CODE OF CONDUCT

Netel Group AB and its subsidiaries shall conduct the conduct of business in a responsible and sustainable manner. This should characterize our work throughout the entire value chain. Our success has a substantial effect on the amount of trust we can garner and is therefore crucial for our brand. A large amount of trust also simplifies and improves our relations with customers, suppliers, and other external partners, which is the foundation for valuable collaborations and business results.

Netel Group AB is a member of the UN Global Compact and supports its principles on human rights, work norms, environment, and corruption. The UN Global Compacts principles and a number of international guidelines are the basis of our Code-of-Conduct. These include the UN:s Universal Declaration of Human Rights, ILO:s (international labor organizations) Declaration of Foundational Principles and Rights at Work and OECD:s guidelines for multinational enterprises.

The Code of Conduct is adopted by Netel Group’s Board of Directors and covers all employees in 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 in which we operate. As an employee within the group, you are obliged to always promote its compliance. We expect all partners such as subcontractors and others who work for the Group to follow the ethical principles described in our Code of Conduct. All partners must undertake to follow Netel’s Code of Conduct for Suppliers.

Relation to national law

Our activities must in all respects follow and be conducted in compliance with prevailing national legislation and for each area and time applicable rules and regulations. This is superior to all of the business’ other goals and must in no way be disregarded.

As legislation and Code of Conduct regulate the same area, and do not conflict with each other, the highest standard must be applied. If any of the requirements of the Code of Conduct are in conflict with current legislation, the highest standard that complies with current laws must be applied.

Application and compliance

Any deviation from the code of conduct can lead to damage to the Group’s trust capital and brand. Failure to comply with the code of conduct is reported to 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 must immediately report this to their immediate superior or use the Group’s whistleblower function. Reports via the whistleblower function are handled anonymously and by an independent external party. Netel does not accept discrimination or retaliation against employees who have reported suspected violations of the Code of Conduct. Through the whistleblower 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 on reported deviations from the Code of Conduct.

Fundamental values

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

Our overall goal is to be a stable organization with profitable growth that offers stimulating and meaningful employment for our employees. In return, each employee must follow our code of conduct, prevailing policies and guidelines and otherwise always act professionally. We must all behave and act in such a way that we form a respected part of business and society. We will work for competition and equal treatment of companies or other players, regardless of size.

Values

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

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

Proximity: “We must work long-term and close to our customers, employees and suppliers. Before we undertake an assignment, we must know that we have access to the resources required to do a good job. We must be known for a close approach with short decision-making and be responsive to customer interests. ”

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

Credibility: “We must create credibility both internally and externally by working with knowledge and professionalism. Our customers must feel secure when they hire us. We must always behave with good business ethics, competence and professional skills. We must have good planning, do the right thing from the beginning, eliminate risks and keep the promised quality and time. We must comply with laws and requirements, choose the best possible technology, prioritize renewable resources and avoid environmentally harmful substances. ”

Commitment: “We must get involved in our customers, suppliers and in each other. We must be a personal and committed company. With our knowledge, experience and commitment, we must always give our customers that little bit extra.”

Long-term Perspective: “We will strive for long-term relationships, both internally and externally. We will work to ensure that the business we conduct is long-term sustainable from an environmental perspective. Through an honest and open dialogue with our customers and suppliers, we will create and maintain long-term and good relationships. We will work to ensure that our work tasks can be reconciled with family and leisure interests.”

Ethical requirements:

