Code of Conduct

 

This policy was adopted by the Board of HL Holding AB and HL Display AB and is applicable to all subsidiaries in the group as well as HL Partners. The policy shall be revised as required and reviewed at least once a year.

HL is a UN Global Compact signatory since 2010, and our Code of Conduct reflects the commitment we have towards the ten principles of the Global Compact. HL’s Code of Conduct outlines the minimum standards we require our employees to comply with. We adhere to the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. Any employee found to be in violation of this policy will be subject to disciplinary action, up to and including termination of employment.

We expect our suppliers to adhere to the same principles, which are described in Appendix F: Code of Conduct for Suppliers.

HL Display Group and HL Partners are hereinafter referred to collectively as “HL”.

 

1.  Human Rights

 

HL supports and respects the protection of internationally proclaimed human rights and makes sure that we are not complicit in human rights abuses.

 

2.  Labour Standards

 

2.1  Freedom of association

As local or relevant laws allow, all employees are free to form, join or not to join unions and have the right to collective bargaining when employed by HL.

 

2.2  Forced and compulsory labour

No form of forced or compulsory labour is tolerated by HL. This includes any form of forced, compulsory or illegal labour, including trafficking, prison labour, bonded labour or any other kind of exploitation or abuse. All employees have the right to leave their employment as stated by contracts or local laws.

 

2.3  Child slavery and child labour

We are not complicit in any form of child slavery, child labour or other forms of exploitation of children. No one is employed below the completion of compulsory school or under the age of 15 and no one under the age of 18 is employed for hazardous work within HL.

 

2.4  Workplace

HL shall provide a working environment that is healthy, safe and in accordance with the relevant ILO conventions and applicable local laws for all employees. HL makes every effort to pay fair salaries and remuneration in accordance with relevant norms in the locations in which the Group has operations.

 

2.5  Discrimination

Diversity amongst HL employees is a positive attribute and HL offers all individuals equal opportunities. No one shall be discriminated against – regardless of ethnicity, colour, gender, sexual orientation, nationality, parental status, marital status, pregnancy, religion, political opinion, ethnic background, social origin, social status, age, union membership or disability. Harassment in the form of physical or psychological abuse is strongly prohibited within HL, as is any kind of intimidation or other threats. Employees in HL have a joint responsibility for this to be achieved. The details related to this are set out in Appendix B: Policy for employee diversity, inclusiveness and equality.

 

2.6  Purchase of sexual services and child pornography

We believe that purchasing sexual services is unethical. It is also illegal in many countries. Therefore, we strictly prohibit our employees from purchasing sexual services while on work assignments or business travel, irrespective of the local laws, This applies both during and after working hours and is irrespective of country of the assignment / work travel.

Sexual exploitation of children and child pornography is not only illegal in many countries, but is a clear violation of human rights. Employees of HL are expected to comply with HL’s policy, irrespective of country and both during and after working hours. To support our policy in this area and protect against child sexual abuse material we have installed a software system called NetClean ProActive onto our servers.

 

3.  Environment

 

3.1  Precautionary approach

HL has a precautionary approach towards environmental challenges which means that we avoid dangerous materials when suitable and more environmentally friendly alternatives are available.

 

3.2  Environmental responsibility

HL will, wherever possible, work to reduce the environmental impact of the operations and contribute to long- term, sustainable development through active and systematic environmental work. The objectives related to this are set out in Appendix E: Policy for Environment and Sustainability.

 

4.  Anti-corruption

 

HL’s reputation of honesty, integrity and responsibility must be upheld and any involvement in bribery, extortion or corruption in any form is not tolerated by HL. HL makes active efforts to ensure that this does not occur within the company.

The term corruption refers to abuse of a position of trust for own or the company’s gain, for example through the use of bribes. It is forbidden to offer, promise, or give, as well as request, accept a promise of, or receive a bribe. A bribe is a gift or other benefit that might influence another person, as part of their employment or duties, to show improper favour to the giver.

HL’s employees may, for example, not offer, give, receive, or request gifts, services, entertainment, or other rewards that:

• Violate accepted business
• Have an unreasonable
• Consist of money, securities, cash loans, or other types of personal payments in the form of discounts, commissions, bonuses or fees.
• Consist of pure leisure or vacation
• Violate existing
• Are other rewards which due to their value or other relevant circumstances are typically likely to improperly influence the recipient in the exercise of their professional duties or in another manner risk embarrassing the company or the employee in the event they become public knowledge.

This does not prevent HL employees from receiving or offering promotional gifts designed to retain and promote good business relationships with customers and other business partners. This subject to the condition that such gifts are modest, openly accepted and offered and otherwise compliant with this Code of Conduct. Management of respective subsidiaries are responsible for preparing appropriate guidelines and routines for employees concerning representation and gifts.

 

4.1  Consumer interests

When dealing with customers and end-consumers, HL acts in accordance with fair business, marketing and advertising practices. HL also ensures that provided goods or services meet all agreed and legal standards.

 

4.2  Competition

HL conducts its activities according to applicable laws and regulations and refrains from concluding unlawful anti-competitive agreements as well as exchanging unlawful price and/or market information with competitors.

 

4.3  Export control

HL shall comply with all applicable rules regarding export controls, including not acting contrary to, or with persons implicated in economic sanctions.

 

4.4  Conflicts of interest

HL employees shall always work in the company’s best interest and avoid all acts that might be perceived as favouring a third party at HL’s expense. Employees shall avoid all types of activities that violate the company’s interest or have a negative effect on the employee’s possibility to act with judgment and integrity. Agreements with or other forms of assignments to related parties shall be avoided, and always be reported to and approved by the nearest manager or the company’s Group management.

HL employees may not spread or abuse confidential information. This principle may be waived if specific permission has been given by the immediate manager. Examples of confidential information include non public information about HL’s operations, financial position, strategies, business transactions, business plans, business processes, etc.

HL respects personal information and handles it carefully. HL respects individual personal information that the company can obtain or use in information processing and ensures that personal data in the operations is handled in accordance with applicable laws and regulations. Details are described in the HL Display Privacy Policy.

 

4.5  Relationships with external parties, such as suppliers and business partners

HL has a code of conduct for suppliers (see Appendix F), based on the same principles as the internal code of conduct, which all business partners must comply with.

 

4.6  Violations

HL will ensure that immediate action, such as termination of employment, is taken against those who violate this Code of Conduct and that circumstances in violation of applicable laws and regulations are reported to the relevant authorities.

Violations of the Code of Conduct shall be reported to the immediate manager. If such person is involved or otherwise disqualified, the reporting can be done with an e-mail to senior management, or if applicable, reported through HL’s third-party Whistleblowing service ‘Speak Up’ (see Appendix D: Policy for Whistleblowing).

 

5.  Implementation

 

New employees sign this Code of Conduct as an addendum to their employment contract and complete an online Code of Conduct module. We also require all employees to complete a short refresher module on Code of Conduct each year.

Managers are responsible for communicating a reminder of this policy annually, and Group HR will make sure the updated version is accessible on the intranet.

 

Do you have any questions?

If you have any questions about our Code of Conduct or other compliance-related topics, the Corporate Compliance Office is available to help. The contact details are:

E-Mail: compliance@werba-print.de

Dietmar Leppert

werba print & display GmbH
Am Froschbächle 23
77815 Bühl (Germany)
Compliance Office +49 7223 98 64 13

Date: February 2024