Code of conduct

LLENTAB shall actively work for safe and healthy working conditions, non-discriminatory conditions and shall continuously develop employees’ skills for increased job satisfaction and career development. Obligations towards employees under legislation and social protection agreements must be respected and complied with.

The rights of our employees and those working for our suppliers or business partners shall always be respected and we constantly strive to maintain high standards in terms of labour law and working conditions.

We shall always act ethically and respect human rights in accordance with the core conventions of the International Labour Organization (ILO). We support and respect the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles for Business on Human Rights, Labour, Environment and Anti-Corruption.

We do not tolerate any form of mental or physical punishment, threat of punishment, discrimination, bullying, harassment or abuse, and we shall provide decent working hours, wages and allowances, freedom of association and collective bargaining.

This means, among other things:

• It is the responsibility of all managers and employees to respect human rights. Consider how the activities, actions and decisions in your field of work can affect people. Work should be carried out so that any negative effects are minimized
• Anyone who discovers that human rights are being compromised in any way should report to their immediate supervisor or use the whistleblowing service

At LLENTAB we have zero tolerance for child labor, slave labor or other forms of forced labor and labor based on human trafficking in any form. This also applies to our suppliers and business partners.

A child (according to ILO Conventions Nos 138 and 182) is a person under the age of 18. A child between the ages of 15-18 may only be engaged to perform simple tasks if the child has completed compulsory schooling. The child must not participate in work that may have a negative impact on health or safety.

This means, among other things:

• Anyone who sees anything that indicates potential child labor, slave labor or human smuggling associated with LLENTAB’s operations, our suppliers’ or business partners’ operations, should contact the Group Management directly
• In cases where LLENTAB allows minors to carry out work, such as internships or school work, it must be ensured that national work environment regulations are followed and that the young person is not exposed to any risks regarding health and safety

At LLENTAB we shall contribute to a good balance between work and private life. We want a responsible approach to wages and allowances. Salary and other remuneration must at least comply with applicable agreements and generally accepted standards for the industry.

This means, among other things:

• LLENTAB’s employees should not have to work unhealthy amounts of overtime. National working time laws must be followed
• All employees shall receive clear and unambiguous information about their working conditions, including salary/remuneration and working hours

We are keen to have a constructive relationship with our employees. This also includes freedom of association and the right to collective bargaining. We strive for an open and transparent dialogue in order to directly involve our employees and, where applicable, their representatives.

This means, among other things:

• Employees are free to organize themselves in any employee organization as well as to refrain from such participation and activity
• Managers must not prohibit employees from exercising this freedom
• The dialogue between trade unions/employee representatives and management should be constructive and respectful
• The representatives of the employee organisation shall be given the opportunity to fulfil their duties

Discrimination has no place in our work environment. LLENTAB strives to promote diversity and equality in the workplace. Differences create dynamism and creativity, promote good decisions and better understanding of our customers. LLENTAB strives to be a company with employees who represent society in general.

No one shall be discriminated against on the basis of gender, age, religion, marital status, ethnicity, social background, illness, disability, pregnancy, ethnic origin, nationality, belief, membership in workers’ organisations, political affiliation or sexual orientation.

This means, among other things:

• Regardless of differences, position, age or other types of characteristics, all employees must be treated with respect
• All employment decisions made shall be free from discrimination
• Anyone who ends up in a situation where discrimination occurs must report to their immediate manager or other appropriate function within the company

Harassment can take the form of written or verbal comments, gossip, jokes, derogatory or offensive language or bullying where superiors abuse their position through insulting or threatening behaviour.

We have zero tolerance for harassment, bullying and victimisation. Sexual harassment and innuendo with sexual meaning must not occur. All employees must treat each other with respect and dignity.

This means, among other things:

• Never make derogatory comments or taunts about other people within the organization
• Don’t ask intrusive questions about anyone’s private life and don’t make unwelcome social or sexual invitations
• Do not abuse position towards subordinates
• Never send emails with inappropriate content to colleagues
• It is not allowed to display pornographic or racist images within the company’s premises
• Anyone who is subjected to victimisation or becomes aware of such discrimination should contact their immediate manager or other appropriate function at the company. The person investigating the matter must be impartial and have the confidence of those affected

At LLENTAB, we are well aware that our employees are the single most important factor in a successful business and we strive to maintain a long-term sustainable work environment where all employees can perform to the best of their ability.

