Code of Conduct Arctic Group AB

    Introduction and Scope

    This Code of Conduct exists to provide clarity by establishing guidelines for us to work by, so that each business is run in a way that we all can stand up for. It is our framework that helps us translate values into actions. Arctic Group has a strong confidence in all employees and together we collaborate, learn, and develop to create long-term value. With a growth mindset we take action, deliver quality and build trust with our customers. Our business provides positive societal impact because of our services and how we conduct and develop our business. Arctic Group’s goal is to improve our customers’ protection to combat cybercrime. We create secure digital solutions which contribute to a safer world.

    Arctic Group’s most important corporate principles related to business ethics, social, and environmental performance, are summarized in this Code of Conduct (“Code”). The Code defines how we do business and how we behave as employees.

    Generally, we shall comply with and, when relevant, go beyond the requirements of national legislation and regulations wherever we do business. We understand that the Code cannot cover every practical situation, we trust employees to use their judgment to determine the best course of action, always concerning our ethics, local laws and regulations.

    Arctic Group supports key norms and international conventions, including, but not limited to:

    • The 10 principles of the UN Global Compact
    • The OECD Principles of Corporate Governance
    • The OECD Guidelines for Multinational Enterprises
    • The Universal Declaration of Human Rights
    • The UN Guiding Principles on Business and Human Rights
    • The International Labour Organisation Conventions on Labour Standards
    • Task Force on Climate Related Financial Disclosures (TCFD)

    We aim to fulfill minimum safeguards related to the as forementioned vital norms and international conventions. A breach should lead to an investigation and measures seeking to prevent further violations.

    Arctic Group practices good governance across the group, including, but not limited to:

    • sound ESG management, decision making, and reporting along with regulatory requirements – own and our owner’s accountability and relations to key stakeholders – employees, customers, suppliers, and communities.
    • compensation structures
    • compliance management with applicable laws
    • negative events which are likely to have a material adverse impact on the financial returns and/or a negative impact on the environment and society
    • board practices

    At all times, the principles included in this Code apply everywhere we do business, and to everyone who works on Arctic Group’s behalf, including full and part-time employees, subcontractors, consultants, temporary staff, and the Board of Directors.

    You might not find all answers to your question in this Code. If you are ever in doubt about a course of action, ask yourself: Is it against the law? Is it unethical? Could it damage Arctic Group’s reputation? Would I be embarrassed to read about it in the media? If yes, stop and consult your manager who can help you find a way to handle the situation.

    You are accountable for following the Code, failing to do so might result in harmful situations for the company, and for you as an employee. You may be disciplined, and the company may be fined, face lawsuits, and suffer damage.

    Customers
    Since Arctic Group’s employees often work close to the customers in the customer’s premises and in the customer’s IT systems, it is of great importance that Arctic Group’s employees follow the customer’s code of conduct, safety instructions and other rules of conduct. If the customer has not issued any instructions, Arctic Group’s employees will request these. If the Code and the customer’s corresponding code of conduct differ, Arctic Group’s employees must use the rules that are most restrictive.

    Suppliers
    Arctic Group shall actively work, through written agreements, to ensure that suppliers undertake to follow the principles set out in this Code. Repeated or severe violations of the principles in the Code shall lead to termination of the business collaboration with the relevant supplier.

    Reporting Violations
    Each employee is expected to discuss any perceived risks or concerns about Arctic Group’s business practices with its manager. Employees must report suspected unethical, illegal, or suspicious behavior immediately. The company does not tolerate retaliation against anyone who makes a good faith report of alleged misconduct or otherwise assists with an investigation. When an alert is raised, it is subject to a thorough investigation with confidentiality and protection of the individual. See separate Whistleblowing Policy. To report a concern:

    • Talk to your manager
    • Contact the CEO

    Distribution of the Code and Acknowledgement of Receipt
    Arctic Group will distribute this Code to employees upon the commencement of employment and upon any change to the Code. All staff must acknowledge, in writing, that they have read, understood, and agree to comply with the Code. This will be complemented with regular training for all employees.

    Business Ethics

    Accounting and reporting
    Arctic Group is committed to provide full, fair, accurate, timely and understandable information in the company’s reports and communication. All financial transactions must be maintained according to Arctic Group record management standards, complying with each company’s statutory, regulatory, or contractual requirements. Business transactions shall be reported accurately, timely and fairly in the accounts of the company.

