Introduction

The why, responsibilities and raise a concern.


The Code of Conduct is an understanding and an introduction to our most important policies and principles and guides our employees in how we interact with each other and with our clients when doing our job.
Therefore, the Code of Conduct applies to all Human Entrance AB’s employees, contractors and consultants and its affiliated entities. Together referred to as “employees” in this policy. Human Entrance AB referred to as we, us, our, the company in this policy.
As an employee, it is your personal responsibility to comply with and to follow the Code of Conduct when performing your work duties.
As a manager it is your responsibility to ensure that your team members are aware of, understand and follow the Code of Conduct.
Conducting business in an ethical and fair way is of the highest importance to us. All our policies and guidelines are created with this in mind. To establish openness, trust and respect among our employees, business partners, investors, and all other stakeholders, we believe transparency is key. Therefore, we encourage anyone, internally or externally, that experiences a misconduct or any other type of malpractice to raise a concern. Raising a concern, you as an employee or as an external part, shall be confident that your identity will be protected. It is possible to raise a concern anonymously via our website (Raise a Concern – Human Entrance ) and the concern will be taken up within the organization.
Repeated and intentional violations of the Code of Conduct may result in disciplinary actions of an employee. Depending on the violation the consequences could be a verbal or written reprimand, suspension, or termination for more serious offenses. We may take legal action in cases of corruption, theft, embezzlement, or other unlawful behavior.


COMPLIANCE WITH THE LAW
The company and its employees are compliant with the national laws in the communities in which we operate. We and our employees will protect our company’s legality and comply with all environmental, safety and fair dealing laws. We expect employees to be ethical and responsible when dealing with our company’s finances, products, partnerships, and public image.
The specific laws that adhere to our area or work can be found in our Compliance Management Policy.


EMPLOYEES & WORKPLACES
DIVERSITY
Diversity is one of the foundations when building our workforce. We strive to be a workplace full of innovation, creativity, and success. Our strongest belief is that we will benefit and grow stronger from having a diverse mix of employees.
The company will make decisions related to our employees’ employment, promotion, development, training, and compensation based on competence, knowledge, and performance. These decisions will not be based on any discriminating categories such as race, nationality, ethnic or social origin, age, religion, political orientation, gender, sexual orientation or identity, family or marital status, pregnancy, or disability.
In turn all employees will respect the above and support the diversity within the company and treat their fellow colleagues with respect, integrity, and professionalism. Any kind of discriminatory behavior, harassment, or victimization against any employee will be acted on and disciplinary measures taken.

Occupational, health and well-being
ENVIRONMENT, HEALTH, AND SAFETY
We are committed to protecting the environment, health and safety of our employees, clients, and the communities we operate in.
We strive to provide a physically and mentally safe and functional work environment for our employees working in one of our offices or remotely from home. We work continuously to prevent accidents, illness, addiction related issues and injuries.
We and our employees are all responsible for creating a good working environment and to keep up a good spirit. We do not tolerate any form of harassment, retaliation, bullying or other physical or verbal acts of an abusive nature.
The company shall collect and store personal data in a correct and lawful manner. Data obtained shall be relevant for the purpose for which it has been collected and treated with great caution. We will make sure that any third parties that handle personal data related to our employees will follow the principles stated in GDPR.
Travelling within work is sometimes necessary, we and our employees will all strive to choose the more environmentally friendly option and consider if the meeting can take place digitally.
We are committed to choosing environmentally neutral alternatives wherever we can to not have a negative impact on the planet and our carbon footprint. We pledge to continually explore further initiatives to make a positive impact on climate change.

WORKING TOGETHER
All employees will accomplish their responsibilities with integrity and respect toward customers, stakeholders, and the community.
Our employees will avoid any conflicts of interests. We expect employees to avoid any personal, financial, or other interests that might hinder their capability or willingness to perform their job duties.
We recognize the employees’ rights and freedom to join or form assembly or associations of their own choice and to bargain collectively.
We respect the right to a good balance between work and private life and the right to leisure time and rest.
We and our employees all agree to and support our equal opportunity policy in all aspects of our work, from recruitment and performance evaluation to interpersonal relations.
All employees will fulfil their job duties with integrity and respect toward customers, stakeholders, and the community. Managers and team leaders will not in any way abuse their authority. We expect them to delegate duties to their team members considering their competences and workload. Likewise, we expect team members to follow manager’s and team leaders’ instructions and complete their duties with skill and in a timely manner. We encourage mentoring throughout our company.
We promote a friendly, collaborative, and respectful work environment with open and clear communication between our employees.
We do not accept child labor or any form of forced or compulsory labor, slavery, or torture.

ANTI CORRUPTION AND ANTI FRAUD
The company and its employees do not engage in any type of bribery or any form of unethical inducement or payment. All employees are required to avoid any activities that might lead to, or suggest, a conflict of interest with the business of the company. We do not make direct or indirect contributions to political parties.
Gifts or hospitality given or received shall be moderate and characterized by openness and constitute a natural and useful element in the work. Agreements or understandings regarding favors or benefits of any kind in exchange for gifts are not accepted.
Employees shall declare and keep a record of hospitality or gifts accepted or offered, which will be subject to managerial review. If uncertainty arises related to any gift or business courtesy our employees are encouraged to turn to their manager for advice.
We and our employees will uphold laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific business practices. The national laws are followed as stated in our Compliance Management Policy.

PROTECTION OF COMPANY PROPERTY & RESOURCES
Company resources, including material, equipment, and information, are provided for company business use. Nonetheless, occasional personal use is permissible if it does not affect job performance or cause a disruption to the workplace.
Employees and those who represent the company are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.
Employees will respect all kinds of incorporeal property.
This includes trademarks, copyright, and company property. May include but not be limited to; business sensitive or client-related information or reports etc. Employees should use such items only to complete their job duties. Employees should protect company facilities and other material property (e.g., company cars) from damage and vandalism, whenever possible. Employees should not misuse company equipment or use it frivolously.
We will not use company equipment such as laptops, copiers, or scanners in the conduct of an outside business or in support of any religious, political, or other outside daily activity, except for company-requested support to non-profit organizations. We will not ask for contributions nor distribute non-work-related materials for private reasons during work hours.
To protect the interests of the company’s network and our fellow employees, we reserve the right to monitor or review data and information contained on an employee’s company-issued laptop or electronic device, the use of the Internet or our intranet.
We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate.

Information security and data protection
The company will collect, process and store data in accordance with the law as stipulated in the General Data Protection Regulation. It is done in a lawful, limited way considering and honoring the rights of the data subject: the right to their data, access, rectification, erasure, restrict processing, portability, and the right to object.
All employees operate under a confidentiality agreement and a separate non-disclosure paragraph is included in the employment contract.
All employees are responsible for the safe use of the IT equipment given to them at the start of their employment. They will take all reasonable steps and actions to protect the laptop, mobile phone and other devices against viruses, unauthorized access or other attacks against system security and integrity.

CORPORATE RECORDKEEPING
We create, retain, and dispose of our company records as part of our normal course of business in compliance with all Human Entrance policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with Human Entrance and other applicable accounting principles.
We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of [Company Name] books, records, processes, or internal controls.

COMMUNICATION AND TRAINING
We will communicate this policy and relevant guidance to employees across all operations through our established internal communication channels. We will also communicate this policy to our suppliers, contractors and business partners and wider stakeholders. Managers and employees will receive relevant training on how to implement this policy in the scope of their employment at Human Entrance AB.