Holmen always expects its employees to act responsibly and ethically in the company’s operations. Here is information and guidance provided on how employees should act with regard to business ethics issues. The text corresponds to the major part of Holmen’s internal document “Business ethics policy”.


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.

There may be a risk of corruption when other people or companies act on Holmen's behalf. Employees must therefore carry out special checks and take precautions before and during cooperation with agents, representatives and other intermediaries.

Competition

Employees may not be party to any form of agreements, contacts or actions that aim at or result in preventing, restricting or distorting competition. Employees must manage contact with competitors 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 and good marketing practice.

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, the employee in question may not make decisions in the matter on Holmen's behalf.

Management of insider information

Since Holmen is a listed company, special rules apply regarding the management of information of a precise nature that has not been made public, which directly or indirectly concerns Holmen and which, if it was made public, would be likely to have a significant effect on the price of Holmen's share or financial instrument (insider information). Individuals who have access to insider information may not themselves trade shares or financial instruments in Holmen, nor may they cause anyone else to conduct such trading.

Holmen has a committee for managing insider information issues (Insider Information Committee), which comprises CEO, CFO and General Counsel. All occurrences of potential insider information must be immediately reported to the Insider Information Committee.

Holmen must inform the general public about insider information as soon as possible. Under certain conditions, the Insider Information Committee may decide to delay a public disclosure. In such cases, Holmen must maintain a log book of the individuals who have access to the insider information and inform such individuals of what this entails.

Members of the board, the group management and the business areas managements 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 (including the day the report is published). This restriction also applies to companies controlled by the mentioned individuals.

Holmen must maintain a list of all individuals who, according to the Market Abuse Regulation, hold a managerial position, and closely associated persons. These individuals must report their share and financial instrument transactions in Holmen to Finansinspektionen (Sweden's financial supervisory authority) and to Holmen.

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. Information within research and development is often confidential and in some cases, patent protection can be attained.

Tax and money laundering

Holmen must comply with applicable laws and regulations regarding tax and anti-money laundering measures. Employees must not accept, support or facilitate any breach of regulations regarding taxation and money laundering.

Circumstances that should be regarded as suspect include if the counterparty proposes that payments should be made in cash or using an unusual currency, if the proposal for a business deal appears unjustified or overly complex, or if a desire is expressed to involve countries that have no connection with the transaction. A special investigation must be conducted in all cases where the counterparty is reluctant to submit complete information.

International sanctions

Sanctions can restrict freedom of action for a state or some of its citizens. The sanctions may take the form of restrictions with regard to trading, financial transactions and travel. The marketing department of each business area and Strategic Purchasing are responsible for ensuring compliance with any international sanctions that are in place. Checks regarding current sanctions will also be included in the check list prior to entering into agreements with new customers and suppliers.

About the policy

It is the responsibility of each employee to be aware of and comply with the policy and its associated guidelines. In the event of any uncertainty as to how these are to be interpreted, Group Legal Affairs should be contacted.

Any suspicion of a breach regarding these matters should be reported to an immediate supervisor or by using the whistleblower function which is available on Holmen's intranet and external website.

Laws and regulations always take precedence if they are stricter or if they conflict with the content of a policy or guideline.

Implementation

All policy documents shall be clear and accessible. 

The business ethics policy together with related guidelines have been adopted by the Group management and is supported by the board. All business areas’ managements is given special information regarding the policy and the guidelines. Certain training on anti-corruption and other parts of the business ethics policy is held for specifically identified groups, for instance sales and purchase functions, that are considered being exposed to non-permitted conduct. 

Attitude, knowledge and handling in respect of these issues shall be of a high and even standard within the entire Group. Occurring issues and measures may vary but the principles shall be the same, regardless of where in the world or in what position you are employed. 

The efforts of the business ethics policy focus on increased risk awareness, both in general relating to each employer’s daily work and in particular related to specific businesses, changes and major decisions. Holmen’s efforts include identifying high risk areas based on different aspects such as geographical location, position and also the character of relevant processes. 

Ongoing work aims to clarify and optimize routines for follow-up and compliance of the policy documents.  



Holmen AB, P.O. Box 5407, SE-114 84 Stockholm, Sweden.

Visiting address: Strandvägen 1, Stockholm.

Tel: +46 8 666 21 00   E-mail: info@holmen.com

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