    Conflict of Interest
    A conflict of interest exists when a person’s private interest interferes, or appears to interfere, in any way with the interests of the Arctic Group. A conflict can arise when a team member takes actions or has interests that make it difficult to perform his/her work for Arctic Group objectively and effectively. Conflicts of interest may also arise when an employee, or members of his or her family, receive improper personal benefits because of his or her position at Arctic Group.

    Corporate Opportunities
    Employees are prohibited from (i) taking opportunities that are discovered through the use of Arctic Group’s property, information or position without the consent of the manager (ii) using Arctic Group’s property, information or position for improper personal gain, and (iii) competing with Arctic Group directly or indirectly.

    Fair Dealing and Competition
    Arctic Group must always act in accordance with current competition law. Arctic Group shall not exchange information or enter into agreements or arrangements with competitors, customers, or suppliers in a way that risks hindering, restricting, or distorting competition in the market.

    Bribery, Corruption and Money Laundering
    Arctic Group operates a zero-tolerance policy with respect to bribery and corruption and shall never accept, facilitate or in any way support activities that involve money laundering.

    The company and its employees may never provide gifts, benefits, or other unauthorized compensation in any form in relation to customers, suppliers, authorities, or other decision-makers for the purpose of obtaining or retaining business.

    Employees are not allowed to receive gifts, benefits, or other forms of remuneration from customers, suppliers, or other parties, that could affect the objectivity of their decision-making. Giving or receiving gifts and benefits of lesser value may be permitted in certain cases, provided that Arctic Group’s rules in the Personnel Handbook are followed.

    Protection of Confidential Information
    All employees must maintain confidential information and shall not disclose such information, directly or indirectly, to anyone unauthorized, corporation, or association. The information might include, but not be limited to information about Arctic Group’s strategies, processes, systems, technologies, customers, suppliers, agreements, services and other business activities.

    In cases where Arctic Group’s employees are introduced to, become aware of, confidential customer information, this information must be protected and not provided to anyone unauthorized. Arctic Group’s employees may not access, copy, reproduce or use the customers’ information other than to perform agreed services with the customer.

    However, confidential information may be disclosed when such disclosure is authorized by Management or upon prior consultation with Management, when such disclosure is required by laws or regulations. The obligation to safeguard confidential information continues even after employment or contractual agreement ends.

    Data protection, customers privacy and cybersecurity
    Arctic Group holds privacy and protects information as a key priority and treats data from connected customers, products, and solutions securely. The company exercises extreme care while managing data belonging to others and runs dedicated compliance controls and implementation programs according to the General Data Protection Regulation and other applicable rules and regulations.

    Arctic Group is aware of the criticality of its digital ecosystem and has therefore implemented the highest technical standards for risk-detection and response. The company’s processes, people and technology all must contribute to building, reinforcing, and solidifying digital trust internally and with our customers.

    Protection and Proper Use of Company Assets
    Employees should endeavor to protect the Arctic Group’s assets and ensure their efficient use. Any suspected incident of fraud or theft should be immediately reported for investigation.

    Compliance with Laws, Rules and Regulations
    Following the law is the foundation on which Arctic Group’s ethical standards are built. In conducting the business of Arctic Group, staff shall identify and comply with applicable law and sound business practice.

    Political involvement
    Arctic Group observes strict neutrality to political parties and candidates. Neither the names nor resources of Arctic Group shall be used to promote the interest of political parties or candidates.

    Taxation
    Arctic Group shall comply with the tax legislations and regulations of each country in which it operates.

    Human Rights and Workplace Standards

    Human Rights
    Arctic Group supports and respects the protection of the UN’s Universal Declaration of Human Rights and the Core Conventions of the International Labor Organization (ILO).  Arctic Group continually monitors and evaluates its value chain to ensure that everyone has safe working conditions, decent working hours and that no one earns less than a minimum living wage.

    Non-Discrimination
    Arctic Group recognizes diversity as strength. Discrimination or harassment against any covered party in respect of race, ethnic background, gender, disability, sexual orientation, religion, political opinion, maternity, social origin or similar characteristic is prohibited. Arctic Group does not tolerate any physical, psychological, sexual, or verbal harassment or any illegal threats against any colleague or business partner.

