Gifts, benefits and bribes

Investor has high expectations of ethical and moral business behavior to protect Investor's brand and reputation. Investor’s policy, approved by the Board of Directors, is that Investor will not under any circumstances tolerate corruption or bribery (including so-called facilitation payments). Investor complies with applicable laws.

Investor has internal procedures approved by the Executive Leadership Team, aimed at providing guidance to evaluate what is appropriate and not appropriate in professional relations regarding, among other things, gifts and benefits. The internal procedures are built on the principles of the Swedish Anti-Corruption Institute’s Code on Gifts Rewards and Benefits in the Business Sector. According to the internal procedures, the gifts and benefits given and received shall always be characterized by openness and moderation. In doubtful situations, the immediate supervisor shall always be informed and consulted. Investor’s Legal department is also available for guidance. The risk for bribery and corruption is evaluated continuously and also assessed on an annual basis as a part of Investor’s risk assessment process.

In order to sensitize the organization of internal procedures, regular trainings are being held and internal procedures are available on Investor's intranet. Investor’s policy and procedures are monitored continuously and updated at least annually. All employees sign the Code of Conduct which also include the anti-bribery and anti-corruption policy.