Page 9 - Code of conduct

We act with integrity and high ethics in that restrict competition. This includes price-fixing,
the dividing of customers and geographical mar-
all of our business relationships. kets, cartels and abuse of dominant position.

• You shall always act in the best interest of
Indutrade and each of our subsidiaries have many different business relationships with vendors, custom- Indutrade and your company, and avoid conflicts
ers, acquisition candidates and shareholders. To be able to grow and develop, we must maintain high confi- of interest. A conflict of interest arises when your
dence among our most important stakeholders and people in our operating environment, and be a trusted private interests, personal relationships or external
partner. There are no shortcuts here – we must do the right thing in all situations. activities affect or give the impression of affecting
how you perform your work duties.

• Inside information is non-public information of a
• We must follow applicable laws and regulations in • No one who works under Indutrade’s name or any
all countries in which we work. If the provisions of of the subsidiaries’ names may grant, offer, precise nature, relating to Indutrade, and which, if
this Code of Conduct demand higher standards receive, request, promise, or promote payments, made public, would be likely to have a significant
than those required by national laws, this Code gifts or other improper benefits that could influ- effect on the price of financial instruments issued
shall be complied with. ence or may be perceived to influence the objec- by Indutrade. If you have inside information about
tivity of a business or governmental decision. Indutrade you may not buy or sell Indutrade instru-
• All forms of corrupt conduct are strictly forbidden. ments. Nor may you disclose such information to
Corruption is defined as “the abuse of entrusted • You may only offer or receive gifts, meals, enter- any third party, for example friends and family, by
power for private gain” and extends to both tainment, and other forms of hospitality, if they for example recommending them to buy Indutrade
financial and non-financial gains. Corrupt conduct are compatible with applicable laws and generally instruments.
includes bribery, receipt of improper gifts and accepted business practice. If you are not sure,
entertainment, facilitation and protection pay- consult with your immediate manager. • We shall always strive to ensure that Indutrade’s
ments, extortion, money laundering, and information is open, correct, continuous, fast and
nepotism. • No one who works under Indutrade’s name or any of the best quality, and that it is provided in accor-
of the subsidiaries’ names shall make political con- dance with applicable laws, regulations, account-
• Corruption risks associated with our operations tributions, charitable donations and sponsorships ing standards and norms. For further information,
shall be assessed when entering into business in expectation of receiving any advantages. please see Indutrade’s insider Policy and
relationships, paying attention to factors such as guidelines.
business partner identity, risk environments such • All success shall be built upon a sound business
as high risk geographical regions, and the type of culture and fair competition. We always adhere to
business we engage in. When necessary, risk applicable competition laws that prohibit agree-
assessment shall be documented. ments and arrangements between competitors

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