Code of Conduct

Netel Group and its subsidiaries shall conduct business in a responsible and sustainable manner. This should characterize our work throughout the entire value chain. Our success has a major impact on our trust capital and therefore a crucial importance for our brand. A large amount of trust both simplifies and improves our relationships with customers, suppliers and other external parties, which is the basis for good cooperation and business results.

Netel Group is a member of the UN Global Compact and supports its principles on human rights, labor standards, the environment and corruption. The UN Global Compact’s principles and a number of international guidelines form the basis for our Code of Conduct. These include the UN’s Universal Declaration of Human Rights, the ILO (International Work Organisation’s) Declaration of Fundamental Principles and Rights at Work and the OECD guidelines for multinational companies.

The Code of Conduct has been adopted by Netel Group’s Board of Directors and covers all employees of the Group, including the Board. The Code of Conduct summarizes how we should act within the company, in relationships with our customers and suppliers and in the society we operate in. As an employee of the Group, you have an obligation to promote its compliance at all times. We expect all partners such as subcontractors and others who work for the Group to comply with the ethical principles described in our Code of Conduct. All partners must agree to follow Netel’s Code of Conduct for Suppliers.

Relation to national legislation

Our business must, in all respects, comply with and be conducted in accordance with current national legislation, and applicable rules and regulations for each area and time. This takes precedence over all of the other objectives of the business and may not be disregarded in any way.

Where legislation and the Code of Conduct govern the same area, and do not conflict with each other, the highest standard must be applied. If any of the requirements in the Code of Conduct conflicts with current legislation, the highest standard in accordance with current laws must be applied.

Application and compliance

Any deviations from the Code of Conduct may damage the Group’s trust capital and brand. Failure to comply with the Code of Conduct is reported to the Group management and serious deviations are reported to the Board.

Deviations may lead to disciplinary action and termination.

Anyone who suspects a deviation from the Code of Conduct shall immediately report this to their immediate manager or use the Group’s whistle-blower function. Whistleblower notifications are handled anonymously and by an independent external party. Netel does not accept discrimination or retribution against employees who have reported suspected violations of the Code of Conduct. Through the whistleblowing function, employees, customers, subcontractors, suppliers and other stakeholders can anonymously report suspected deviations from the Code of Conduct.

All new employees must read and confirm that they have understood the Code of Conduct by signing it. Managers have a special responsibility to ensure that employees and partners are informed about and understand the Code of Conduct and to follow up reported deviations from the Code of Conduct.

Fundamental values

Our success depends on the skills and commitment of each employee. We take a positive view of, and encourage, employees’ own initiatives for further development. All employees must be able to express their opinion openly and honestly. Good health is fundamental for achieving good results and well-being. We must be an attractive workplace that creates long-term value for customers and society.

Our overall objective is to be a stable organization with profitable growth that offers stimulating and meaningful employment for our employees. In return, every employee must follow our Code of Conduct, prevailing policies and guidelines and otherwise always act professionally. We must all conduct ourselves and act in such a way that we are a respected part of the business community and society. We must promote competition and equal treatment for companies or other actors, regardless of size.

Values

At Netel, we work with freedom subject to responsibility and with a high degree of responsibility far out in the organization. Despite the size of our company, we are still a “small” company, with short decision-making paths, close dialogue between all employees, and a door-is-always-open feeling among our management. We believe in respect for each other as individuals and welcome initiative and employees’ striving to develop with the company. Netel is a down-to-earth company with great care for quality.

Our corporate culture is characterized by the following five core values; Proximity, Efficiency, Credibility, Commitment, Long-term approach.

Proximity “We shall work with a long-term view and close to our customers, employees and suppliers. Before we accept an assignment, we must know that we have access to the resources required to do a good job. We shall be known for a close working method with short decision-making paths and be sensitive to customer interests”.

Efficiency “We shall constantly strive for the highest possible quality in an efficient manner. By being effective, we create added value for our customers”.

