ASPO CODE OF CONDUCT
1. OUR COMMITMENT TO INTEGRITY
The Code of Conduct clarifies the standards of behavior that is expected of Aspo Group employees in the performance of their duties. It gives guidance in areas where employees need to make personal and ethical decisions. This Code of Conduct applies to all Aspo Group employees and operations.
Code of Conduct is approved and issued by Aspo’s Board of Directors.
At Aspo, we believe acting ethically and responsibly is not only the right thing to do, but also the right thing for our business. Aspo Code of Conduct (“Code”) is the foundation for doing business the right way.
We comply with applicable laws and regulations in all our operations. For us, however, integrity starts with our Code of Conduct and everyday ways of working.
Our Code of Conduct sets out the principles that help us make ethically sound decisions. We are all responsible for knowing our Code of Conduct, knowing how to do the right thing and understanding why it is important.
By making the right choices, we protect the value created at Aspo every day. Acting with integrity builds our reputation as a trustworthy partner, supplier, customer and employer.
As a member of the United Nations Global Compact, we value its ten principles relating to human rights, labour, environment and anti-corruption.
As Aspo employees, we are expected to:
- Read, understand and comply with our Code of Conduct
- Speak up and voice our concerns if we suspect any misconduct
- When You are uncertain about the right thing to do ask for advice from our managers or Aspo Legal who is responsible of Compliance
In addition, managers are expected to:
- Lead by example
- Communicate our compliance manual and company policies to their team and take the time to discuss how they apply to the team
- Promote an atmosphere in which team members feel they can voice their concerns
- Listen to the concerns of team members and escalate any suspected misconduct that they become aware of
- Supervise and support their teams in meeting the expectations above
2. OUR PEOPLE AND OPERATIONS
2.1 Respect people and human rights
Aspo is committed to respecting human rights in line with the United Nations Guiding Principles on Business and Human Rights. We promote decent working conditions. We do not tolerate the use of forced or child labour under any conditions.
Non-discrimination, diversity and inclusion
Aspo treats everyone with dignity and respect. All our employees must respect everyone’s right to freedom of thought, opinion, expression, religion and right to assemble peacefully. We don’t tolerate any discrimination based on employee’s education, personal skills, position, personality, lifestyle, work experience, ethnicity, religion, gender, sexual orientation, age, national origin, ability and other characteristics. This applies to all employee including temporary, migrant, student, contract, direct employees, and any other type of worker or a job candidate.
Aspo respects diversity and is dedicated to providing an inclusive and harassment-free working environment.
Well-being, health and safety
Employee well-being and health are important to Aspo. We never compromise on safety, and we only work with business partners that share our commitment to health and safety. We are all responsible for working safely at all times, and we must comply with relevant
occupational health and safety laws, as well as with our company safety rules and standards. All managers must instruct, supervise and support their teams, so they can work safely.
2.2 Environmental responsibility and product safety
Aspo respects the environment and strives to lower the environmental footprint in all of its operations. We are all responsible for that products are safe for the use they are meant for and meet their regulatory requirements.
3. BUSINESS INTEGRITY
3.1 Zero-tolerance for corruption and bribery
We do not tolerate corruption or bribery in any form. We never offer or pay bribes or allow bribes to be paid to government officials or private persons, and we never solicit or accept bribes.
Specifically, we must not give or offer anything of value to improperly influence a business decision to get business, keep business or gain an unfair advantage. We cannot do so directly or indirectly, meaning through a third party acting on Aspo’s behalf. Likewise, we must not, directly or indirectly, ask for or accept anything of value that might affect or appear to affect our ability to be objective in our business decisions. “Anything of value” must be broadly understood and includes any payment, loan, discount, political or charitable contribution, reimbursement, gift, gift card, meal, entertainment, trip, employment or internship, business opportunity, service or other benefit.
We make sure that gifts and hospitality always support a clear business objective and are accurately recorded, of reasonable value and appropriate to the nature of the business relationship. All requests and offers of any improper payment, benefit, gift or hospitality must be rejected and reported without delay to Aspo’s Compliance officer.
