Code of Conduct - Lagercrantz Group

Lagercrantz Group is a technology group that within well-defined niches and in partnership with customers and suppliers offers value-creating technology solutions. The Group has approximately 2,500 employees in some seventy independent subsidiaries that are run under their own names. Each subsidiary manages its business with considerable freedom and has its own responsibility. The most important business decisions are thus taken where knowledge is greatest ― close to customers and the market.

The operations are based on close and long-term relationships with customers, suppliers and other business partners, and we aim to be a trustworthy, long-term and reliable partner. Besides commercial goals and principles, the business operations should also be conducted with high standards of integrity and ethics. We thus attach great importance to acting in a professional, honest and ethically correct manner.

We support the concepts contained in the UN’s Global Compact (www.globalcompact.org), the ILO’s core conventions (www.ilo.org), as well as the OECD’s Guidelines for Multinational Enterprises (www.oecd.org), and these principles are the inspiration for our Code of Conduct. Our long-term goal is that all partners and suppliers of our companies should comply with the Code of Conduct. However, we understand that some changes require time, but we expect continuous efforts towards improvements. As a minimum, we comply with all prevailing laws and regulations and when necessary we will also introduce standards that follow this Code where existing laws and regulations are not in line with its objectives. We expect as a minimum requirement that customers and suppliers have knowledge of and comply with current legislation.

The Managing Director of each individual company in the Group is responsible for ensuring that the day-to-day work is conducted in accordance with our Code of Conduct.

Each company within the Group strives to have a positive influence in the communities where the Group operates. Business decisions that may be considered to have an impact on the wider community shall as far as possible always be preceded by, or promptly followed by, discussions with community representatives for the purpose of identifying possible need for collective measures.

We maintain neutrality in relation to political parties and candidates. Neither the name Lagercrantz Group, the company name of each group company, nor any resources under the control of group companies shall be used to promote the interests of political parties or candidates.

Business Ethics and Anti-Corruption

We do not accept corruption, bribes or unfair methods of competition. Lagercrantz Group complies with the Swedish Business Code issued by the Swedish Institute Against Bribes (IMM), which aims to guide companies in questions relating to how gifts, remuneration and other benefits may be used in the business sector to promote the company’s operations. All sales and marketing of our products and services shall also take place in accordance with the relevant laws and regulations in each country.

We shall not offer or make improper payments or pay other remuneration to any person or organisation for the purpose of establishing or retaining business relationships with our Group. We shall not, directly or indirectly, ask for or accept any form of improper payment or other remuneration, which is provided for the purpose of establishing or retaining business relationships with our Group.

Workplace, Equality and Human Rights

We strive to be a respected employer. Companies in the Group should provide a good working environment and strive to be an attractive employer when it comes to the employees’ professional development. The relationship with and between employees should be based on mutual respect and also allow reasonable influence in areas that impact the individual’s work situation.

We offer a pleasant workplace and look after our employees’ health and also ensure their well-being and development. Our employees’ health and safety shall be prioritised, and appropriate protection shall be used ― the equipment and buildings used shall be safe, and hazardous substances and waste shall be handled in a secure manner.

We strive to ensure that employees in the Group shall be afforded equal opportunities for career advancement, training, remuneration, work content and working conditions, regardless of gender. In those cases where remuneration gaps exist between men and women, we should actively work to adjust them. We also work to achieve a more uniform gender breakdown in recruitment.

We offer equal employment opportunities regardless of race, religion, gender, disability, family circumstances or sexual orientation. We work to counter all forms of discrimination at the workplace or in dealing with employees when it comes to setting of salaries and career advancement.

Employees should be treated with respect and dignity. No employee should under any circumstances be subject to physical punishment or other forms of physical, sexual, psychological punitive measure, harassment or coercion. We do not accept any form of forced labour, involuntary or unpaid work. The UN’s Convention on the Rights of the Child, the ILO’s Convention on the Minimum Age for Employment, and the Convention on Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour, are guidelines for all business activities that are conducted in our name. Employees should have the freedom to exercise their legal right to be a member of, organise or work for organisations that represent their interests as employees.

Environment

Recycling considerations and economising on natural resources are an important basis of our business operations. The environmental perspective should be part of every important decision, with the aim of creating long-term value for the Group’s customers, employees, shareholders and for the wider community. The environmental work shall also be conducted within the framework of our business concept and should be well-integrated in our operational work. By extension, this means that the entire life cycle of the products and services we supply should be taken into consideration.

Customers and suppliers are expected to be familiar with and meet requirements under national legislation, regulations and industry standards. Customers and suppliers as a minimum requirement should ensure safe handling of hazardous substances and waste.

Confidentiality and Conflicts of Interest

All information concerning our business with customers and suppliers is confidential, as well as all information about our employees and our internal affairs. Information about services and products that customers/suppliers buy or sell is also confidential unless otherwise agreed.

Involvement in external activities shall be reported to and approved by the immediate manager. Examples of such activities are if employees accept external employment, are members of boards of directors of other companies or conduct other business activities.

Financial Reporting

All financial reporting and accounting shall be maintained and reported in accordance with local regulations (GAAP) and IFRS. All assets, liabilities, revenue, costs and operations shall be described in a correct manner.

Social Media and Communication

At our workplaces, most of us have access to the Internet and social media. These are tools for our work and intended for business communication. Employees who communicate in their professional capacity always represent their company and Lagercrantz. Therefore, all communication must be aligned with our values. Employees must also distinguish clearly between private and professional presence online.

Trade Compliance

We follow at all times applicable international trade laws of the countries in which we conduct business. Consultation and authorisation shall always be obtained from the Group Management prior to exporting or entering into agreements with business partners in countries listed on the EU or US sanctions and export control lists.

The Managing Director of each group company is responsible for ensuring compliance with these trade policies and must therefore obtain relevant knowledge of resellers, customers, suppliers, other business partners, as well as individual contracts, in order to verify which countries products will end up in and who the end-customers are.

Compliance, Reporting and Whistleblowing

Managers and leaders in the group companies of Lagercrantz Group should be familiar with and be responsible in their area for ensuring compliance with this Code of Conduct and with relevant national laws and regulations.

Each employee is responsible for acting in accordance with the values and commercial principles of the Code of Conduct and for reporting any violations or suspected fraud. Reports may be submitted confidentially or anonymously to whistleblower@lagercrantz.com or via post to Lagercrantz Group AB, Attn. Info, Box 3508, 103 69 Stockholm.

No penalty or negative consequence shall apply to persons who submit a report in good faith.