Code of Conduct

OUR ETHICAL PRINCIPLES

WE ACT TRANSPARENTLY

We always comply with the law, the agreements we have made and the collective agreement in the industry. We do not tolerate corruption, bribery, money laundering or other unethical practices and we promote competition. Each of us knows and is committed to complying with the laws, regulations, agreements and guidelines that apply to our work.

We practice transparent and responsible business practices. Our finances, reporting and accounting are truthful and the choices we make stand up to open scrutiny. We comply with the applicable procurement policy in all our purchases.

We make decisions in the best interests of Niemi and do not allow our personal interests to influence our decisions. We will recuse ourselves in the event of a conflict of interest.

We will not accept or give bribes, or otherwise seek to influence decision-making unethically. We accept and give gifts and hospitality with discretion.

Our sponsorship and charitable activities are in line with our strategy and good business practice. We do not sponsor government, political or religious bodies. Our marketing is always factual and does not contain misleading information. We communicate our activities transparently to our employees and stakeholders.

WE TREAT EVERYONE WITH RESPECT

We treat our customers, colleagues, suppliers, partners and all our stakeholders with respect and equality, regardless of gender, race, religion, origin or any other personal characteristic.

We do not tolerate discrimination or bullying and we reflect this throughout our value chain. We do not tolerate offensive or inappropriate behaviour from our customers, suppliers, partners or other stakeholders.

We promote diversity, equality and inclusion in our workplace. We recognise that we operate in a traditional male-dominated industry with a Finnish background and are committed to increasing diversity in the industry.

We encourage the expression of diverse views, which we believe enrich our organisation and contribute to our success. We regularly monitor the development of our working philosophy through surveys and use this to develop our activities together.

We actively address concerns raised through our surveys and reporting channels.

WE PROMOTE HEALTH AND SAFETY

Safety at work is everyone’s business. We make sure that we can do our work safely, both in the field and in the office. We get familiarised and trained to work in a healthy, safe and responsible way. We make sure our qualifications are up to date.

We comply with the safety regulations and use appropriate protective equipment and pay attention to work ergonomics. We never come to work or work under the influence of alcohol or other intoxicants.

We monitor our accident frequency and actively develop our activities with our health and safety committee. We actively observe our working environment and systematically carry out safety observations to prevent accidents.

We all have a duty to report any safety risk and to take care of our own safety and that of others. We have the right to refrain from working until it is safe to do so again.

We also understand the psychological strain of our work and take care of our Niemi family. We know how to ask for help in time and we know that we will always be helped.

WE CARE FOR THE ENVIRONMENT

Environmental responsibility is at the heart of our strategy. We take our responsibility in preventing climate change and protecting biodiversity. We minimise our environmental impact in all our activities and continuously improve our performance.

We have set ourselves ambitious environmental targets – we will make our fleet completely zero emission by 2035 and in the same year we will aim for carbon neutrality at company level. Our targets are in line with the 1.5 degree climate commitment.

Reaching our targets will require a commitment from all of us. We will actively educate and communicate on sustainability issues. We give everyone at Niemi the opportunity to have a say, for example by collecting initiatives, and we use these initiatives as a basis for developing our activities.

We take the environment into account in all our purchasing and seek to build long-term partnerships with shared objectives.

We continuously improve our environmental management system and develop innovative solutions together with our partners.

WE ACT RELIABLY

WE PROTECT OUR ASSETS

We are committed to protecting our assets wherever they are located and wherever they are stored or used. We understand our responsibilities outside working hours, on social media or when representing outside the workplace.

Our assets include physical property, technology assets, our company name, brand, trademarks and other intellectual property rights, customer relationships and personal data. We use property only for company business and other authorized purposes.

We also protect the assets entrusted to us by our customers, partners and other stakeholders.

By protecting our assets, we protect our competitiveness in the marketplace.

WE PROTECT INFORMATION

We handle all personal data entrusted to us appropriately and comply with the EU General Data Protection Regulation (GDPR) when processing personal data.

We understand the policies and practices regarding personal data such as names, addresses, personal identification numbers, email addresses and other identifiable and confidential information.

We collect data only when necessary and store it securely until we delete it from our systems.

We take security seriously and strive to protect our data and information systems from unauthorized access, damage and misuse.

We keep the data under our control properly stored.

We use strong usernames and passwords, security software and updates, and protect our network and manage access rights.

We back up and destroy data appropriately.

WE REPORT ISSUES OF CONCERN

MAKING ETHICAL DECISIONS

If you are not sure how to proceed, you can think about it by asking the following questions.

1. Is my decision legal?
2. Does it comply with our Code of Conduct and Niemi’s values?
3. Will it not advance your personal interests and create a conflict of interest?
4. Would my decision pass public scrutiny? How would it look in the media?
5. Would my decision protect Niemi’s reputation as an ethical company?

If you answered ‘yes’ to all questions, the decision is very likely to be in line with our ethical principles.

REPORTING CHANNEL AND SANCTIONS

When you suspect that a situation has not been handled in accordance with the law, our Code of Ethics or our other policies, you have a duty to report it.

You can always talk to your supervisor in the first instance, or you can report your concerns to the Human Resources Director or anyone in Niemi’s management.

You can also make an anonymous report to Niemi’s reporting channel. All reports submitted to this channel will be treated confidentially.

Please also remember our other notification channels:

• Safety and environmental alert
• Feedback and suggestions for improvement

Violations of our Code of Conduct will always result in sanctions. There will be no penalty or pressure on the whistleblower for reporting incidents.

SUSTAINABILITY WORKING GROUP

Niemi has an active working group whose task is to lead, report and communicate the company’s responsibility work throughout the organisation.

The working group is divided into three sub-groups:

• Environmental responsibility
• Social responsibility
• Good Governance

The groups are responsible for being aware of the requirements in their area, developing the necessary policies, principles, guidelines and training, and carrying out any audits.

The group works closely with the management team, the Board of Directors and all the people at Niemi.