Nolato's Code of Conduct

The Code applies to all Nolato’s employees and all representatives acting on behalf of the company, including permanent and temporary employees, contractors, consultants, senior managers and board members of Group companies. All employees and other representatives are responsible for complying with this Code. 

The principles and rules are valid in all markets and need to be understood by everyone in the organization, and should be applied in the same way, wherever you are in the world. The CEO assumes ultimate responsibility for the implementation and application of the Group Policies and Guidelines that are included in the Code. Responsibility for promoting sound business ethics and compliance with our policies is delegated to all managers in the Nolato Group. The Nolato Spirit and associated policies are part of training and follow-up programs at all levels in the Group. Every new employee should be given the opportunity to read and discuss The Nolato Spirit and this Code of Conduct as part of the onboarding process.

Nolato’s responsible business conduct depends on us all applying the corporate values and core business principles outlined in this Code. Breaching the Code or applicable laws can result in penalties for the company, or the individuals involved, and can damage the reputation of the Group. 

The Code of Conduct can be found on Nolato’s website. It is each manager’s duty to ensure that employees understand the Code. Each employee is responsible for understanding the requirements that are directly applicable to their position, role and employment. In situations where the Code does not provide a clear answer, you should discuss the matter with your line manager or the Group Sustainability Director.

Nolato has a zero-tolerance policy for non-compliance with legislation and for human rights violations, and on issues regarding bribery, corruption and breach of competition laws.

Any employee, regardless of position and role, who is found to have violated this Code, or any underlying Group policies, directives or applicable laws and regulations, will be subject to disciplinary action, which may ultimately lead to termination of employment and/or criminal proceedings.

Nolato regularly monitors sustainability work and development through dialogue and/or annual questionnaires with our stakeholders and through formal audits. Nolato’s reporting should meet applicable regulations and international standards and the Group’s performance is mainly presented in the Sustainability Report, which is a part of the Annual Report. 

Nolato’s Sustainability Report is used to demonstrate compliance and monitoring regarding the Group’s performance in relation to The Nolato Spirit. The report can  be found at www.nolato.com/en/IR/Responsible-business-conduct.

When Nolato’s stakeholders, customers and other parties ask Nolato to demonstrate compliance with laws, international initiatives and other requirements, The Nolato Spirit document and this Code should be sent to the party concerned. Any additional questions should be referred to the relevant business area, company or person.

Nolato’s whistleblowing function enables anyone who in a work-related context 
has obtained information about suspected irregularities, breaches of law or serious violations of Nolato’s Code of Conduct to raise the alarm, without the risk of being subject to any form of reprisal.
 
Irregularities can be reported to the management team or senior manager of the relevant unit. But if this is not appropriate or does not work, Nolato’s whistleblowing function at www.nolato.com/whistleblowing can be used.

Nolato’s whistleblowing function complies with the EU Directive on the protection of persons who report irregularities (2019/1937), as well as with implemented local laws. All whistleblower reports are handled in a secure system by an independent person bound by secrecy to protect the whistleblower from the risk of being harassed or opposed due to their whistleblowing.
 
The right to use Nolato’s whistleblowing function extends to anyone who was employed or seeking work at Nolato, carried out work for Nolato or was professionally engaged at Nolato in another way (e.g., as a trainee, agency worker, consultant, contractor or supplier) when they obtained the information about the irregularity, breach of law or serious violation of the Code.

The whistleblower does not have to be certain that what is being reported is true, but must have good reason to believe in the accuracy of the report. Anyone who knowingly reports false information or unfounded rumors will not be covered by the legal protection for whistleblowers, and Nolato may take action under employment law.
 
Dissatisfaction solely about your own work or employment situation does not usually constitute grounds for whistleblowing, nor do disputes or complaints about the workplace, work environment or management if they do not relate to breaches of law or serious violations of Nolato’s Code of Conduct.
 
The whistleblower will receive confirmation of the report within seven days. The recipient of the report will then follow up the report, investigate the matter and take any necessary action. Within three months of receiving the confirmation, feedback will be given on the investigation.