Credibility “We shall create credibility both internally and externally by working with knowledge and professionalism. Our customers shall feel secure when they hire us. We shall always conduct ourselves with good business ethics, competence and professional skills. We shall have good planning, get it right from the start, eliminate risks and deliver promised quality and timeliness. We shall comply with laws and requirements, choose the best possible technology, prioritize renewable resources and avoid environmentally harmful substances”.

Commitment “We shall be committed to our customers, suppliers and each other. We shall be a personable and committed company. With our knowledge, experience and commitment, we shall always give our customers that little extra”.

Long-term approach “We shall strive for long-term relationships, both internally and externally. We shall work to ensure that our business is sustainable from an environmental perspective. Through an honest and open dialogue with our customers and suppliers, we shall create and maintain.

Ethical Conduct Requirements

All employees should be treated equally and fairly.
We shall respect the individual and shall not accept discrimination, harassment or bullying. Everyone shall have equal opportunities regardless of ethnicity, faith, gender identity or expression, age, nationality, language, political opinion, marital status, sexual orientation, functional disability or union membership.
We strive for diversity and a more equal workplace.
We shall respect the right to freedom of association, opinion and expression as well as the right to collective bargaining.
We do not accept forced labor or child labor in any form.
We shall respect our suppliers’ and customers’ intellectual property rights so that brands, goodwill, technology and knowledge are managed and transferred in a way that protects intellectual property rights. This includes handling social media, phone calls, document and data management in public environments (e.g. subway, airplanes and trains).
We shall manage the company’s confidential information with care and not disclose such information to third parties.
We shall act to prevent undeclared work, money laundering, other financial crime and the impact of illegal business.
We have zero tolerance of bribery, corruption and fraud.
We shall act correctly and in accordance with all applicable international and national standards and laws on gifts, bribes and corruption. As an employee and partner of Netel, you cannot offer or arrange travel, give gifts or other services or benefits that are illegal or improper and cannot be reviewed and reported openly and in accordance with our policy. We shall not accept gifts from suppliers unless the value can be deemed to be insignificant. Regardless of value, it is always prohibited to accept cash or equivalent, e.g. sponsorships and personal discounts. In case of visits to suppliers, participation in conferences, exhibitions, etc., all travel and accommodation costs shall be paid for by Netel.
We do not accept anti-competitive practices. We shall act for healthy competition when tendering, procuring and purchasing as well as prevent undue influence, bribes, price collusion, cartels, abuse of market dominance and various types of manipulation of tenders aimed at distorting competition or which violate current competition legislation.
We shall not make a decision if we have a conflict of interest. If we are aware of a conflict of interest that can be assumed to be a conflict of interest against us, we shall voluntarily disclose this and report it to the immediate manager. We have a conflict of interest.
if the matter concerns us or our spouse/partner, parent, child or sibling or any other related party or if the outcome of the matter can be expected to result in significant benefit or damage to ourselves or any related party,
if there is any other particular circumstance that undermines the trust in our impartiality in the case.
We shall not offer or grant any undue advantage, benefit or incentive to a public official, international organization or any other third party. This applies regardless of whether it takes place directly or through an intermediary.
We shall not participate in advertising or marketing materials made to publish our suppliers’ products and services without approval from the Marketing Manager.
Netel Group AB and all subsidiaries are politically neutral. Company funds may not be used to make contributions to political parties, organizations, candidates or holders of public positions. The Group can make contributions to trade associations after approval by Netel Group’s Board.
Netel Group AB and all subsidiaries are committed to maintaining the highest ethical standards in all aspects of our business operations. Compliance with international sanctions is integral to our values and practices. We strive to conduct our business in a responsible and lawful manner, ensuring that we do not engage with entities or individuals subject to sanctions imposed by United Nations, European Union or other relevant authorities.
As employees, we shall not operate competing businesses or create a benefit, for ourselves or someone else, by utilizing information or our position in the organization.
In relation to customers and suppliers, we shall clarify that the principles of this Code of Conduct must be applied mutually, and that concluded agreements must be followed and applied correctly.