    Information and Communication
    Arctic Group strives to have a transparent and proactive communication with all stakeholders, without disclosing confidential information that could harm the company or its customers. Arctic Group respects every person’s right to express themselves and have opinions. Dissemination of confidential information or information that is detrimental to Arctic Group or its customers may, however, constitute a breach of the duty of loyalty in the employment contract.

    The duty of loyalty means that the employee must put the employer’s interests before its own and that the employee has a duty of confidentiality in matters concerning the work. This applies in all contexts – not only during working hours but also outside work, for example when the employee as a private person writes on social media. Only specially appointed spokespersons have the right to speak on behalf of Arctic Group and express the company’s official positions on various issues.

    Safe and Healthy Workplaces
    Arctic Group seeks to provide a safe, healthy, and productive environment that nurtures the employees’ well-being, leading to successful and sustainable results. When it comes to accidents, zero incidents are sought. Arctic Group shall take reasonable precautions to prevent workplace-related health issues. Arctic Group makes every effort to improve the work environment, frameworks, and policies continuously. Hence, the company is conducive to create personalized and regular follow-ups of the workstyles that marry flexibility and well-being. These efforts should take place both locally and centrally.

    Arctic Group expects all employees to refrain from using alcohol and drugs during working hours. Arctic Group apply smoke-free environments in workplaces, staff areas or similar areas where the employee and/or customer are active (This includes all smoking, including electronic cigarettes).

    Working hours, Compensation and Freedom of Association
    Arctic Group shall comply with applicable laws, agreements, and industry standards on working hours and compensation. Arctic Group respects the right of all employees to organize, join associations and bargain collectively or individually.

    Forced or Child Labor
    Arctic Group does not tolerate any forms of modern slavery, including forced, bonded or compulsory labor, or human trafficking. We respect children’s right to personal development and education, and we do not use child labor. The minimum age for employment shall be in accordance with the ILO Minimum Age Convention (No. 138) or the age specified by local legislation if higher. Covered Parties are free to leave their employment after reasonable notice as required by law and contract.

    Diversity and Inclusion
    Arctic Group promotes diversity and provides an inclusive working environment where everyone feels valued and respected, irrespective of their race, gender, marital/civil partnership status, age, disability, religion or belief, color, national origin, or sexual orientation.

    Gender equality is a priority across the entire company, from the Board of Directors to managers and employees; it is also considered in the selection process of vendors and contractors. Arctic Group has together with mother company Allurity signed up to the SHE indexes (https://www.sheindex.com/se) and has defined related targets to monitor annually, including disparities in pay between genders. The Head of HR is responsible for ensuring progress towards our targets, supported by several different firm-wide initiatives.

    Arctic Group requires a diverse pool of candidates from our recruiters (except in special circumstances) and tracks the share of high potential employees who are female.

    Improving gender balance is systematically considered when promoting and recruiting candidates for top management positions. Arctic Group has a practice of equal representation of men and women in the decision-making group when recruiting or promoting candidates to those positions.

    Society and the Planet

    Arctic Group believes in a sustainable combination of financial, social, and environmental results and is mindful of the human impact on the society and the planet. Arctic Group is committed to prioritizing the well-being of its employees, business partners and the community. Arctic Group’s commitment and communication apply equally to all stakeholders and is based on credibility, responsibility, proactivity, and interaction.

    Community Involvement
    Arctic Group seeks to be a responsible member of the communities in which we operate through focused partnerships at local and national levels. Arctic Group encourages staff to volunteer in local community organizations. In addition, as part of our commitment, we engage with schools and universities to offer apprenticeships to tomorrow’s energy efficiency technicians and to develop and retain them.

    Environmental protection
    Minimizing Arctic Group’s environmental impact is a prerequisite of its operation along with the core business activities. Arctic Group will continue to educate its staff on relevant environmental issues and provide opportunities to participate in regular environmental training. We will also comply with high standards and environmental regulations.

    Arctic Group will encourage its suppliers through agreements where practicable to prioritize as recyclability of purchased components, sustainable forestry, energy efficiency, emissions reductions, and proactive environmental protection.

    Climate actions
    Arctic Group shall continue to reduce their carbon footprint. In addition, Arctic Group is committed to align its operations and define targets to act upon to contribute to the goals of the Paris Climate Agreement. Progress will be measured at least annually.