Code of conduct Akelius Residential Group Code of Conduct Approved by Business Committee Region of Implementation

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1 Code of conduct Akelius Residential Group Code of Conduct Approved by Business Committee Region of Implementation Global

2 1 Introduction and ambition The Code of Conduct is a decisive basis for our business activities. It determines our company s conduct in sustainable business and promotes a desirable corporate culture. By acting at all times with ethics and integrity, we achieve and preserve the good reputation of our company. This benefits all aspects of our business activities. We want to ensure that Akelius is an esteemed employer and trustworthy partner to our tenants and suppliers. Akelius supports the United Nations Global Compact principles, International Labor Organization and OECD guidelines. Local guidelines and policies can, where relevant, be worked out based on these common guidelines, to reflect local aspects. 2 Code of Conduct Business at Akelius will be conducted in accordance with the following principles. Those principles contained in the Code and its Annex applies to all our employees, including temporary staff and trainees but also to contractual partners. We respect the rights of the individual, act in accordance with fair business, marketing and advertising practices and are committed to continuously developing the safety and quality of our products. We respect the rule of law, conduct our business with integrity and honesty and are accountable for our actions. If the local law is stricter than the code, local laws must always prevail. We continually work to reduce our impact on the environment and health. We do not engage in illegal industry co-operation. We do not accept the offering, request or acceptance of bribes. We encourage our employees to avoid situations in which loyalty to the company may come into conflict with other, personal interests. 1

3 We are committed to open and transparent communications within the bounds of commercial confidentiality. We demonstrate good faith and mutual respect in dealings with employees and their representatives in the workplace. We do observe local custom. The Code of Conduct applies to all Akelius operations and all Akelius employees worldwide regardless of function, grade or standing. Akelius expects equivalent standards of conduct from all persons acting on its behalf. Akelius employees commit to protect the companies, tangible as well as intellectual, and trade secrets and to stay loyal to the company in all our contact with external and internal partners. 3 Principles of our Code of Conduct 3.1 Fair business We shall follow and respect the rule of laws in the countries we are operating and do business in. We conduct our business with integrity and honesty and are accountable for our actions. The code sets a minimum of appropriate behavior even if it is a higher standard than local law dictates. If the local law is stricter than the code, local laws must always prevail. We do not engage in illegal industrial co-operation or cartels. Instead we act in accordance with fair business competitions principles, marketing and advertising practices and are committed to continuously developing safety and quality of our products that will stand a fair assessment from our consumers. We do not accept the offering, request or acceptance of bribes, extortion or money laundering. 2

4 We encourage our employees to avoid situations where loyalty to the company may come into conflict with other personal interests. Corporate integrity and lawful conduct of business is a prerequisite for trustful cooperation with our partners. We reserve the right to terminate any cooperation when business partners undermine our standards. 3.2 Fair employment practices Akelius supports and respects protection of international proclaimed human rights and we make sure Akelius is not complicit in any human right abuses. We respect the rights of the individual and we demonstrate good faith and mutual respect in dealings with employees and their representatives in the workplace. 3.3 Freedom of Association We respect workers rights to form and join organizations of their choice and to bargain collectively. We expect our suppliers to respect the right to free association and the right to organize and bargain collectively without unlawful interference. 3.4 Forced Labor We will not utilize prison or forced labor in contract relationships in the manufacture and finishing of our products, nor purchase materials from business partners utilizing prison or forced labor. 3.5 Child labor We do not use child labor in our own manufacturing or operation and shall not engage in or support business where child labor is 3

5 used. Ensuring that all children go to school and that their education is of good quality is essential to preventing child labor. Child thus, refers to any person below 15 years of age, unless minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. 3.6 Minimum compensation & remuneration We shall apply and respect standard local working hours regulated in local law in the countries we are operating in. We shall ensure that wages paid for a standard working week shall always meet at least legal/industry minimum standard. We do not engage in businesses or with suppliers that do not apply the same principles as we do regarding work hours and minimum pay. 3.7 Discrimination and harassment We do not tolerate discrimination or harassment of any kind. All employees in our Group should have the right to work in an environment free from harassments, threats and discrimination. All leaders and managers are responsible for ensuring that these conditions exist. We do not engage in businesses or with suppliers, sub-contractors or any other business relationship where discrimination and harassments are tolerated. Akelius trust and respect that a true ethical business environment is a foundation to build good relationships between our employees and the company. Sexual harassment, abuse or unwelcome sexual invites are strictly prohibited and will be followed with disciplinary actions and reprimands. 4

