Code of Conduct
Absolent Air Care Group’s vision is to provide clean air for people, planet, and life. To obtain our vision, it’s crucial that everyone in our organization show responsibility in every aspect of their work; financially, socially, andethically.
Within Absolent Air Care Group we work with sustainability at heart by protecting people and planet, development, culture of caring and challenging the system. We have a strong platform consisting of values, policies, business ethics, environmental care, and corporate governance.
This Code of Conduct shall apply to all employees in the organization. It is the responsibility of each employee to comply with laws and regulations and our Code of Conduct.
Thank you for your commitment and loyalty to the Group. If there is something you do not understand or if you need additional information, please feel free to contact Absolent Air Care Group or your closest manager.
Yours faithfully,
Axel Berntsson, President and CEO
Absolent Air Care Group AB
2022-04-01
1. General rules of Conduct
Absolent Air Care Group responsibility is extending in those societies where we are active as well as
to our employees, business partners and to the society in general. Rules regarding how we should act
on the market:
• We operate our business with the highest moral and integrity
• We comply with laws and regulations of each country in which we cooperate
• We respect the United Nations Guiding Principles on Business and Human Rights and accept our responsibility to comply with the rights that concerns our actions towards our employees and those societies where we are active.
• We integrate the principles of this policy into critical processes in our business operation
Absolent Air Care Group value social responsibility and ethical behavior throughout the organization.
Absolent Air Care Group and its employees have an obligation to all stakeholders to observe high standards of integrity and fair dealing. Stakeholders include customers and end-users, owners and
investors, employees, partners and suppliers, governments and authorities and local communities. If you are unsure how to act in certain situation, a guiding principle is to ask yourself the following:
• Is this against the law?
• Would this be considered unethical?
• Could this potentially jeopardize and/or damage Absolents reputation?
• Would it be embarrassing if I read about this in the media?
Managers’ responsibility
The overall responsibility for this Code and the implementation hereof lies with the President and CEO of Absolent Air Care Group. Direct manager will follow up and monitor the implementation of this Code. People with a leading position at Absolent Air Care Group have additional responsibilities to commit to the code. Managers should communicate, lead by example, and encourage and give basis to all employees act ethically and in compliance with the Code.
All managers have the responsibility to communicate and distribute relevant parts of the Code, as described below, to employees and to handle any concerns or complaints. Managers are responsible for ensuring that employees are provided with, and updated regarding, relevant parts of the Code. This document is presented to all employees in the organization and can never replace national legislation that in many cases is much more specific. The nature of this Code of Conduct is not meant to cover all possible situations that may occur. All sites and business areas within Absolent Air Care Group are responsible for being updated about their specific legislative requirements.
Implementation
The implementation of this code is conducted in the onboarding process of every employee, but it is also every employee’s personal responsibility to ensure that their activities comply with this Code. Should a situation occur where no specific guidelines exist, their conduct should be compliant in accordance with this Code.
Compliance
In case of failure to comply with this Code the result can end in disciplinary actions, including dismissal. Every employee should feel encouraged and safe to inform the local senior management if they have reason to suspect that laws, legal requirements, or this Code are being materially violated. The confidentiality and anonymity will be respected.
2. Responsibility in the workplace
Health and safety of employees
Absolent Air Care Group respect all employees and their rights, offer safe and good working conditions without discrimination, and consciously develop the skills and competencies to ensure the
satisfaction and personal development of the individual. We respect and comply with local regulations regarding terms of employment, as well as the right to form associations and collective bargain.
Working environment, human development, and recruitment
Absolent Air Care Group complies with local laws and regulations regarding workers’ contracts. Salaries should be paid regularly and comply with the applicable local legislation and the local market situation. Employees are entitled to a minimum of one day off in seven and to take time off for established national and local holidays, all in accordance with national law. Employees should be granted the stipulated annual leave, sick leave, and maternity/ paternity leave without any negative repercussions. Absolent Air Care Group provides a working environment where everybody is treated with respect and dignity and is given fair and equal opportunities for personal development regardless of gender, age, race, religion, sexual orientation, or national origin. No form of discrimination or harassment in the workplace is tolerated. Recruitment and promotion of employees is based on a match between assessed job requirements
and applicants’ qualifications and experience.
Alcohol, drug abuse and/or gambling
Absolent Air Care Group expects all employees to attend work with an unimpaired judgment and therefore to refrain from any alcohol, drug abuse and/or gambling that may affect their work.
Employee privacy We at Absolent Air Care Group handle personal information under strict confidentiality and in accordance with EU’s General Data Protection Regulation (“GDPR”) and local legislation.
Prohibition of child labor
Absolent Air Care Group does not employ children and does not accept child labor in the supply chain. Absolent Air Care Group recognizes the rights of every child to be protected from economic
exploitation and from doing work that is likely to be hazardous to the physical or mental health, harmful to the moral or social development, or interfere with the child’s education. A child in this context is a person younger than 15 years of age, or 14 years of age in accordance with the exceptions for developing countries as set out in the ILO Convention No. 138 on Minimum Age. If relevant national legislation has set a higher age, this age will apply.
3. Responsibility towards business partners
Fair business dealing
Employees behave in accordance with high business ethics and act in compliance with antitrust, competition and fair dealing laws. Especially, employees involved in sales, marketing and purchasing functions are familiar with applicable competition laws. Absolent Air Care Group respects the laws and regulations in the countries in which it operates and requires that its suppliers and partners do the same. Employees shall follow all relevant laws and regulations and adhere to internal Absolent Air Care Group rules, including this Code that may go beyond what is required by law. Should any requirement in this Code violate applicable law, the law takes precedence.
