Code of Conduct

1. Background and purpose

Broviken Gruppen AB (the parent company) has developed a number of group-wide governance documents, including this Code of Conduct, to ensure that all legal entities within the group (“Broviken”) comply with applicable laws and regulations and adhere to Broviken’s values.

The Code of Conduct clarifies Broviken’s values, principles, and ethical guidelines, and provides guidance for all employees within the group, regardless of their form of employment. The general principles of the Code of Conduct shall permeate the business, and all employees shall be well acquainted with its significance. Violations of the Code may result in disciplinary action, including termination of employment.

2. Target audience

This Code of Conduct shall be applied by all legal entities within the Group.

3. Code of Conduct

The Code of Conduct is based on the UN’s 10 principles for responsible business, defined in the following areas.

3.1. Social responsibility

3.1.1. Fundamental human rights and working conditions
Fundamental human rights shall be respected and applied to all employees regardless of their form of employment.

3.1.2. Health, working environment, and safety
A safe working environment shall be ensured by creating healthy and supportive workplaces and proactively preventing work-related injuries. All employees within the Group are responsible for reporting suspected deficiencies and contributing to improvements.

3.1.3. Diversity, equality, and inclusion
Broviken shall promote diversity, equality, and inclusion. Discrimination, harassment, threats, and inappropriate behavior are not permitted. Employees shall actively act against harassment and bullying.

3.2. Environmental responsibility

3.2.1. Counteracting climate change & adapting operations to climate change
Broviken shall actively contribute to the green transition and combat climate change by developing the Group’s services with direct and indirect sustainability impacts in mind. Measures to ensure responsible environmental work are defined in Broviken’s Sustainability Policy.

3.2.2. Purchasing
Purchases shall be made responsibly and with respect for resource utilization. Responsible purchasing ensures reliable and long-term business relationships. All suppliers must comply with national laws and regulations and respect international conventions.

3.3. Financial responsibility and Broviken as a business partner

3.3.1. Customers and quality
Broviken shall maintain high quality and good service. Laws, agreements, and internal rules shall always be followed. Broviken shall encourage customers to actively work with environmental issues in order to create added value for both customers and society. Broviken shall take sustainability aspects into account in relation to customers and assignments.

3.3.2. Reliable and secure information management
Confidential information, such as business plans, service development, employee data, salaries, medical data, and financial information, shall be protected against unauthorized use and dissemination. Information from external parties shall be protected with the same care as the Group’s own data.

3.3.3. Business, competition, and accounting principles
Broviken shall act as a reliable Group and fulfill its commitments. Financial transactions shall be accounted for according to the Group’s accounting principles and laws. The Group shall promote fair competition and comply with laws prohibiting anti-competitive agreements, including price-fixing and cartels.

3.3.4. Prevention of corruption, conflicts of interest, undue benefits, gifts & bribes
Broviken has zero tolerance for bribery and corruption and does not accept undue influence from business partners, customers, or other stakeholders. Employees and business partners may not accept or request benefits that could be perceived as corruption.

Business decisions shall be based on objective data, not personal interests. Transactions with related parties and transactions that may create conflicts of interest shall be avoided. Every employee has a responsibility to act vigilantly and restrictively to prevent conflicts of interest. If a conflict of interest nevertheless arises, it shall be handled openly, and any suspicions must be reported immediately.

Employees must maintain trust in Broviken, the company, and themselves, both professionally and privately. They must also comply with laws and regulations and avoid unethical tax planning and improper activities.

3.3.5. Prevention of money laundering and terrorist financing
Broviken Group AB shall comply with the Money Laundering Act and the Swedish Financial Supervisory Authority’s regulations on measures against money laundering and terrorist financing. Within the Group, each company is responsible for complying with relevant laws and regulations to combat money laundering and terrorist financing.

3.4. Reporting suspected violations

All Broviken employees are expected to follow the Code of Conduct, policies, procedures, and applicable laws, and to report any irregularities that violate these. Employees should feel safe to report without fear of negative consequences, and their reports should be treated seriously, professionally, and confidentially.

For reporting misconduct of public interest, such as accounting fraud, bribery, corruption, mishandling of personal data, or serious irregularities such as environmental crimes and safety deficiencies, special procedures are in place. Broviken’s whistleblower channel, Visslan, shall be used, or the company’s own channel if one exists. During processing, the identity of the reporter shall be protected, and unauthorized access to the case shall be prevented. The identity will not be disclosed without consent, except when required by applicable law, and protection against reprisals shall be ensured.

4. Roles and responsibilities

The Group CEO is responsible for this Code of Conduct, including ensuring its implementation and monitoring compliance.