Anti-Bribery and Anti-Fraud Policy

Human Entrance AB Anti-Bribery and Anti-Fraud Policy

Our corporate conduct is based on our commitment to acting professionally, fairly and with integrity. Human Entrance does not tolerate any form of bribery and corruption.

Purpose of Policy

The purpose of this policy is to set out the responsibilities of all business functions and business units at Human Entrance AB in observing and upholding our position on bribery and corruption.

Policy

This policy applies to Human Entrance employees (staff, contract and temporary) and extends to our entire majority owned business dealings and transactions in all countries in which we or our subsidiaries and associates operate. Where we have a minority interest we will encourage the application of this policy amongst our business partners including contractors, suppliers and joint venture partners.

This policy should be implemented in conjunction with the guidance on giving and accepting gifts and hospitality, which is available in our Employee Handbook.

We are committed to operate responsibly wherever we work in the world and to engage with our stakeholders to manage the social, environmental and ethical impact of our activities in the different markets in which we operate. Human Entrance AB does not engage in bribery or any form of unethical inducement or payment including facilitation payments and ‘kickbacks.’ All employees are required to avoid any activities that might lead to, or suggest, a conflict of interest with the business of Human Entrance AB. Employees must declare and keep a record of hospitality or gifts accepted or offered, which will be subject to managerial review. We do not make direct or indirect contributions to political parties.

We 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 following national laws underpin this policy:

• SE Penal Code (SFS 1962:700) Chapter 10
• SE Income Tax Act (SFS 1999:1229) Chapter 9
• SE Marketing Act (SFS 2008:486)

Responsibilities

The Managing Director of Human Entrance AB has the primary responsibility for implementing this policy and for reporting annually to the Human Entrance Board.

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.

Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage.

Review of policy and records

The Managing Director of Human Entrance AB will together with relevant stake holders within the company review the implementation of this policy in respect of its suitability, adequacy and effectiveness and make improvements as appropriate. It will periodically report the results of this process to the Human Entrance Board.

Human Entrance AB will establish feedback mechanisms in order to maintain accurate records – available for inspection –which properly and fairly document all financial transactions. Internal control systems will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

Version 2017-01-01

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