6 3.8 Health and Safety and work environment We will only utilize business partners who provide their workers and employees with a safe and healthy work environment. This also applies to business partners who provide residential facilities for their employees. We are convinced that it is essential to provide a safe, healthy and inspiring work environment for all Akelius employees. All our employees are responsible for maintaining this objective. We do not tolerate use of alcohol, narcotics or misuse of medicines during work. It is strictly forbidden to use, sell, buy, produce, and possess alcohol or narcotics within and around Akelius premises. This includes also driving under the influence of alcohol or narcotics during or in connection to any work related occasion. We do not tolerate any violence or threat of violence against employees, visitors, customers, suppliers or any others at the workplace. Disciplinary action, which can lead to dismissal and termination of employment, will be taken to those who violate this rule. We are convinced that companies who support a healthy lifestyle and strive to motivate and empower their staff have better performing employees. Therefore we encourage our employees to live a balanced and an active life. 3.9 Environment Akelius strives to support a precautionary approach to environmental challenges. We want to conduct our business on a long term basis which means that we support the long term preservation of a sustainable society and thus integrate environmental considerations into our business planning and decision making. Our business relationships 5

7 with third party producers and other material suppliers shall comply with local environmental legislation; actively strive to impose as little impact on the environment as possible and work with annual target setting to reduce environmental impact. We believe that the commitment and passion for doing business in a sustainable way should be supported by follow-up on the progress of performance in our environmental focus areas which are energy, water, product lifecycles, responsible sourcing and logistics. We believe it is important for continuous improvements to set environmental targets and by monitoring activities in the environmental focus areas. 4 Area of application This code applies to all of Akelius board members, management, employees, suppliers, business partners, sub-contractors and clients. Each of us has a responsibility to act honestly and ethically. Our Code of Conduct provides the framework to put Akelius values into action. We all have a responsibility to act with integrity, comply with applicable laws and regulations both in letter and spirit, and honor the Akelius Code of Conduct. 5 Whistle Blowing Channels Procedure All management executives and other supervisors are responsible for ensuring that their employees are familiar with, and adhere to, the Code of Conduct. Akelius will protect the anonymity of any employee who reports presumed misconduct. It is a corporate principle that any 6

8 employee who, in good faith, reports a possible breach has no cause to fear any adverse effects on their employment. By reporting violations, you are helping protect our business, colleagues and others. The employee reporting may remain anonymous if he or she wishes. False allegations or misuse of the whistle blowing channel procedure is in itself a violation against the Code of Conduct. If reporting to the nearest supervisor or manager is not applicable for whatever reason, you should first contact your local Staff Development for help. If you do not want to discuss an issue or concern with your local Staff Development you should then contact any of the following for a confidential talk: Pål Ahlsen Fredrik Lindgren Leif Norburg, Board Roger Akelius, Board Igor Rogulj, Board Staffan Jufors, Board pal.ahlsen@akelius.se fredrik.lindgren@akelius.se leif.norburg@gmail.com roger@akelius.se igor@rogulj.de staffan.jufors@gmail.com Contact in person, over the phone or through is appropriate. The person you talk to must not disclose your name to anybody. Employees, suppliers or any other external business partner can report a suspected violation against this Code of Conduct anonymously to whistleblower@akelius.com. 6 Appendixes Appendix A UN Global Compact 10 Principles 7

9 Appendix A UN Global Compact 10 Principles Human Rights 1. Businesses should support and respect the protection of internationally proclaimed human rights; and 2. Make sure they are not complicit in the human right abuses Labor 3. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining 4. The elimination of all forms of forced and compulsory labor; 5. The effective abolition of child labor; and 6. The elimination of discrimination in respect of employment and occupation Environment 7. Businesses should support a precautionary approach to environmental challenges; 8. Undertake initiatives to promote greater environmental responsibility; and 9. Encourage the development and diffusion of environmentally friendly technologies Anti-Corruption 10. Businesses should work against corruption in all its form, including extortion and bribery 8

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