The health and safety of our employees is a top priority when formulating and developing our work routines and when organizing our business. LLENTAB always strives to reduce or completely eliminate the number of occupational injuries and illnesses by continuously identifying and managing risks that may arise as a direct or indirect result of our operations.

Managers at all levels are directly responsible for taking steps to minimize potential negative impact on the individual.

This means, among other things:

• Responsible managers must ensure that their employees are familiar with LLENTAB’s routines and rules regarding health and safety
• All employees must follow the safety regulations at the workplace
• All managers and employees must contribute to a safe workplace for themselves and their colleagues and report when risks or events linked to health and safety are identified

LLENTAB strives to be perceived as an attractive and stimulating workplace for both women and men. We believe that power, influence and resources should be distributed equally between the genders in order to create fair conditions. We shall start from the basic principle of the equal value of women and men and we shall work to ensure that no one is subjected to degrading behaviour because of their gender.

This means, among other things:

• Women and men shall have equal opportunities for employment, training, promotion and development in their work
• Women and men should have equal pay for work of equal value
• Both women and men should be able to combine their work with parenthood

Alcohol and drugs increase the risk of accidents, health problems, loss of valuable labour, costs related to loss of production and quality deficiencies and we therefore do not tolerate the use of alcohol and drugs in connection with work. This is developed in our alcohol and drugs policy, which all employees must take part in.

A basic requirement is that we respect and comply with national and international legislation, competition rules, agreements and safety requirements and other regulations that set the framework for our business. LLENTAB shall protect the owners’ investments and strive for a sustainable and improved return. The company shall keep its owners well informed about strategies, business operations and results.

At LLENTAB we believe in a fair and competitive market. We do not carry out any activities that are illegal under applicable competition laws and all employees are expected to strictly comply with the laws and regulations that apply.

LLENTAB does not allow any form of price cooperation and we support correct and comprehensive competition in all parts of the business in tenders, quotations, procurement and purchasing.

This means, among other things:

• We never enter into any agreements with competitors regarding prices, trading conditions, production, technology development, market sharing or other marketing activities
• We never discuss pricing, profits, costs, offers, customers, market development, technology development or other non-public sensitive information with competitors

Corruption is the abuse of a position of power for personal gain. LLENTAB does not tolerate corruption, bribery or extortion in any form. This applies to all businesses and transactions in all countries in which we operate. Neither LLENTAB nor anyone representing the company may engage in or in any way consent to corruption.

LLENTAB can make donations to non-commercial non-profit organizations or to charity. Donations must be decided by the respective country’s CEO and they must not be linked to past, present or future business transactions.

This means, among other things:

• We act and make decisions without regard to personal gain
• In case of suspicion of irregularities linked to corruption, the employee must inform their manager without delay or use the whistleblower system

LLENTAB’s employees may not engage in activities that can lead to conflicts of interest or exploit relationships with business partners for their own gain. Employees shall avoid conflicts of interest between private financial matters and the company’s operations. This includes giving or receiving personal gifts or services beyond what is normal business and accepted in LLENTAB’s guidelines for hospitality and benefits. It also includes not soliciting or making any kind of promises in connection with gifts.

Employees may not perform work or indirectly conduct economic activities for organizations that compete with, or do business with, LLENTAB. All business transactions should be handled properly according to the company’s rules.

This means, among other things:

• All employees must inform their manager about any business activities conducted outside LLENTAB
• Anyone who discovers misconduct or unethical behavior must inform their manager or other appropriate function within the company
• If any of LLENTAB’s business partners repeatedly and/or seriously violate our guidelines, the cooperation will be terminated

We shall not deal, directly or indirectly, with any person or entity listed as inadmissible on sanction lists. It is not allowed to do business with countries or regions that are subject to sanctions.

This means, among other things:

• Anyone who trades with an external party on behalf of LLENTAB must have knowledge of the company’s owner (payment receipt) with whom we do the business
• If it is suspected that an external party may be on a sanctions list or may have an associated company in a country subject to sanctions, the immediate manager or other appropriate function of the company should be contacted

LLENTAB remains neutral with regard to political parties and candidates. Neither LLENTAB’s name nor resources controlled by the Group may be used to promote individual political parties or candidates.

