Code of Conduct

Preserving Secomea’s culture is vital to us and following this Code of Conduct helps us to do that, as we are all responsible for protecting each other and our reputation through our actions or omissions. We shall safeguard that we run and grow our business responsibly based on our values. We want to be a credible partner for our stakeholders and the communities in which we operate.

It is essential to Secomea that our employees and business partners meet the Code requirements, and it serves as a guide to our actions. This Code applies everywhere we operate. However, if local laws, standards, or regulations are stricter, you must always follow the stricter legislation. In some cases, there may be specific policies, instructions etc., which must be consulted.

The Code is intended for:

We expect the frame and minimum standards provided in this Code to be observed by:

• Employees and Management at Secomea
• Business Partners, which include Suppliers and Agents

Application of our Code

Secomea Business Partners, Employees and Management are all responsible for ethical behavior and integrity.

It is very important for Secomea that Business Partners, Employees, and Management comply with this Code.

Responsibilities of Employees

• Read, understand, and follow the Code.
• Be a role model and safeguard ethical behavior
• Report concerns about unethical/illegal behavior
• Cooperate on investigations of possible unethical/illegal behavior

Responsibilities of Management

• Comply with responsibilities of employees
• Lead by example
• Ensure that your employees are offered guidance in the event of concerns and information about unethical/illegal behavior.
• Enable a work environment that invites trust and open reporting to secure that all team members can share their worries.
• Identify and anticipate compliance risks that can affect Secomea
• Proactively identify initiatives and actions that can prevent compliance risks

Responsibilities of Business Partners

• Read, understand, and follow Secomea’s Code
• Report concerns about unethical/illegal behavior
•  Cooperate on investigations of possible unethical/illegal behavior
• Ensure that policies are made, and measures taken to comply with the principles of this Code
• Setting the same or comparable standards as in this Code for own business partners

Secomea’s responsibilities and values

Secomea is committed to conducting its business in accordance with applicable laws in all markets in which Secomea operates. We undertake to maintain ethical standards in everything we do. The Code is built on internationally recognized principles that promote human and labor rights, environmental, climate protection,  antidiscrimination, anti-corruption, and anti-bribery.

If one violates this Code, applicable laws, regulations and/or industry codes, Secomea will reconsider the business relationship and take appropriate action, which may result in termination of the relationship.

Secomea respects the following initiatives: the UN Global Compact 10 principles and the UN Guiding Principles on Business and Human Rights. We will contribute to the UN 17 Sustainable Development Goals.

This conduct and these principles are reflected in and shall be operationalized through our policies on Environmental, Social and Governance (ESG), Climate, Anti-corruption and bribery, Diversity and Inclusion, and Data Privacy responsibilities:

• Respect for People and Equal rights
• Health and safety at work
•  Caring for the climate and environment
• Business Ethics, Anti-corruption, and Anti-Money Laundering
• Protection of data and business secrets

Respect for People and Equal rights

Secomea is engaged in supporting the protection of internationally declared human and labor rights.

• Employment terms and conditions shall comply with applicable laws and ILO conventions.
• Equal opportunities for all employees, regardless of age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation or socio-economic status with the aim of fostering, cultivating and preserving a culture of diversity, equity and inclusion.
• Any kind of child labor is unacceptable. All legal limitations on the employment of children under the age of 18 years shall be followed. Children need to be protected from economic exploitation, and from performing any work that is likely to be hazardous or to interfere with the child’s education or be harmful to the child’s health or physical, mental, or social development.
• No forced, bonded, or involuntary prison labor is accepted.
• The freedom of association and the right to collective bargaining shall be respected
• Detecting, preventing and eliminating any negative impact on human rights with zero tolerance for discrimination, segregation and violence (sexual, psychological, physical, emotional, among others).
• Personal data and privacy shall be respected and the 7 principles of the GDPR must be followed.

Health and safety at work

Safety and health are integral parts of Secomea’s operations, and we aim to set high standards of protection.

When working with Secomea, you must always provide and maintain a healthy, hygienic and safe work environment for all employees and develop a proactive, collaborative attitude towards employee health and safety.

• Strive to maintain a fair and effective enforcement of a safe work environment to prevent illness and injury, both physically and psychologically, for all employees, guests, and contracted workers, and ensure that employees report injuries or ill health resulting from their work, and generally pay attention to safety.
• Develop a proactive, collaborative attitude towards employee health and safety
• All employees shall be educated in relevant health and safety, especially those engaged in hazardous work, including chemical, biological, and physical exposures.
• Facilities and equipment shall be constructed and maintained in accordance with at least the standards set by applicable laws.

Caring for the climate and environment

Environmental responsibility is important to Secomea.

Secomea supports and encourages operating practices and production systems that strive towards sustainability.

Business shall be conducted with due care for the impact on the globe and the environment. We are committed to reducing our carbon footprint throughout all our operations and our investments.

• Comply with all applicable laws, regulations, and international standards regarding environmental protection and must always aim to use natural resources sparingly and minimize damage to the environment.
• Set up or apply a sound environmental management system and take reasonable measures to reduce direct and indirect negative impacts on the environment and continuously improve them.

Business Ethics, Anti-corruption, and Anti-Money Laundering

Secomea is committed to ensuring that corruption and bribery does not take place anywhere in our value chain. Moreover, we wish to ensure that all business must be conducted responsibly. This includes ensuring that we and our business partners must adhere to all applicable laws, including regulations on anti-corruption and bribery in all relevant jurisdictions. We must continuously address corruption risks in all business relationships, in line with the OECD guidelines for Multinational Enterprises.

• All business shall be conducted in compliance with applicable legislation on fair competition and antitrust.
• Conflicts of interest shall be avoided whenever possible.
• Measures to counter money-laundering shall be taken.
• Secomea has zero tolerance for any form of corruption and bribery.
• No improper payments or other benefits can be offered or accepted.
• No personal gift, meals or entertainment can be offered or accepted to or from third parties unless such a gift is reasonable, modest, and appropriate under the circumstances.
• Ensure that none of Secomea’s business in any way supports war, conflict, terrorism, money laundering, drug trafficking or the slave trade. This includes the use of conflict minerals.

Protection of data and business secrets

Secomea always aims to protect confidential information and the personal information of others, just as Secomea will protect the privacy of others.

Secomea is responsible for personal data being processed in accordance with relevant laws, including the General Data Protection Regulation (GDPR).

• Not disclose or sell any confidential or personal information, including intellectual property, except in situations when authorized.
• Not use non-public information for financial or other personal gain.
• Not share “inside information” about a company with anyone who may then trade on the information.
• Comply with local laws governing the collection, use, and retention of personal information.

Compliance with the Code

Awareness of any activities in conflict with this Code shall be reported to Secomea with no delay. For Business Partners, please report through your contact person at Secomea. For employees, please consult with your manager. Secomea prohibits retaliation against workers who report in good faith.

Secomea reserves the right to perform audits or verify compliance with this Code at the premises of our agents and Business Partners.

Secomea reserves the right to demand corrective measures regarding activities in conflict with this Code. Moreover, Secomea reserves the right to terminate an agreement with any employee, agent or Business Partner who does not comply with the principles of this Code.