Responsible business

Nolato aims to uphold future-oriented responsible business conduct. We promote and apply sound business ethics and endeavor to combat all forms of corruption. Nolato conducts business with a high level of integrity and ethics, and we expect the same from our suppliers and business partners. In summary, this means:

Anti-bribery and anti-corruption

• We conduct business with a high level of integrity and ethics, and have zero tolerance of bribery and corruption.
• We comply with applicable regulations and laws, including all anti-money laundering legislation and reporting obligations.
• We assess the risk of bribery and corruption and implement preventive measures.
• We endeavor to prevent our businesses from being used for money laundering or terrorism financing.
• All forms of compensation to suppliers, partners and agents must only be for actual goods or services supplied.
• We never offer, or accept, gifts, benefits or payments that could influence, or be seen to influence, the objectivity of the recipient’s decisions or that breach legislation and/or local practices.
• We never pay bribes or facilitation payments.
• We ensure that commission, donations and sponsorship are made transparently.
• We endeavor to ensure that external partners acting on our behalf share and are aware of our commitment to doing business ethically.

Conflicts of interest 

• We make business decisions based on Nolato’s best interests.
• We avoid situations in which company loyalty could come into conflict with personal interests.
• We avoid all situations in which there is a potential conflict of interest in relationships or personal considerations.
• We always avoid situations where business judgement could be affected by gifts, hospitality, entertainment, sponsorship, political or charitable contributions, or by a close relationship with any business entity engaging or competing with Nolato. 

Fair competition 

We are committed to, and promote, free and fair competition.

• We respect and comply with applicable competition laws in all markets in which we operate.
• We act in accordance with fair business, marketing and advertising practices.
• We compete fairly and do business based only on quality and competence. 
• We do not tolerate any violation of antitrust laws, competition laws or related regulations.
• We never get involved in any understandings with competitors regarding the allocation of customers or prices or any other practices or agreements that restrict competition.
• We do not exchange confidential or sensitive commercial information with competitors.
• We respect ownership and intellectual property rights.
• Agreements that are sensitive in relation to competition law must be reviewed with regard to legal aspects.

Trade compliance

• We comply with applicable trade compliance requirements, as well as all applicable export and import laws and regulations.
• We respect and comply with applicable sanctions and rules related to cross-border trade.
• We do not engage, indirectly or directly, with any country, entity or person included in any sanctions list. 
• Due diligence is required for business opportunities in conflict zones and countries flagged as high-risk regions.

Responsibility for products and solutions

• We aim to contribute to making our customers’ products and solutions more sustainable, and to supporting a more sustainable society.
• We strive to ensure that our operations, services and products have as low an impact on human health, the environment and society as possible.
• We proactively offer our customers ‘eco-design’, as well as sustainable products and solutions.
• We use internal and external expertise to continually develop the eco-design of products and services.
• We continually address and assess the environmental and health and safety effects related to our main products and solutions over their life cycle.
• We comply with applicable laws and regulations that apply to our products and services, as well as with international standards and guidelines regulating conflict minerals and other material sourcing.
• We regularly follow up and evaluate our performance on social responsibility, the environment and business ethics.
• We refrain from manufacturing products that we believe are incompatible with our view of sustainable development. 

Commitment to quality 

• We are committed to delivering quality work in everything that we do.
• We supply products and services at the right quality that meet and exceed our customers’ expectations.
• We are continually improving and developing our operations based on sustainability considerations. 
• We take a systematic approach to quality management, and all production units should be certified in accordance with the ISO 9001 quality assurance system and applicable sector-specific certifications.
• We conduct regular evaluations of our quality assurance measures through analysis, recording of discrepancies and internal/external audits.
• We maintain effective and transparent procedures regarding customer complaints.

Company assets

• We use our company’s assets responsibly.
• We protect our company’s and, where applicable, our customer’s assets from damage, criminal acts and loss.
• We insure our company’s assets adequately.
• We comply with all applicable internal controls to protect and safeguard our assets.
• Assets should only be used for business purposes, unless other use has been approved by the relevant manager.
• We do not tolerate any use of our assets for illegal activities or personal gain.

