Anti-corruption policy

Purpose

The purpose of this anti-corruption policy is to define the principles that apply within our Group in order to counteract corruption in all activities within the Group’s sphere of influence. All employees of Rototilt and its affiliates within the Group must comply with the rules contained in this policy. The content of this policy reflects the applicable provisions of Swedish legislation. The stated principles will also apply in other countries, however, although there must be some capacity for adaptation to the conditions applicable in each individual country. The rules in this document do not, of course, apply in the event they are superseded by the binding law of the respective country.

Key principles

• Rototilt must comply with all applicable laws in the individual countries in which Rototilt is active.
• The business must be characterised by a high degree of integrity and ethics.
• Rototilt does not accept the offering, request or acceptance of bribes of any kind, regardless of form, method or purpose.
• Rototilt does not accept so-called ‘facilitation payments’ intended to speed up the performance of routine actions by civil servants or other officials. 

Risk management

Risk analyses must be conducted in order to assess the risks of corruption when Rototilt and its affiliates operate in certain countries or deal with certain counterparties. All business partners must be scrutinised in accordance with ‘due diligence’. The scope of this scrutiny must be reasonable with regard to the risks identified by a thorough analysis of the information and the results of the risk analysis conducted.

Benefits and gifts

Within Rototilt, it is absolutely prohibited to give or receive benefits that constitute bribery and/or kickbacks. Every employee is obligated to take this prohibition into account in their contact with customers, suppliers or similar business contacts. Limited hospitality of a reasonable extent in the course of the performance of the role is, however, generally regarded as acceptable as part of creating business relationships. The following apply to benefits and gifts:

• Benefits may not be given or received where the purpose is, or is suspected of being, to influence the behaviour or decisions of the recipient.
• Any benefits given or received must, in objective terms, be moderate and transparent, as well as constituting a natural and useful element in the performance of the role.
• Benefits may never be given or received if they are associated with conditions relating to a particular course of action on the part of the recipient.
• Business contacts with persons with whom the employee has a personal friendly relationship must be avoided and/or carefully considered.
• Gifts may never be given to officials working for public authorities. With regard to gifts to other public sector employees, great restraint must be observed.

Meals and entertainment events

The purpose of meals and entertainment events must be to create and maintain good business relationships. These elements must be a natural and useful part of the role and primarily be used for work purposes, such as working lunches. In addition, the following applies:

• Invitations to dinners and entertainment events may only be made/accepted if they relate to a normal dinner and/or if the event is moderate in nature.
• Repeated invitations from/to the same person over short periods of time are to be avoided.
• In connection with business negotiations, dinners and entertainment events in addition to usual working meals are to be avoided.
• Considerable restraint must be observed with regard to invitations made to public sector employees.

Travel, study visits, training, conferences and promotional events

Travel, study visits, training, conferences and promotional events are permitted if they constitute a natural and useful part of the performance of the role. A fundamental precondition is that the content is serious and that there is a predetermined programme that is stated in the invitation. The scope for fun and leisure must be limited. For invitations in particular, the following applies:

• Invitations may never be sent to officials working for public authorities. Considerable restraint must be observed with regard to invitations made to public sector employees. 

Information and training

All employees of Rototilt and its affiliates within the Group must be informed of this policy. Recurring training must be provided for individuals in roles where the company’s employees are at particular risk, such as purchasing, distribution and marketing, as well as for people working in high-risk countries.

Monitoring, evaluation and review

All employees are obligated to comply with this policy. Every manager within Rototilt and its affiliates is responsible for ensuring that all employees receive full information about this policy. Compliance with this policy must be evaluated by Rototilt’s management on an annual basis. The content of this policy must be reviewed regularly in order to ensure that the rules remain fit for purpose as the business evolves or as other circumstances change.

Reporting corruption incidents

Employees within the Group must be free to raise concerns and to report violations of the policy without running the risk of reprisals. Reports must be submitted to the HR manager.