Fair competition and antitrust legislation
Absolent Air Care Group is committed to competition that is based on the added value of its products and services. We do not engage in unfair, misleading, or inaccurate comparisons, anti-competitive agreements or arrangements and does not tolerate bribes or extortion, neither as a payer, initiator nor as a receiver. Absolent Air Care Group is a global Group with companies around the world. The antitrust and competition laws are complicated and technical and vary from country to country. The Code identifies specific activities prohibited by the antitrust laws of many countries.
Relation with our partners, suppliers, and stakeholders
All employees are expected to ensure that our business complies with the Code and to make sure that our business partners, suppliers, and consultants are duly informed of its contents. We prefer to corporate with suppliers, distributors, agents and consultants and other business partners that share the same view on the principles expressed in this Code of Conduct. Should a supplier fail to comply with Absolent Air Care Group’s Code of Conduct, we will through cooperation try to resolve the situation or terminate the relationship. Absolent Air Care Group is interested in any input from its stakeholders and always tries to answer questions and to participate in relevant surveys and studies.
Communication
Absolent Air Care Group practices open and honest communication to all stakeholders apart from information that is regarded as commercial confidential information, unless such commercial
confidential information is required to be disclosed pursuant to applicable disclosure regulations. Advertising, marketing, and labelling is always truthful and clear.
4. Responsibility towards society and environment
Absolent Air Care Group has a zero-tolerance for any types of bribes, fraud, facilitation payments or other improper benefits contrary to this policy, local laws and regulations, industry standards or ethical codes in the countries in which we operate.
For further information, employees should refer to Absolents Anti-Bribery & Anti-Corruption Policy. In addition, local laws and regulations should always be followed. In the unlikely event of a conflict between the local law and this policy, the law shall take precedence, and the conflict must be reported to Absolent Air Care Group.
Political contributions
Absolent Air Care Group is politically neutral and does not pay political contributions to obtain a business advantage. Individual participation in politics must not involve the use of Absolent Air Care Group’s funds, time, equipment, supplies, facilities, brand, or name.
Trade sanctions and export controls
Absolent Air Care Group is committed to conducting business in accordance with applicable trade sanctions laws and export control regulations which Absolent Air Care Group believes are important tools in the international community’s striven to inter alia improve human rights. Absolent Air Care Group will not tolerate any violation of trade sanctions laws, export controls laws or related regulations by its employees. This means that Absolent Air Care Group will not engage, directly or indirectly, in any business, dealing, or transaction prohibited by applicable trade sanctions or export control regulations. Furthermore, Absolent Air Care Group and its employees will not carry out any direct or indirect business activities with any person, entity or government targeted by trade sanctions, nor export goods or services subject to applicable export control laws without required licenses and/or approvals from the relevant authorities.
Environmental protection
Absolent Air Care Group work with sustainability at heart by providing clean air for people, planet, and life. We have responsibility for the environmental compatibility and sustainability of our
products and services and it is crucial that that everyone in our organization show responsibility in every aspect of their work. The business is based on our employees having access to the information they need for developing products and solutions for efficiently cleaning process air with the minimum reasonable negative impact on the climate. Research and development are a central part of Absolent Air Care Group’s operations and is conducted in-house to develop energy and materialefficient products that meet our customer’s needs.
Government investigations
Absolent Air Care Group cooperates with any appropriate government investigation. If a governmental demand in this respect is put forward, the immediate manager must be informed before any action is taken or commitment is made. Documents must never be destroyed or altered in anticipation of a government investigation, and misleading or untrue statements to government investigators must not be made. This is true even when a governmental investigation or proceeding has not yet begun or been announced, and it is also true even when such an investigation or proceeding simply appears to be a possibility. No coercion or pressure must be put on employees to compromise this policy.
Conflict of interests
Employees must avoid private activities, financials interests or relations that might lead to a conflict of interests with the interests of Absolent Air Care Group. If a conflict occurs or can be foreseen, the employee is required to discuss and solve the matter with his/her immediate manager.
Community outreach
Absolent Air Care Group acts as a good corporate citizen wherever it operates and supports local,
regional and global communities in appropriate ways.
5. Responsibilities towards shareholders
Public information and confidential information
Any information that is not public property or public knowledge should be considered confidential information. Examples are trade and business secrets and personnel information. Confidential information is protected and is not disclosed unless required by law or authorized by management. Necessary steps to avoid unintentional disclosure of confidential information are taken, which include storing and transmission of such information in a safe manner. Confidential information received from third parties is handled with similar respect.
Insider trading
Absolent Air Care Group protects insider information and refrain from insider training. This Code of Conduct was adopted for the purpose of maintaining a high ethical level and legal compliance within Absolent and to secure a good reputation within the public and the capital markets. It is always the responsibility of the individual insider to make any required notice of changes in his or
her holding of shares or other financial instruments in Absolent Air Care Group and to comply with the relevant applicable laws and regulations. Any violation of insider trading laws is a serious crime and may result in criminal liability.
Records and reports
The integrity of Absolent Air Care Group record keeping, and reporting systems is of outmost importance.
Employees must use special care to make sure that records are accurately and completely prepared and reviewed, whether they are for internal or external use.
Employees must apply accounting rules and controls and follow company procedures for retaining
and disposing of records.
6. Reporting violations
All employees and affected parties are required to report any practices or actions believed to be improper behaviour or actions that is not in compliance with this Code of Conduct to your local
Managing Director alternatively to Absolent Air Care Group using any of the following ways:
Axel Berntsson, President & CEO
Absolent Air Care Group AB
Att: CEO
V Hamngatan 10
411 17 Göteborg, Sweden
Phone: +46(0)510-484000
E-mail: whistleblowing@absolentgroup.com