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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.

 

Holmen's 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 control actions 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.

Handling information

Information about Holmen's operations must always be handled with caution. Certain type of information shall be deemed confidential. As a consequence of Holmen being a listed company, special regulations applies in respect of handling information that may affect the price of Holmen's share. 

Marketing

Employees must present Holmen’s products and services in a way that is correct 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. Specific routines and procedures shall be in place in order to handle conflicts of interest.

Handling of insider issues

Holmen has a committee for handling of insider issues (the ”Insider Committee”) that comprises of CEO, CFO and General Counsel.

 

Holmen shall inform the public as soon as possible regarding information of a precise nature which would be likely to have a significant effect on the price of Holmen’s share or financial instrument. The Insider Committee may decide to delay a public disclosure provided that certain conditions are satisfied. A delay of public disclosure implies that a situation with insider information arises. Holmen must then maintain a log book of the persons who have access to the insider information and inform these persons of what this entails.

 

The existence of information that potentially may have a significant effect on the price of Holmen’s share or financial instrument must be reported immediately to the Insider Committee.

 

Members of the board, the group management and the business areas managements as well as persons who participate in the production of financial information and/or press releases on a group level, may not execute any transactions in shares or financial instruments in Holmen during a period of 30 days before announcement of an interim report or year-end reports.

 

Holmen must maintain a list of all persons discharging managerial responsibilities in Holmen in accordance with the Market Abuse Regulation and persons closely associated with them. These persons must report their transactions in shares and financial instruments in Holmen to the Financial Supervisory Authority and to the Insider Committee.

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 breach of regulations regarding taxation and money laundering. Employees should be particularly observant to certain circumstances that should be regarded as warning signals for these non-permitted conducts.

International sanctions

Specific routines and procedures within appropriate units of Holmen shall continuously ensure that current international sanctions are complied with.

 

 

 

About the policy

It is the responsibility of each employee to be aware of and comply with Holmen's business ethics policy and its related 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 a superior manager or by using the whistleblower function which is available on Holmen's website and intranet.

 

Laws and rules always take precedence if they are stricter or if they conflict with the content of 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.  



The Holmen Group

Holmen is a forest industry group that manufactures printing paper, paperboard and sawn timber and runs forestry and energy production operations. The company’s extensive forest holdings and its high proportion of energy production are strategically important resources for its future growth.

Holmen AB

Tel: 08-666 21 00

E-post: info@holmen.com

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