  • All employees must be treated equally and fairly.
  • We must respect the individual and do not accept abusive discrimination, harassment and bullying. Everyone should have equal opportunities regardless of ethnicity, religious orientation, gender identity or expression, age, nationality, language, political opinion, marital status, sexual orientation, disability or trade union membership.
  • We strive for diversity and more equal workplaces.
  • We must respect the right to freedom of association, opinion and expression as well as the right to bargain collectively.
  • We do not accept forced labor or child labor in any form.
  • We must respect the intellectual property rights of our suppliers and customers so that trademarks, goodwill, technology and know-how are handled and transferred in a way that protects intellectual property rights. This includes handling social media, phone calls, documents and data management in public environments (e.g. metro, air and train).
  • We will handle the company’s confidential information with care and not disclose such information to third parties.
  • We must act to counteract undeclared work, money laundering, other financial crime and the influence of illegal activities.
  • We have zero tolerance for bribery, corruption and fraud.
  • We must act correctly and in accordance with all applicable international and national norms and laws on gifts, bribes and corruption. As an employee and partner of Netel, you may not 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 will not accept gifts from suppliers unless the value can be considered small. Regardless of value, it is always forbidden to receive cash or equivalent, e.g. sponsorship and personal discounts. When visiting a supplier, participating in conferences, exhibitions, etc., all costs for travel and accommodation must be paid by Netel.
  • We do not accept anti-competitive practices. We shall act for fair competition in tenders, procurement and purchasing and counteract undue influence, bribery, price collusion, cartels, abuse of market dominance and various types of manipulation of tenders that aim to distort competition or that are contrary to applicable competition law.
    • f the matter concerns us or our spouse / partner, parent, child or sibling or any other related party or if the outcome of the case can be expected to bring particular benefit or harm to ourselves or a close relative,
    • if there is otherwise a special circumstance that upsets the confidence in our impartiality in the matter.
  • We shall not offer or give 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 the approval of the marketing manager.
  • Netel Group AB and all subsidiaries are politically neutral. Business funds may not be used to provide grants to political parties, organizations, candidates or holders of public positions. The Group can make contributions to industry organizations after approval by Netel Group’s Board of Directors.
  • As employees, we must not conduct competing activities or prepare ourselves or any other gain by using information or position in the organization.
  • In relation to customers and suppliers, we must clarify that the principles in this code of conduct must be applied to each other, and that agreements entered into must be followed and applied correctly.

Quality, environment and work environment

Quality

  • Netel shall deliver products and services of consistently high value, quality and reliability. Product safety is of the utmost importance.
  • For all projects, we must establish a project plan (quality, environmental and work environment plan) in order to prevent errors in service or product, reduce harmful environmental impact and ensure that safety, health and protection are given priority.
  • We will achieve good quality in our business and continuous improvements of its processes by actively working with our quality goals.
  • We must regularly assess the factors in working conditions and tasks that involve risks.
  • Our quality work is expressed in more detail in the quality policy adopted by Netel Group’s Board of Directors.

Environment

  • We must contribute to sustainable societal development. Each employee must 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 must strive to reduce our carbon dioxide emissions and recycle materials.
  • We must comply with laws and requirements, choose the best environmentally friendly technology, prioritize renewable resources and avoid environmentally harmful substances. We must always choose the least hazardous chemical and health products when purchasing.
  • We will identify, analyze and update our significant environmental aspects in the business to prioritize and minimize the environmental impact of these.
  • Our environmental work is expressed in more detail in the environmental policy adopted by Netel Group’s Board of Directors.

Working environment

  • We care about the well-being of our employees and promote a positive health and safety culture. This also applies to people who are not employed and who work in our premises and projects.
  • Our operations must be planned so that safety, health and protection are given priority.
  • We will work to prevent the work environment risks that our operations are associated with and prevent work environment accidents from occurring by:
    • Always use suitable protective equipment, e.g. seat belt and fall protection when working at high altitudes.
    • Never carry out electrical work on electrical equipment, circuits and tools without suitable qualifications and in accordance with regulations.
    • Never work under the influence of alcohol or drugs
    • Never use a mobile phone for calls, text messages, emails, etc. in connection with driving a vehicle. Hands-free should always be used during calls.
    • Always wear a seat belt, both as a driver and passenger.
    • Never drive a vehicle at a speed or in a way that, with regard to the road, surface and type of vehicle, can pose a danger to yourself or others.
    • Always have relevant training and experience for performing the tasks.
    • Always report risky situations or behaviors that violate applicable regulations to your immediate supervisor.

Personal data processing

  • We must be careful about how we handle personal data.
  • We must know what personal data we process and why.
  • We must keep register extracts of which personal data we process.
  • We must ensure that we have personal data agreements with our customers and suppliers before we receive, process or disclose any personal data.
  • We must be well acquainted with and follow our personal data policy.
  • We are aware that our own personal data is processed by the employer in order to pay salaries and taxes, etc. must be able to be fulfilled in the right way.
  • How we work with personal data and IT security is expressed in more detail in the IT policy adopted by Netel Group’s Board of Directors.