We compete vigorously, yet fairly and ethically, and within the framework of applicable competition laws. Each Aspo employee must adhere to competition laws, regulations and internal policies.
3.2 Protecting company assets and information
Tangible and intangible assets
In our everyday work, we are responsible for Aspo’s and our business partners’ assets, such as machinery, equipment, raw materials, vehicles, IT and mobile devices, funds, intellectual property and information. We are expected to handle them with care and protect them from damage, loss, theft and misuse.
All our employees must take appropriate measures to safeguard our and our business partners’ confidential information. We handle confidential information with care and share confidential information only with those who have the right to access the information and need it to do their work.
We follow our corporate policies and procedures to protect data from threats and unauthorized and illegal use. We respect the privacy of our colleagues, stakeholders and their representatives by handling personal data in compliance with relevant laws and company policies.
Disclosure and inside information
As a publicly listed company, we must comply with applicable laws and rules of the stock exchange when making Aspo’s information public. Only designated company employees can make public statements to the media on behalf of Aspo. We are committed to following the rules and regulations relating to market abuse and inside information, such as restrictions on trading and disclosure.
Decision-making and document trail
Our decisions must be made with Aspo’s best interests. Legal and financial approval procedures are in use throughout our organization, and we are committed to following them. These procedures include determining authorized persons, monetary limits and segregation of duties.
All business transactions must be recorded in our books and accounts accurately and fairly. Accurate recordkeeping and reporting help us meet our legal and regulatory requirements, for example, concerning taxation.
3.3 Avoid conflicts of interest
We are all expected to act in the best interest of Aspo. This means we must all avoid conflicts of interest, among other things. A conflict of interest arises when your personal interests conflict with Aspo’s interests. Even the appearance of a conflict of interest can damage the company and our reputation.
4. OUR STAKEHOLDERS
We seek productive, ethical and transparent relationships with our suppliers, agents, distributors, customers and contractors. We expect our partners to follow all applicable laws and regulations, and commit to our Supplier Code of Conduct.
Trade compliance and anti-money laundering
We operate our business in an international trade environment which requires importing and exporting of products, other goods, service and information, from one country to another.
We comply with applicable laws and regulations that affect our operations. Regulations include, but are not limited to embargoes and sanctions, customs import and export regulations, export controls, customs valuation, country of origin and preferential trade.
We do not conduct business in violation of applicable anti-money laundering, anti-terrorism and financial crime laws.
5. COMPLIANCE INVOLVES EVERYONE
We are all responsible for maintaining the integrity and ethical standards of Aspo. If we suspect misconduct, we are all obligated to speak up and report it, as well as listen to the concerns raised by others. We must never assume that someone else has reported a risk or concern.
Voice your concerns – Whistleblowing
We support a culture that encourages every individual to speak freely. We provide a safe, secure and confidential way to express concerns and questions when the usual ways are unavailable or inappropriate.
All employees must promptly report any suspected or observed breach of the law, this Code of Conduct, our compliance manual or other Aspo policies to
- their managers or company CEO
- a representative of Aspo Legal, Aspo HR or Aspo Internal Audit or
- use Aspo’s Whistleblowing channel via website https://report.whistleb.com/aspo
This makes it possible for us to deal with issues and correct them in a timely manner and prevent them from happening again at the same place or elsewhere in the organization.
We review misconduct reports carefully, handle personal data appropriately and maintain the confidentiality of reports to the extent possible.
We do not tolerate retaliation against any person who, in good faith, reports suspected misconduct or participates in an investigation to resolve suspected misconduct. Examples of retaliation include demotion, dismissal, denial of promotion, salary reduction and any kind of threatening, bullying or harassment. Any person, regardless of position, who engages in retaliatory behavior will be subject to disciplinary action.
Violations of our Code, including failure to promptly report a known Code violation, or making a false report of a violation, may result in disciplinary action up to, and including, termination of employment.
Aspo Board of Directors, December 18, 2019