CODE OF CONDUCT UPPFÖRANDEKOD ETISKE RETNINGSLINJER FOR GOD ATFERD TOIMINTAOHJEET KODEKS POSTĘPOWANIA
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1 CODE OF CONDUCT UPPFÖRANDEKOD ETISKE RETNINGSLINJER FOR GOD ATFERD TOIMINTAOHJEET KODEKS POSTĘPOWANIA 行为准则
2 PARTNERTECH CODE OF CONDUCT PartnerTech Code of Conduct (hereafter The Code) has been adopted to underscore the principles by which PartnerTech conducts its relations with employees, business partners and other stakeholders. Honesty and fairness have always characterized our way of doing business. By applying The Code in our daily work we take responsibility in helping to ensure that our business is conducted in a responsible and sustainable way. The Code plays an essential role in creating a group wide culture of responsibility and commitment to PartnerTech values. For PartnerTech, to be a responsible company means to behave ethically in all aspects of business, to care for the environment, to set good examples in the way we act towards each other as employees and how we treat our business partners. We always respect laws and regulations wherever we do business. To be successful it is a clear requirement that we are, and are perceived as, a reliable partner to our customers wherever they are. We must ensure there are no doubts whatsoever among our shareholders that we are setting, and working towards, the highest standards in respect to business integrity and promoting a sustainable society. All employees must be familiar with and live up to The Code. It is the highest level of a framework which consists also of detailed policies and directives. PartnerTech is committed to creating a working environment where you feel that you can raise any issues, without fear of retaliation. This commitment shall be upheld by all levels of management. PartnerTech has common principles to strengthen the sense of belonging and ensure consistent behavior. That is why we have created our core values. They promote personal commitment and describe the ways that we create customer value. The principles are based on a number of simple statements that serve as reminders for us when we do our jobs: We are partnering for success We respect each other and act in the best interests of PartnerTech. We believe success creates success through partnerships with customers, suppliers and employees. We deliver customer value We are proactive and deliver value to our customers business in every interaction. We provide world class quality and customer service We continuously improve to stay ahead of our competitors and to the level expected by our customers. We strive to eliminate waste in everything we do Each of us is accountable for being effective and improve performance in all that we do. We are one team We respect and rely on each other, by making expectations clear and keeping our commitments. We recognize achievements. Leif Thorwaldsson President and CEO PartnerTech Page 1 of 7
3 Content Introduction... 3 Our business principles... 3 Fairness in all business relations... 3 Accuracy in accounting and reporting... 4 Personal financial interest... 4 Political involvement... 4 Conflict of Interest... 5 Dealing with confidential information... 5 Social media... 5 Respect for the individual... 5 Fair employment conditions... 6 Freedom of association... 6 Prevention of Involuntary or Child labor and human trafficking... 6 The environment... 6 Health & Safety... 6 Reporting of violations... 7 Contacts... 7 Page 2 of 7
4 Introduction All our employees must be aware of and comply with this Code of Conduct. Together with our Group policies, The Code forms the basis for the way we work in PartnerTech. All our employees are expected to always act in the spirit of The Code. All managers are accountable for communicating the content of and for enforcing The Code within their organizations. Failure to comply with The Code can result in disciplinary action. The Code has been adopted by the PartnerTech Group Management and the PartnerTech Board of Directors and can be amended or changed only by the PartnerTech Board of Directors. It is based on the UN Global Compact. The Global Compact asks companies to embrace universal principles and to partner with the United Nations. It has grown to become a critical platform for the UN to engage effectively with enlightened global business. UN Secretary-General Ban Ki-moon PartnerTech requires suppliers, subcontractors, consultants and other business partners to adopt and follow these principles. PartnerTech evaluate and select business partners on the basis of their ability to meet with the requirements of this Code. Our business principles PartnerTech s objective is to strengthen the competitiveness of our customers and their products. PartnerTech follows the laws and regulations in each country where we operate. The Code sets forth the minimum level of approved behavior. In case local law is stricter than The Code, local law shall prevail. Our suppliers must uphold the human rights of workers, and treat them with dignity and respect as understood by the international community. The supplier code of conduct is, in complement to this Code of Conduct, regulated in D (you find it in PIMS). Fairness in all business relations Business decisions are based on the best interests of PartnerTech, without regard to personal relationships or considerations. Employees must not accept gifts, benefits, reimbursements or entertainment that could affect, or even appear to affect, the objectivity and professional judgment of the employee. Likewise, PartnerTech shall not offer rewards or benefits to any business party or stakeholder, which is, or appears to be, in violation of applicable laws. Page 3 of 7