Employees who engage in dialogue with public authorities and other public bodies to inform or influence public policy must do so in a responsible and transparent manner in accordance with applicable legislation.

This means, among other things:

• Employees may participate in political activities and contribute to political parties privately, but only in their spare time and for their own money
• Employees may not make political contributions or expenses for such purposes on behalf of LLENTAB
• Anyone who engages in political activity in private may not do this, or pretend to do so, as a representative of LLENTAB

LLENTAB complies with statutory requirements and quality and safety standards in the design, manufacture, marketing and sale of our products. Delivery of products to customers shall not take place until quality, safety and regulatory requirements have been met.

This means, among other things:

• We act professionally and competently to meet agreed requirements and expectations
• We plan well and deliver according to promises and agreements
• We do not undertake projects we are not sure will meet the conditions under which they will operate
• We support the development of our employees so that everyone knows what requirements are set and can be responsible for ensuring that the execution is right
• We monitor and improve our business system for quality work
• We work with products and services from selected suppliers and follow up the cooperation with them
• We work continuously to improve the business and correct the errors and deficiencies that arise, take preventive measures and share lessons learned from this within the Group.
• We clarify and comply with contract requirements and applicable laws, regulations and standards for the design and manufacture of steel products and steel buildings

LLENTAB strives for a transparent business climate and a high level of business ethics. Our employees have a key role in identifying any irregularities that need to be corrected.

To alert us to serious risks, which may harm individuals, our organisation, society or the environment, we use a whistleblowing service that is available to employees and external parties on our website. The guidelines for the whistleblowing service comply with the General Data Protection Regulation, GDPR.

The service is important for reducing risks and maintaining confidence in our operations, as we can detect and remedy suspected irregularities at an early stage.

This means, among other things:

• Anyone who suspects serious irregularities affecting the company’s vital interests, such as accounting, auditing, corruption, danger to life and health, serious environmental crimes, major deficiencies in security or serious forms of discrimination or harassment, can report via LLENTAB’s website via our whistleblower service
• A whistleblower who expresses a genuine suspicion or concern under these guidelines is not at risk of retaliation as a result of their report
• Whistleblowing messages can be reported openly or anonymously and anyone who has chosen to remain anonymous is guaranteed that no one will try to identify the whistleblower
• To ensure independence and confidentiality, all reports are received by an external actor who reviews the report and forwards the case to appointed case managers at LLENTAB

It is central to our business that we protect our assets, including real estate, intellectual property and financial resources. We are all responsible for protecting our assets and using them carefully and efficiently.

We do not tolerate fraud and misuse of company assets. Fraud refers to any act, including failure to act, with the aim of misleading others (e.g. the company, the public or investors) into taking actions that would cause them to suffer financial harm.

Property, equipment, resources and financial resources may only be used for the purposes of our business and not for personal gain.

Examples of asset misuse include theft, falsification of expense or time sheets, as well as inappropriate use of company computers, phones or facilities.

This means, among other things:

• Employees shall comply with all applicable local travel and expense regulations
• Private expenses may not be reported as business expenses
• The Company’s computers may not be used for illegal activity or to display inappropriate material, including pornography sites, hate sites or other sites that may damage the Company’s reputation

In order to maintain the trust of our customers, suppliers and other stakeholders, the accuracy and integrity of our financial reporting are fundamental. All financial transactions must be recognised and accounted for in accordance with applicable accounting policies.

It is not permitted to enter information in our accounts or records that is deliberately misleading or conceals the true nature of the transaction or to provide misleading information in order to influence goals or key figures. It is forbidden to manipulate or change accounting rules in order to achieve financial goals.

This means, among other things:

• The submitter is responsible for ensuring that it is correct and that the information provided accurately reflects the underlying transaction when reporting
• Anyone who discovers an error in an accounting entry, or suspects that fraud has been committed, must report this to their immediate supervisor immediately

LLENTAB’s intellectual property rights, e.g. ideas, trade secrets, domain names and designs, are valuable assets for the company. Such values may be lost or jeopardised if these assets are misused or improperly disclosed.