Human rights

Netel has a direct impact on the human rights of not only our employees, but the people we impact through our business operations. As a critical infrastructure company, we are aware of the impact that we can have through our operations, in the communities where our infrastructure is located, and in the construction of critical infrastructure.

We conduct our operations in a way that respects human rights and this policy applies to everyone at Netel, including contractors, and those who act on behalf of or represent us.

Netel is committed to respecting human rights as defined in the International Bill of Rights, the ILO Fundamental Conventions on Labour Standards and the UN Guiding Principles on Business and Human Rights.

As part of our commitment to respecting human rights, we have identified our salient human rights issues, which will be the issues we place the most focus on. These are:

Health and safety in the construction and installation of infrastructure
The use of contractors
Diversity and non-discrimination
To achieve our commitment to respect human rights, we shall:
Conduct human rights due diligence throughout our operations and value chain.
Ensure that all employees, contractors and suppliers are aware of this policy and place expectations on our contractors and suppliers to do the same for their employees.
Provide training on relevant human rights topics to our employees, and expect our contractors, third-party personnel and suppliers to do the same.
Comply with all relevant local, national and international laws and regulations. Where local laws conflict with human rights standards defined by this document, we will comply with local laws, while working to uphold and promote our human rights commitments.

Quality, environment and work environment

Quality

Netel shall deliver products and services of consistently high value, quality and reliability. Product safety is of the highest importance.
For all projects, we shall establish a project plan (quality, environment and work environment plan) in order to prevent errors in services or

Environment

We shall achieve good quality in our business and continual improvement of its processes by actively working with our quality goals.
We shall regularly assess the factors in working conditions and work tasks that entail risks.
Our quality work is described in more detail in the quality policy adopted by Netel Group’s Board.
We shall contribute to sustainable social development. Every employee shall work to minimize negative environmental impact and work for
long-term sustainability in their part of the business. This means, among other things, that we shall strive to reduce our carbon dioxide emissions and recycle materials.
We shall comply with laws and requirements, choose the best environmentally friendly technology, prioritize renewable resources and avoid environmentally harmful substances. We shall always choose the least health- and environmentally hazardous chemical products when purchasing.
We shall identify, analyze and update our significant environmental aspects of the business to prioritize and minimize their environmental impact.
Our environmental work is described in more detail in the environmental policy adopted by Netel Group’s board.

Work environment

We safeguard the well-being of our employees and promote a positive health and safety culture. This also applies to people who are not employees but who work on our premises and projects. Our business must be planned so that safety, health and protection are prioritized.

We shall work to prevent the work environment risks that our business is associated with and to prevent work environment accidents from occurring by:

Always use appropriate protective equipment, such as safety harnesses and fall protection when working at heights.
Never perform electrical works on electrical equipment, circuits and equipment without appropriate qualifications and in accordance with rulebooks.
Never work under the influence of alcohol or drugs.
Never use a mobile phone for calls, texts, emails, etc. when driving a vehicle. Handsfree must always be used when making calls.
Always use seat belts, both as drivers and as passengers.
Never drive a vehicle at a speed or in a manner which, regarding road, surface and type of vehicle, may endanger yourself or others.
Always have relevant training and experience for carrying out the work tasks.
Always report risky situations or behaviors that violate applicable regulations to your immediate manager.
Our work environment efforts are described in more detail in the health and safety policy adopted by Netel Group’s Board.

Processing of personal data

We shall be careful with how we handle personal data.
We shall know what personal data we are processing and why.
We shall keep records of personal data we process.
We shall ensure that we have personal data agreements with our customers and suppliers before we receive, process or disclose any personal data.
We shall be familiar with and follow our personal data policy.
We are aware that our own personal data is processed by the employer in order to enable the correct payment of wages and taxes, etc.
The way we work with personal data and IT security is described in more detail in the IT policy adopted by Netel Group’s Board

Jeanette Reuterskiöld
CEO Netel Group