Code of Conduct
L E Lundbergföretagen AB's (Lundbergs) responsibility towards its shareholders is to develop and maintain a financially healthy and well-functioning company. This is achieved, among other things, by taking responsibility in the environments where we operate and towards our employees, business partners and society at large.
This code of conduct applies to Lundbergs and its wholly-owned subsidiaries. Lundbergs must also work to ensure that the code's approach permeates the companies in which we are an active owner.
All Lundberg employees and all board members must have good knowledge of the code of conduct and practice it in their daily work.
Our actions must always be well in line with the legal requirements that apply where our subsidiaries, associated companies and other holding companies operate, and it is a matter of course that both Lundberg's and our partners always comply with applicable laws and regulations.
We comply with applicable laws, regulations and international guidelines and principles in the field of environment, anti-corruption, labor law and human rights. We have committed to act in line with the UN Global Compact.
We are against all forms of corruption. Corruption means abusing one's power or position for personal gain. A common form of corruption is bribery. Corruption is not only illegal, it also has serious negative effects on society. All forms of corruption, including bribery, are strictly prohibited. We do not pay, offer, or accept bribes or other improper benefits, such as gifts or entertainment deemed lavish, to influence decisions or secure improper benefits. We do not work with suppliers, vendors or partners who offer bribes or are involved in corrupt activities.
Lundberg's employees must pay attention to situations where private interests conflict with Lundberg's legitimate interests. Lundbergs must be informed of such conflicts and avoided as much as possible.
Neither the name Lundbergs nor Lundbergs resources shall be used to promote the interests of political parties or persons running for positions in public administration.
Our time perspective is long-term. There is a strong connection between value creation and sustainability. Therefore, it is of great importance that investments are made with regard to its long-term economic, social and environmental impact.
Our relationships must be characterized by high business ethics. We take responsibility for our business and show consideration for all actors involved. Lundbergs shall not undertake assignments that are contrary to general legal opinion, or that may otherwise be considered unacceptable from a general point of view. Lundbergs must work for healthy competition and observe good marketing practice. Lundbergs maps risks regarding human rights in the value chain and works actively to counteract these.
Lundbergs does not accept that our business partners engage in activities that conflict with our code of conduct. Cooperation with business partners within the framework of an assignment must be characterized by correct business relationships, clear agreements and mutual respect.
Our workplace must be characterized by openness, responsiveness and mutual respect. We distance ourselves from all discrimination.
We strive for openness, clarity and reliability in our communication with the outside world as well as with our internal and external stakeholders. However, it is of utmost importance to never disclose confidential information.
Lundbergs employees must ensure that personal opinions and comments made privately or in social media are not perceived as Lundbergs positions.
If the code of conduct does not provide guidance, or if someone feels that it is not being followed, employees must consult with their immediate manager, secondarily with the company's CEO and thirdly with the chairman of the board. Board members must consult with the chairman of the board and secondarily, depending on the nature of the issue, with other members. It is also possible to make a report anonymously via https://www.lundbergforetagen.se/en/sustainability/whistleblowing where all reports are received and investigated by an external actor.
L E Lundbergföretagen AB (publ)
Board of Directors
Stockholm, May 30, 2024