1. Background, Purpose and Scope
The purpose of this policy is to describe how Elcoteq conducts business in an ethical way according to its values. This policy is applied to all Elcoteq's activities globally and it is communicated to Elcoteq's employees and stakeholders. Every Elcoteq employee is responsible for implementing this policy. The policy has been approved by Elcoteq's Board of Directors and it is introduced to Elcoteq employees through induction, training and internal communications. Stricter guidelines or more detailed instructions may be defined for certain regions, countries or functions, but they shall be in line with this corporate policy. If any of the requirements in this policy is in violation of the local law, the local law takes precedence.
2. Content
2.1 Ethics and the Law
Corporate Governance
Elcoteq's domicile is Finland, so the Corporate Governance is based on Finnish legislation. In addition to this, Elcoteq applies the guidelines for the administration of public limited companies. In December 2003, HEX Oyj, the Central Chamber of Commerce and the Confederation of Finnish Industry and Employers issued new recommendations on corporate governance of listed companies. The recommendation entered into force on July 1, 2004. Elcoteq complies with this recommendation as well as the insider guidelines issued by the Helsinki Stock Exchange.
The general meeting of shareholders is the supreme decision-making body in the company and the forum in which its shareholders exercise their voting rights. Shareholder meetings consider the matters stipulated in the Finnish legislation and the company's articles of association. Responsibility for the management of the company and appropriate organization of its operations lies with the Board of Directors. The Board is elected by the Annual General Meeting.
In addition to the tasks required by Finnish legislation and Elcoteq's articles of association, the Board is also responsible for confirming the company's strategy, for approving its annual budget, and for deciding on major investments and donations to good causes. The Board of Directors appoints the President and Chief Executive Officer who is responsible for the operative management of the company.
The Board of Directors has appointed Working, Review, Compensation and Nomination Committees from among its members to monitor the company's operations and to prepare matters for the consideration for the Board. The duties of these Committees have been stipulated in Charters approved by the Board.
Good Corporate Citizenship
Elcoteq takes care of the community under its influence and communicates openly with its stakeholders. Elcoteq recognizes its financial, social and environmental responsibilities as a global company and strives to promote positive development in communities where the company operates, while respecting local cultures and habits. We conduct business with integrity.
Human Rights
Elcoteq respects the principles of international human rights conventions such as the United Nations' Declaration of Human Rights and applicable ILO Conventions.
Conflicts of Interest
Elcoteq's employees shall avoid situations where giving or receiving a gift can lead to debt of gratitude beyond prudent business conduct. Family relationships must not affect the decision making to be adverse to Elcoteq. Persons married or in other close relationship are not recommended to be under each other's management.
2.2 Employees' Rights
Elcoteq complies with applicable local and international legislation in all its activities. As an employer Elcoteq acts responsibly aiming to fulfill the requirements of the international SA 8000 standard, which covers the following main topics:
Child Labor
Elcoteq complies with the UN and ILO Conventions on the rights of the child and does not engage in or support the use of child labor.
Forced Labor
Elcoteq does not engage in or support the use of forced labor.
Health and Safety
Elcoteq's occupational health and safety management is based on preventive actions. As an employer we provide our employees with a healthy and safe working environment according to applicable laws and regulations. We are also continuously improving occupational health and safety management and promoting the wellbeing of our personnel through co-operation between the company and employees. Elcoteq's units are locally responsible for health and safety management including the compliance with the applicable occupational health and safety laws and regulations. Where Elcoteq provides staff housing facilities, employees' safety is a priority concern. Elcoteq's health and safety instructions are applied to dormitories as well.
Freedom of Association and Right to Collective Bargaining
Elcoteq respects the right of all employees to form and join trade unions of their choice and collective bargaining according to local laws and regulations.
Discrimination
Elcoteq does not engage in or support discrimination based on race, caste, national origin, religion, disability, gender, sexual orientation, union membership, political affiliation or age. Elcoteq does not allow abusive, harassing or offensive behavior. This includes gestures, language and physical contact, that is sexually coercive, threatening, abusive or exploitative.
Disciplinary Practices
Elcoteq does not allow the use of corporal punishment, mental or physical coercion and verbal abuse.
Working Hours
Elcoteq complies with applicable laws, industry standards and applicable collective bargaining agreements on working hours and overtime compensation.
Remuneration
Elcoteq complies with applicable laws, industry standards and applicable collective bargaining agreements on wages. Deductions from wages for disciplinary purposes can only be made according to local legislation. Wages and benefits are paid in full compliance with applicable laws.
2.3 Environment
Elcoteq has a separate Environmental Policy.
2.4 Suppliers
Ethical and environmental considerations are included into Elcoteq's supplier system requirements. These are monitored by suppliers' quality audits. If the ethical performance of Elcoteq's supplier is questionable, the supplier will be audited and if non-conformities are found, the supplier is recommended to carry out corrective actions. If the corrective actions are not carried out in a reasonable time, Elcoteq will not continue to use the supplier as a part of the supply chain.
3. Monitoring
The implementation of this policy is monitored by internal and external audits as well as by annual employee survey. Questions about the application or meaning of this policy or potential violations are to be reported to superiors. In cases of serious violations, local Human Resource management, Security and line management closest to the issue will conduct the investigations. Acts inconsistent with this policy must be corrected and disciplinary actions can lead up to termination of employment. There will be no adverse work related consequences as a result of an employee reporting the violations of this policy.