This means, among other things:

• Anyone who suspects that a third party has infringed, or appears to have infringed, our intellectual property rights should immediately inform their immediate supervisor
• The intellectual property rights of others must be respected
• Intellectual property rights developed during your employment remain LLENTAB’s property even after you have terminated your employment

We encourage employees to communicate LLENTAB’s brand and our products and services, but it is not allowed to leak or disclose trade secrets and other confidential information to third parties.

Information about LLENTAB is a valuable asset. Employees may have access to confidential information such as financial information, trade secrets, prices, sales figures, profits, strategies, contract information, customer and supplier lists or other non-public information about LLENTAB.

Confidential information about LLENTAB must be protected, handled carefully and may not be disclosed to unauthorized persons or made public unless specifically authorized to do so. The obligation to protect confidential information continues after termination of employment. This also applies to information that customers, suppliers and other business partners have shared with us.

This means, among other things:

• Be careful not to post confidential information on social media or discuss confidential or sensitive information in places where others can hear your conversation
• If it is necessary to share confidential information with third parties, make sure that a confidentiality agreement has been concluded
• Keep in mind that you may be required to protect confidential information even after you have left the company. This also means that new employees must not share a former employer’s confidential information, nor should they ever be asked to disclose such information
• Use only equipment and services approved by the company when handling LLENTAB’s information
• Use your LLENTAB email account or other company channels for all work-related communications. Do not use private email accounts, social media or similar

What we plan and implement must be responsibly and long-term designed with a focus on environmental, economic and social aspects. All employees have a role to play in continuously improving and further developing our environmental work.

The sustainability perspective must be included in everything we do to minimize the impact on the environment in our processes to ensure that we contribute to the society in which we operate.

LLENTAB will, through better environmental choices, build climate-smart steel buildings and thereby contribute to energy and resource efficiency throughout the building’s life cycle.

With a focus on reduced energy consumption, optimized transports and ensuring that waste management takes place in a safe and environmentally adapted way, we will work to reduce climate impact.

In its commitments, LLENTAB strives to create optimal conditions for minimizing climate and environmental impact, as well as contributing to energy and resource efficiency in the projects we participate in. LLENTAB stives to offer building materials with good sustainability properties from a life cycle perspective and to phase out harmful substances in the products we use. When possible, renewable energy sources shall be used in our facilities and processes. Biodiversity, land use, deforestation and water use shall also be taken into account in the production and purchasing phase.

By producing environmental product declarations, EPDs, for our manufactured materials and by requiring our suppliers to provide us with the same basis for purchased materials and products, we can measure our carbon dioxide emissions for the products. We also monitor our climate footprint on an annual basis based on, among other things, electricity, heat, fuel, water, forest raw material consumption, as well as passenger transport, material transport, waste volumes and machine use. Based on this follow-up, we establish objectives and action plans to reduce our greenhouse gas emissions.

In our everyday lives, we will do everything to reduce the waste of natural resources and take care of the waste that arises in the best possible way. The emphasis is on improving resource efficiency, i.e. preventing the generation of waste and achieving increased sorting rates.

On our construction sites and in our projects, we will work to become even better at reducing energy consumption, sorting construction waste at source and making good environmental choices when renting equipment and purchasing materials.

The chemicals purchased must be assessed from an environmental and health perspective before use and must be accompanied by related documentation such as Safety Data Sheets. The user must be informed about the risks associated with the chemical and have access to the right protective equipment if necessary. LLENTAB has internal rules regarding responsible handling of chemicals that comply with applicable legislation and procedures for how we should act in the event of spills or other environmental impact from chemicals used in the business.

This means, among other things:

• Strive to create healthy environments where production and products do not affect people and nature in a negative way
• Manage and document our environmental impact carefully and in accordance with legal requirements
• Use chemicals and other consumables that minimize the risk of harm to humans or the environment
• Work to, in all our operations, reduce carbon emissions, reduce energy consumption, and choose sustainable energy sources
• Ensure that applicable environmental permits are in place
• Make active product choices and reduce the use of harmful substances and materials and purchase building materials with good environmental performance
• Use resources such as energy, water, chemicals and materials in a sustainable way
• Minimize travel by using web or phone meetings if possible
• Ensure that waste management is carried out safely and contributes as far as possible to recycling, reuse and resource efficiency