected to assist with information at the same time as information may not be disclosed to non-interested parties.

 

CONSEQUENCES OF VIOLATIONS

We and our business partners agree that it is a breach not to follow agreements, laws and other requirements that affect us. This applies at all levels. Violations can have consequences, such as taking measures to correct the error and ensuring that it does not happen again, damages, termination of an ongoing business or other relevant action. This must be done in writing so that no ambiguities arise