Personal and business-critical information 

• We respect and protect information obtained from customers and third parties, as well as personal information (or data) about our employees.
• Information about our business and related parties is handled with caution, and we take relevant measures to ensure protection of business-critical information.
• Personal information (or data) is handled responsibly, and we ensure that information related to identified persons is handled in compliance with applicable regulations and laws in the countries where we operate.
• We respect and apply the protection of rights and privacy according to the EU General Data Protection Regulation (GDPR) and other applicable data privacy laws in the North America and Asia.

Information security and confidentiality

• We are careful regarding critical information that may be confidential, especially any information that could potentially affect Nolato’s or any business partner’s share price.
• We maintain good information and IT security and good information management.
• We ensure that confidential information is handled in compliance with applicable regulations, group policies and directives.
• Employees handling confidential information, including trade secrets, must comply with non-disclosure agreements, insider trading laws, applicable laws  and regulations, group policies and directives. 
• Nolato’s Insider Policy and Insider Register regulate the trading of financial instruments.

Accounting policies and reporting principles 

• We are committed to ensuring transparency in the Group’s financial and sustainability reporting.
• We comply with applicable laws and regulations regarding accounting, as well as financial and sustainability reporting.
• We provide transparent, accurate, regular and timely periodic financial and sustainability information in accordance with national and international regulations and standards.
• Financial and sustainability performance are evaluated by monitoring relevant parameters and through internal and external audits.
• Sustainability risk analyses should be carried out as a part of the due diligence process during acquisitions and divestments of businesses and properties.

Efficient and accurate tax management

• We conduct our business and support tax processes with a high level of ethics and integrity, with the overall aim of producing correct tax outcomes at accurate cost.
• We are committed to paying taxes as required by legislation in each jurisdiction.
• We address tax-related issues promptly and work proactively to mitigate tax risks.
• We always comply with applicable tax laws, regulations and company procedures in our business.

Honest and clear communication

• We communicate in a way that reflects our core values and Code of Conduct. 
• We provide transparent and objective information to our stakeholders and communicate honestly, clearly and in a timely manner, and ensure that information is not misleading.
• We comply with the obligations we have as a publicly listed company and apply disclosure restrictions regarding external communication in accordance with applicable legislation, agreements and standards relating to stock markets and financial reporting. 
• We endeavor to communicate transparently with the aim of engaging and involving our employees in the Group’s development. 
• We respect all employees’ freedom of expression about matters that concern them personally.
• To ensure clear, honest, professional and legally compliant responses to requests from analysts, investors and the media, we have appointed spokespeople for external communication that concerns the Group. 
• Nolato’s spokespeople are as follow:
  • External statements regarding the Nolato Group should only be made by the CEO or CFO, who are the Group’s spokespeople.
  • Managers are spokespeople within their respective area of responsibility.
  • Employees may give statements regarding specialist knowledge or on facts that are already known. 
  • In situations where these external disclosure restrictions do not provide a clear answer, you should discuss the matter with your senior manager or with the management team.

Requirements for suppliers 

• Nolato conducts business with a high level of integrity and ethics, and we expect the same of our suppliers and business partners. 
• We request that our suppliers and their suppliers comply with legal and human rights requirements. 
• We partner and collaborate with suppliers that accept and comply with Nolato’s Code of Conduct and encourage them to implement similar procedures and policies. We also expect them to pass these values and ethical principles on to their suppliers. 
• We encourage our suppliers to introduce certifiable management systems on quality management, the environment and work environment, and to support the Paris Agreement to limit global warming.
• We collaborate with our suppliers to meet our sustainability targets.
• We assess suppliers prior to and during our cooperation with them. 
• We regularly follow up and evaluate supplier performance within social responsibility, environment and business ethics.
• We endeavor to ensure that suppliers’ operations, services and products have the minimal possible impact on human health, the environment and society, and do not contain any counterfeit parts or materials. 
• If suppliers do not comply with our requirements, this could result in demands for improvement, corrective measures or termination of cooperation. 

Active corporate citizen

•  We strive to contribute to a better society and support local communities in the locations where we operate.
• We engage with the communities where we operate, and endeavor to provide jobs and professional development for local people.
• We participate in projects and cooperation with industrial networks, schools, universities and research institutes.
• We prioritize the support and sponsorship of organizations that share our values and that benefit the societies and locations in which we operate.
• We take a neutral position on political issues. Neither the company’s name nor its financial resources are to be used for political purposes or in a political context.