SUNDS FIBERTECH’S CODE OF CONDUCT

January 01, 2020

To support us in doing the right thing, we have a set of rules called Sunds Fibertech’s Code of Conduct. The Code defines the morals and ethics, responsibilities, and proper practices for us as individuals, teams, and as a company. The purpose of the Code is to safeguard Sunds Fibertech’s business by informing all Sunds Fibertech’s personnel, as well as our external stakeholders, of the company’s requirements and expectations.

Scope

The Code of Conduct applies to all employees including our subsidiaries and our board members.

• Each company within our groups is responsible for the ethical guidelines and for monitoring these.
• All employees refer to all employees in the parent company and subsidiaries.
• MDs and Managers in our companies have a special responsibility and should lead by example.
• All managers are required to go through the Code of Conduct with new employees and ensure all other employees are aware of the guidelines and what they mean in relevant contexts.

Each MD will ensure that disciplinary actions, are taken against those who violate this Code of Conduct and that circumstances in violation of applicable laws and regulations are reported to the relevant authorities.

Our commitments

Our Code of Conduct is based on the UN Global Compact’s ten principles which are in turn based on the UN Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at work, the Rio Declaration on Environment and Development, and the UN Convention Against Corruption.

Respect for people and human rights

We respect basic human rights and we follow laws and regulations

• We respect the UN conventions on human rights and accepts the responsibility we have towards our employees and the communities in which we operate.
• We comply with the laws and regulations that apply in the countries in which we operate.

We offer our employees fair and reasonable working conditions

• We seek to attract, develop and retain qualified and motivated employees.
• Our employees shall be offered a safe and healthy work environment, which we continuously seek to improve.
• The conditions of employment offered to employees must meet the minimum requirements in national law and/or collective agreements as well as relevant ILO conventions. We take every effort to pay fair salaries and remuneration in accordance with relevant norms in the locations in which we have operations.

We reject child labour and forced labour

• We do not employ any person under the age of 15 or any applicable higher statutory minimum age.
• We do not accept forced labour, slave labour or other forms of involuntary labour at our workplaces.

We are a non-discriminatory workplace

• We offer all individuals equal opportunities regardless of skin colour, gender, nationality, religion, ethnicity or other distinguishing characteristics.
• We make active efforts to achieve a corporate culture and workplace free from discrimination and harassment.
• Employees have a joint responsibility for this to be achieved.

We respect our employees’ right to be organized

• Our employees are entitled to form or join a trade union and we respect the rights of our employees and their trade unions to negotiate collective agreements.

We are against purchase of sexual services and child pornography

• Purchase of sexual services, sexual exploitation of children and child pornography is illegal based on legislation in several countries, and can support trafficking, which is a violation of human rights.
• Employees on assignments and business travel, also internationally, are expected to respect our stance. This applies irrespective of country and both during and after working hours.

Career development

• We encourage our employees’ career development. When open job titles are published, we seek new employee internally first, if possible.

Good business ethics

All employees and representatives are expected to show honesty and integrity in dealing with other employees, customers, suppliers, business partners, organizations and authorities.

• We have zero tolerance for all forms of corruption and makes active efforts to ensure that this does not occur within the Group.
  -The term corruption refers to abuse of a position of trust for own or the company’s gain, for example through the use of bribes.
  – It is forbidden to offer, promise or give as well as request, accept a promise of or receive a bribe.
  -A bribe is a gift or other benefit that might influence another person, as part of their employment or duties, to show improper favour to the giver.

We support and aim to achieve fair competition

• Employees must therefore comply with all relevant competition rules and refrain from concluding unlawful anti-competitive agreements as well as exchanging unlawful price and/or market information with competitors.

Conflicts of interest are avoided

We are politically independent, and our employees work in the best interests of the company

• Our employees shall always work in best interests of the company and avoid all acts that might be perceived as favouring a company, organizations, individuals, or other stakeholders at the company’s expense. Employees shall avoid all types of activity that violate the company’s interests or have a negative effect on the employee’s judgement and integrity.
• Agreements with or other forms of assignments to related parties shall be avoided, and always be reported to and approved by the nearest manager or the company’s Group management.
• We as a company do not take a political stand and therefore, we do not use funds from the company to support political campaigns or other political purposes.

Respect for the environment

Consistent and long-term environmental work creates both environmental benefits and value

• Our aim is to meet the expectations placed on us by the company’s shareholders, employees, the outside world and employees in our subsidiaries, regarding our business model and long-term sustainable development.
• Necessary emission and discharge permits shall be obtained where required.
• Procedures and standards for waste management (handling and disposal of chemicals and other dangerous materials) and for emissions and effluent treatment must meet or exceed minimum legal requirements.
• In our operations we will, where possible, work to reduce our environmental impact by preventing and reducing pollution and the use of harmful substances and contribute to long-term, sustainable development through active and systematic environmental work.

Safe products and traceability

Regular control of product safety

• Products manufactured within our Group and its subsidiaries must comply with all laws and regulations relating to product safety. Products shall be traceable in accordance with applicable legal requirements and industry standards.
• It is important that all employees are aware of which regulations apply to product safety for the companies they are involved with and that regular checks are performed to ensure compliance.

Duty of care for the company’s assets

Our employees respect our property

• We have both physical assets (machinery, equipment, etc.) and intellectual property (computer systems and programs, concepts, trade secrets, brands, etc.). Assets, including communication systems, may only be used for legitimate business purposes and not for personal gain or gain for a third party.
• The employee has a duty to protect property and assets against damage, theft and misuse.

Personal information

We respect personal information and handles it carefully

• We respect individual personal information that the company can obtain or use in information processing. Processing of personal data shall be in accordance with the currently applicable personal data policy.
• Our management and the management of each subsidiary are responsible for ensuring that personal data in their operations is handled in accordance with applicable laws and regulations.

Personal responsibility and routines for reporting violations

All employees must read the Code of Conduct and are responsible for knowing the laws, guidelines and regulations relevant for their working duties. If an employee has questions relating to practical situations (e.g. giving or receiving of gifts/rewards or conflicts of interest) the immediate manager should be consulted in the first instance.
If an employee suspects a possible behaviour that deviates from the Code of Conduct, this should be reported to the immediate manager as soon as possible. If such person is involved or otherwise disqualified, the event should be reported to the next-highest manager, or alternatively according to the reporting instruction for the company concerned.

All reports shall be taken seriously and investigated where necessary. There shall be no form of retaliation (termination of employment, harassment, discrimination, etc.) for reporting in good faith of a violation of the Code of Conduct or participation in the company’s investigation of a complaint.

Date: 2020-01-01

Acknowledged by: Lars Eklund, CEO