Code of Conduct Undertaking

SVANEHØJ is committed to carrying out its business in a sustainable way. In order to promote the long-term interests of SVANEHØJ and its stakeholders, the company strives to maintain the highest legal and ethical standards in all its business practices. Each employee is expected to act responsibly and with integrity and honesty, and to comply with SVANEHØJ's Code of Conduct and any underlying policies and instructions.

Introduction

SVANEHØJ is committed to carrying out its business in a sustainable way. In order to promote the longterm interests of SVANEHØJ and its stakeholders, the company strives to maintain the highest legal and ethical standards in all its business practices. Each employee is expected to act responsibly and with integrity and honesty, and to comply with this code and any underlying policies and instructions.

Compliance with laws

All business and other activities of SVANEHØJ shall be carried out strictly in compliance with all applicable laws, and under the principles of good corporate citizenship in each country where such activities take place. Each employee is expected to comply with the requirements of those laws and regulations that apply to SVANEHØJ’s operations and to his/her job, and with the SVANEHØJ principles of good corporate citizenship.

Openness

SVANEHØJ promotes openness and transparency, as well as continuous dialogue with its stakeholders, including customers and other business partners, shareholders, personnel, authorities, local communities and the media. SVANEHØJ strives to be honest and accurate when communicating with its stakeholders, and SVANEHØJ employees shall make their statements in accordance with this principle.

Respect for human and labour rights

SVANEHØJ supports and respects the protection of human rights as defined in the United Nation’s Universal Declaration on Human Rights. No employee is allowed to take any action that violates these human rights principles, either directly or indirectly. SVANEHØJ supports basic labour rights as defined by the International Labour Organization. In this respect, SVANEHØJ upholds the freedom of association and the effective recognition of the right to collective bargaining. In the case that these rights are restricted by local law, SVANEHØJ endeavours to offer its employees alternative means to present their views. SVANEHØJ does not accept any form of forced or compulsory labour or the use of child labour.

Fair employment practices

SVANEHØJ promotes freedom from discrimination based on race, ethnic or national origin, colour, gender, family status, sexual orientation, creed, disability, age or political beliefs, or other characteristics protected by law. SVANEHØJ fosters equal opportunity and employees are selected and treated on the basis of their abilities and merits. SVANEHØJ does not accept any form of discrimination, harassment or bullying from its employees.

Occupational health and safety

SVANEHØJ endeavours to create hazard-free workplaces for its employees, contractors, and others working in various locations by applying high standards of occupational health and safety. SVANEHØJ strives to assure the safety of its products and solutions through its product development processes. Each employee is responsible for complying with the safety instructions, for using personal protection equipment when required, and for reporting on any shortcomings regarding safety instructions or protection measures.

Conflicts of interest

SVANEHØJ expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of SVANEHØJ. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation.

Anti-corruption

No SVANEHØJ or any of its employees may, directly or indirectly, promise, offer, pay, solicit, or accept bribes or kickbacks of any kind, including money, benefits, services or anything of value. Such payments and favours may be considered bribery, which violates local legislation and internationally recognised principles for combating corruption and bribery.

Environment

SVANEHØJ’s target is to develop and produce for its customers, the products and solutions that fulfil applicable environmental requirements and good practices. Efforts are made to achieve sustainable development in our operations. Each employee shall comply with the policies and instructions regarding environmental protection.

Relationship with authorities and local communities

SVANEHØJ maintains constructive co-operation with authorities and regulatory bodies, at both local and international levels. SVANEHØJ seeks to play a role in serving the needs of the local communities whenever possible.

Innovation and protection of proprietary information

SVANEHØJ supports and encourages innovation by its employees in all areas of its activities. SVANEHØJ’ intellectual property is one of its most valuable assets and the patents, trademarks, copyrights, trade secrets, and other proprietary information of SVANEHØJ must be protected. At the same time, each SVANEHØJ employee must respect the intellectual property rights of others.

Accuracy of accounting records

SVANEHØJ accounting records must be accurate and reliable in all material respects. Unrecorded funds are prohibited. The records cannot contain any false, misleading, or artificial entries.

Competition and fair dealing

Competition laws aim to protect consumers and businesses against unfair business practices. Each employee shall comply with those laws. Actions such as participation in cartels, abuse of a dominant position in the marketplace, or the exchange of price or other commercial information between competitors, are prohibited.SVANEHØJ employees should be sensitive to competition concerns when attending occasions where competitors, or potential competitors, can be present.

Anti-fraud

SVANEHØJ does not tolerate fraudulent behaviour or activities, such as embezzlement, fraud or theft. Such violations will lead to immediate termination of employment and are subject to criminal sanctions.

Implementation

SVANEHØJ takes an active approach to the application of this code and promotes its implementation through the effective communication of its contents to its employees. SVANEHØJ monitors the application of this code internally. Suppliers and business partners are an important and integral part of the total value chain of the products and services of SVANEHØJ.

They are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as SVANEHØJ. SVANEHØJ promotes the application of this code by monitoring the actions of its suppliers and business partners. The application of the code will be reviewed from time to time by the Board of Management, which may decide on necessary revisions or interpretations.

Reporting violations

Any SVANEHØJ employee becoming aware of a potential violation of this code must contact his or her superior or SVANEHØJ’s HR or Top Management. The Top Management of the respective subsidiary must be informed unless he or she is party to the alleged violation, in which case the Svanehøj Group Management must be contacted. SVANEHØJ will investigate all reported matters with discretion. SVANEHØJ shall not take any adverse actions, as a result of such reporting, against any employee reporting in good faith what he or she believes to be a violation of this code.

Sanctions

Violation of this code may lead to a warning, termination of employment and payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.

Appearances

On business travels (e.g. service jobs), employees represent Svanehøj Group from the moment they leave their home address and until they return home. When interacting with our customers, employees are obligated to represent Svanehøj Group in the best possible way. Employees must be decently dressed when travelling between jobs as appearance is important. Employees should be well-rested when showing up on board or at the yard to start the job. Each employee is expected to behave professionally interacting with customers, yard workers, vendors and competitors.

Loyalty

Svanehøj Group expects full loyalty from its employees. It is important that no employee passes on rumours about colleagues, other departments within the company, products or way of working to third party as such act will reflect badly on the entire organization. In case an employee is confronted by customers about specific cases like warranty cases, it is of the utmost importance that the employee only passes on information already made official by Svanehøj Group HQ.