5 PartnerTech competes in a manner that is both ethical and fair, without engaging in any inappropriate activities or unfair trade practices. We will inevitably be confronted with complex situations where we feel we do not get a clear answer from The Code of Conduct or through the Management System. When this is the case, we expect employees to discuss the matter with his/her nearest superior or to seek advice from the contacts at the end of this Code. Accuracy in accounting and reporting PartnerTech is committed to ensuring accuracy in financial reporting and communication. All financial transactions made by PartnerTech must be recorded in accordance with generally accepted accounting practices in each jurisdiction. Accounting records must show the nature of all transactions in a correct and non-misleading manner. All internal financial reporting shall be made in accordance with the PartnerTech Financial Manual. Personal financial interest Employees must never use association with PartnerTech for personal gain and shall avoid engaging in external financial interests that might conflict with the PartnerTech interests. Interests to be avoided include personal or family financial interests in any operation or company that has business relationships with PartnerTech. PartnerTech is listed on the NASDAQ OMX Nordic Exchange, Stockholm and we as employees must comply with all applicable stock market laws and regulations in order to maintain the shareholders trust and PartnerTech s accountability on the financial market. Only authorized spokespersons are permitted to represent PartnerTech externally and to comment on disclosed information. We do not allow misuse of inside information. Inside information is information that is not public and is likely to significantly affect the price of the PartnerTech shares. Typical inside information is financial results and major orders. Political involvement PartnerTech observes strict neutrality with regard to political parties and candidates. Neither the names nor resources of PartnerTech shall be used to promote the interests of political parties or candidates. Page 4 of 7
6 Conflict of Interest We do not offer nor accept improper gifts or hospitality. Employees may not engage themselves, with or without compensation, in activities outside PartnerTech that might conflict or appear to conflict with PartnerTech interests, without approval from the employee s manager and in accordance with the Grand Parent principle. Dealing with confidential information Employees often have access to information about PartnerTech, and sometimes also to information owned by third parties, that is not generally available to the public. Such confidential information must not be passed on to anyone outside PartnerTech, and this includes family members. We must all be aware of the risk of unintentional exposure of information, e.g. by discussing company matters with co-workers while traveling or in public places. Employees are not allowed to trade in PartnerTech shares or any other kind of property on the basis of so called insider information, i.e. information that is accessed through work at PartnerTech and which is not made public. Social media We ask our employees not to act as PartnerTech spokespersons, making statements regarding PartnerTech or our customers on social media sites, unless specifically requested to do so. Neither should we use social media in a way that can cause harm to the PartnerTech brand or reputation. When we as individuals speak about ourselves in the social media sphere, we must not spread any PartnerTech information that is not intended for the public (see also the Social Media policy). Respect for the individual PartnerTech provides equal employment, promotion, development and compensation opportunities to all individuals without regard to gender, race, religion, age, disability, sexual orientation, nationality, social or ethnic origin, citizenship, union affiliation, political opinions or any other characteristics protected by applicable law. Physical, psychological, sexual or verbal harassment against any colleague or business partner will never be tolerated. As employees we shall conduct our work with respect for all people regardless of differences. Page 5 of 7
7 Fair employment conditions Employment terms and wages shall be fair and reasonable. All employees, including those who are temporarily employed, should have their employment terms in writing and be made aware of them as confirmed by signatures from both the employer and the employee. Freedom of association All employees are free to exercise the right to form, join or refrain from joining unions or similar organizations devoted to collective bargaining. Representatives for trade unions must not be subjected to improper discrimination. PartnerTech gives official trade union representatives access to trade union members and their work places. Prevention of Involuntary or Child labor and human trafficking All work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice. PartnerTech does not tolerate underage labor in its operations or in the operations of any supplier or other party with whom we cooperate. The minimum employment age is the lawful age for working in the country in question. We do not allow illegal or forced labor in our operations or in the operations of any parties with whom we cooperate. The environment As a contract manufacturer and competence partner, we comply with laws, regulations and other requirements, aiming to satisfy them with margin to spare. We continuously work to reduce air and water pollution as well as the consumption of other natural resources throughout the value chain. We work systematically and our environmental programs feature continuous improvement, technical development and resource efficiency. Health & Safety We ensure the safety of all employees and any other persons who may be directly affected by the activities of PartnerTech, as far as reasonably practicable. We will at all times provide and maintain a safe and healthy working environment for all employees. We ensure that significant risks arising from work activities under our control are eliminated or adequately controlled via risk assessments. The use of drugs or alcohol at the workplace is not tolerated. We provide sufficient information, instruction, training and supervision to enable all employees to avoid hazards and contribute to their own health and safety at work. Page 6 of 7
8 Our employees are involved in health and safety decisions through consultation and cooperation. We comply with legal requirements, developing and implementing appropriate health and safety procedures and working practices. Reporting of violations If you become aware of unethical or illegal conduct, you are expected to report your concerns to any of the telephone numbers listed on the back of this folder. When reporting suspected violations, employees may choose to identify themselves, or to remain anonymous. There will be no retaliation against any employee making a report in good faith. If you need additional guidance, please consult your closest manager, Human Resources Manager or Managing Director. This code was adopted by the PartnerTech Group Management, May 1 st Contact Details Eva Klevås, Group HR Manager and Manager Global Training & Development Phone Mobile eva.klevas@partnertech.se Page 7 of 7
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