KOMMUNINVEST I SVERIGE AB. Ethics policy

Transcription

1 KOMMUNINVEST I SVERIGE AB Ethics policy

2 Table of contents 1 Introduction 2 2 General principles 2 3 Insulting behavior is never accepted 2 4 Political neutrality 3 5 Transactions based on tax planning 3 6 Trading in financial instruments on own account and insider information Reporting obligation Insider information 4 7 Conflicts of interests and employees' personal finances 4 8 Outside activities 4 9 Gifts and corporate entertainment 5 10 Travel and various travel benefits 5 11 Use of IT systems and other resources in certain cases 5 12 Documentation 5 13 Confidence based on candour and honest marketing 6 14 An instructive organisation which provides extra security where necessary 6 15 Follow-up, reporting and training 6

3 1 Introduction The company's business operations shall be conducted in such a manner as to ensure that public confidence in the company is maintained and that the business is considered sound. This takes place, among other things, through the company conducting business operations in an ethically appropriate manner. This policy sets forth the board of directors' guidelines for handling the company's ethical questions. 2 General principles The company's business concept and vision clarify the fundamental ideas underlying the business. The board of directors has established the trademark values which the world at large should associate with the company. The work carried out with the company's employees regarding the company's values has entailed the establishment of a number of core values. These core values must permeate all of the company's work and, used correctly, should contribute to the achievement of the goals established for the business. The following core values have been established: Clarity Quality Totality Participation In all of their activities at the company, in the performance of other duties, and privately, the board of directors, the CEO, senior management, and the employees should conduct themselves in such a manner as to maintain confidence in the company. This also contributes to maintaining the confidence of the market on which the company operates. The company and the employees must comply with the laws and regulations which, in different ways, govern the business operations. In addition, the employees must comply with all internal policies, instructions, and other written policies. 3 Insulting behavior is never accepted The company's work environment policy and personnel policy clearly state that insulting behavior is not accepted at the workplace. It is important that this

4 fundamental view also characterises our relations with people around us, such as parties with whom we do business and our members. 4 Political neutrality The employees of the company must endeavour, in all of their activities, to treat all members and their representatives neutrally and equally, irrespective of their political views. 5 Transactions based on tax planning The company conducts socially beneficial operations for Swedish municipalities and county councils - operations which are primarily financed through taxes. The company may not participate in transactions where it is apparent from the circumstances that the planned transaction, or the use of a particular financial instrument, is largely made possible by, or has the primary purpose of providing to a customer or other party, a tax advantage, or which is intended to reduce the tax revenues of the municipalities and county councils. 6 Trading in financial instruments on own account and insider information Rules regarding trading in financial instruments on own account are intended to ensure public confidence in the company and its business operations. Rules regarding a notification obligation and prohibitions against short-term trading reduce the risk of suspicion of abuse of insider information. 6.1 Reporting obligation Directors and all employees of the company are covered by the reporting obligation and must annually report their holdings of financial instruments and changes in such holdings to the company. The CEO shall appoint a corporate officer to receive the notifications. Holdings, and changes in holdings, of financial instruments which consists of shares, depository receipts for shares, securities which entitle the holder to purchase shares or depository receipts for shares, fund units, financial derivative instruments regarding shares, or the equivalent, need not be reported unless the company specifically requests. There is also no reporting obligation regarding the purchase and sale of currency for the payment of financial instruments, goods, services or travel.

5 Financial instruments for which there is a reporting obligation may only be acquired where the intention is to hold the instrument for more than one month. Where, for special reasons, an employee must demand premature repayment prior to the expiration of the one-month period, the employee must consult with his or her immediate superior. Transactions involving financial instruments may not be carried out to such an extent as to jeopardise the employee s personal finances. 6.2 Insider information Insider information is information regarding a circumstance not published or generally known to the public which might materially affect the price of a financial instrument. It is prohibited to use insider information on behalf of oneself or a third party for trading on the securities market in order to acquire or sell financial instruments to which the information relates and to use insider information for the purpose (through advice or otherwise) of inducing any third person to purchase or sell financial instruments to which the information relates. This provision involves not only the use of insider information but also the unauthorised disclosure of such information, which also covers closely-related persons. 7 Conflicts of interests and employees' personal finances In order to ensure that the company s business matters are handled correctly, an employee may not handle matters in which he or she has a personal interest or questions regarding which a relative of the employee, or a company in which the employee or his or her relative has a significant interest, has a personal interest. 8 Outside activities Employees must contact their immediate superior in order to discuss the appropriateness of engaging in outside activities or work in other companies. An employee may not engage in activities which impede or affect the employee's performance of his or her work or which compete with the business operations conducted by the company. Planned outside activities or engagements must be reported to the head of human relations. The notifications received shall be set forth in a list which includes a notation of the company s position. The CEO shall determine whether an employee's outside activities or other engagements on behalf of other companies are compatible with the employee's

6 employment by the company. The CEO may delegate this task to another officer of the company. 9 Gifts and corporate entertainment An appendix to this policy contains an instruction regarding bribes and entertainment (appendix 1). 10 Travel and various travel benefits With respect to travel, hotel accommodations, etc., the company and the employee shall choose the alternatives which are appropriate and compatible with the company's position and reputation. Any bonus points earned during business travel and overnight stays are the property of the company and must be used for a business purpose whenever possible. 11 Use of IT systems and other resources in certain cases Greater use of IT systems and the Internet is essentially positive. Increased internal and remote communications and the exchange of information is important and desirable, both for our customers and for the company. The security aspects of IT use is governed, among other things, by the IT policy. The company's technical equipment, IT systems and other resources may not be used for association activities or other private purposes without the consent of the company. 12 Documentation The proper documentation of measures is a sign of good conduct. Proper documentation benefits both the company and its customers. Measures of significant importance, or of importance as a matter of principle, must therefore be logged/documented. If this is not done through a contract, the recording of telephone calls, or otherwise, the recording of notes from memory may be appropriate. This will make it easier later to clarify what has occurred. It is ethically acceptable to record conversations with customers.

7 13 Confidence based on candour and honest marketing Honesty and the greatest possible candour generate confidence. Within the scope of legislation, internal guidelines and executed agreements, the company must both internally and externally endeavour to achieve the greatest possible candour regarding the business activities of the organisation and its financial development. In its customer contacts, the company's representatives must act honestly and provide customers with objective and correct information. In all marketing and in the drafting of prospectuses and other documents, the company must ensure that the information is structured in such a way that the recipient obtains a correct and nuanced impression of the company and its financial products and services. 14 An instructive organisation which provides extra security where necessary The company endeavours to run an instructive organisation where all employees feel responsible for improving the business operations and protecting the company against errors and losses. Such an organisation requires openness, encourages suggestions for improvements, sees the possibilities in utilising error and anomaly reporting, and maintains established forms for regular reporting and the reporting of anomalies and risks. If an employee, for any reason, wishes to anonymously report a violation of internal or external rules to his or her superior, other corporate officer, or director, or to report to such person in a manner other than through the established routines, the employee's wishes should be satisfied to the extent possible. The CEO establishes the guidelines required for application by the company and is authorised to appoint a specific corporate officer to receive reports from employees. 15 Follow-up, reporting and training Compliance with this policy is monitored within the scope of the review carried out by the internal auditor. Reporting of important ethical questions is made to the board of directors. At least once each year the CEO, or a corporate officer appointed by the CEO, shall go through the ethics policy with all personnel and illustrate the application of the policy using practical examples.