Anti-corruption
Holmen does not tolerate any form of corruption. Employees may not give, promise, offer, request or receive compensation or benefits that conflict with applicable laws, good business practice or which may affect or be considered to affect the objectivity of decision-making. All issues regarding gifts, hospitality and other benefits must be dealt with openly, moderately and responsibly. The same principle shall apply to other people or companies acting on Holmen’s behalf, such as agents and other intermediaries
Competition
Employees may not be party to any form of agreements, contacts, associations or actions that aim at or result in preventing, restricting or distorting competition or that would be an abuse of a dominant position. Employees must manage contact with competitors and other business partners with care and in a way that ensures compliance with competition regulations.
Marketing
Employees must present Holmen’s products and services in a way that is accurate and fair.
All marketing should be designed responsibly and be carried out in accordance with applicable rules, good marketing practice and requirements under other legislation, such as rules on data protection (primarily GDPR).
Conflicts of interest
Employees must avoid contexts in which their own interests or those of relatives or friends may risk conflicting with what is best for Holmen. Private interests and external activities must not affect, or be considered to affect, the judgement or actions of employees when carrying out their work for Holmen. When the risk of a conflict of interest arises, the immediate supervisor must be informed and is responsible for taking appropriate action. If there is a conflict of interest, decisions in the matter on Holmen’s behalf shall as far as possible be made without involvement of the employee in question, and in no case be made by the employee in question alone.
Management of insider information issues
Since Holmen is a listed company, special rules apply regarding the management of information that has not been publicly disclosed and that, if publicly disclosed, would probably have a material effect on the price of Holmen’s shares or financial instruments (“insider information”). Individuals who have access to insider information may not themselves trade shares or financial instruments in Holmen, cause anyone else to conduct such trading or otherwise reveal insider information to anyone else.
Members of the Group’s Board, Group management and business area management, as well as individuals whose work involves the production of financial information and/or press releases at Group level, may not trade shares or financial instruments in Holmen for a period of 30 days prior to the publication of Holmen’s interim or year-end reports. This restriction also applies to closely associated persons and companies to the mentioned individuals.
Holmen has a committee for managing insider information issues (“Insider Information Committee”). All occurrences of potential insider information must be immediately reported to the Insider Information Committee.
Handling information
Information about Holmen’s operations must always be handled with sound judgement and caution. See Communication policy for further details regarding communication and public statements. Information that is business-critical, valuable, or sensitive for Holmen must be regarded as confidential and be kept classified. A non-disclosure agreement must be entered into when exchanging information with an external party and the external party’s requirements for non-disclosure shall be complied with. Information within research and development is often confidential and, in some cases, protection can be attained by way of patent or other intellectual rights registration.
Processing of personal data
Holmen’s processing of personal data shall be conducted with the protection of the personal integrity taken into consideration and in accordance with applicable legislation. The processing may only be conducted if there is a clearly stated purpose and legal basis for the processing. Holmen shall ensure that appropriate technical and organisational security measures are taken when personal data is being processed, that personal data are erased and that information regarding the processing is provided by the company to the data subjects. All processing of personal data shall be included in Holmen’s GDPR register.
Tax and money laundering
Holmen must comply with applicable laws and regulations regarding tax and anti-money laundering. Employees must not accept, support or facilitate any illegal or inappropriate methods to avoid tax (tax evasion) or measures aimed at conceling the origin of money (money laundering).
Circumstances that should be regarded as suspect include if the counterparty proposes that payments should be made in cash or to use an unusual currency or if the proposal for a business deal appears unjustified or overly complex. A special investigation must be conducted in all cases where the counterparty is reluctant to submit complete information.
International sanctions
Holmen shall ensure that no international sanctions decided by UN/EU or its member states, United Kingdom, any of the EEA states or US are violated. Before entering into new agreements or business relationships, and thereafter with internally decided regularity, it must be ensured that the counterparty is not subject to sanctions directly or indirectly, that contracted products or services are not subject to sanctions and that transactions are not carried out in territorial sanctions areas. Organization, tools and routines must be in place to ensure that applicable international sanctions are complied with.