Code of conduct

This Code of Conduct sets out the fundamental principles of ethical behaviour expected of all those who work for or with Proact.

1. Compliance with the law

We will endeavour to understand our legal and regulatory obligations, and we will follow all laws and regulations that apply to us.

2. Respect in our interactions with others

We will be polite and treat others with respect and professionalism in all business interactions. We will deal with others fairly, honestly, and openly. We will not tolerate any form of bullying or harassment.

3. Protecting company funds and keeping accurate records

We are responsible for the safekeeping of company revenues, accounts and associated records and materials. We will be careful regarding costs and will keep records of any expenses that we later wish Proact to pay for. We will maintain accounting and systems procedures that always enable us and other relevant parties to obtain a true and fair view of our accounts. We will keep accurate and detailed business records of all transactions.

4. Confidentiality and intellectual property

We will protect confidential information and trade secrets in our possession from unauthorised use or disclosure. We will respect intellectual property rights and obligations of confidentiality and will not knowingly violate such rights or try to persuade others to do so.

5. Social and environmental responsibility

We will always operate in accordance with relevant health, safety and social and environmental laws and industry standards, including the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention Against Corruption.

We will take reasonable risk-based steps to ensure that our suppliers and other business partners also follow these laws and standards, by undertaking due diligence, contractual commitments and monitoring. We will not tolerate any form of modern slavery, human trafficking or human rights abuses within our business or our supply chain.

We will always try to use limited resources and increase energy efficiency to prevent or minimise any harmful effects of our operations on the environment. This includes promoting systems for recycling and recovery of materials, limiting carbon emissions and working to prevent work-related illness and injury. We shall follow all laws and regulations relating to the disposal of electrical and electronic equipment.

6. Following securities market rules

Proact IT Group AB is a public listed company. We will follow all securities laws, regulations and best practice guidance that apply to us, including the Market Abuse Regulation, the Nasdaq Stockholm listing rules and the Swedish Corporate Governance Code.

7. No anti-competitive behaviour

We will compete fairly and ethically and will not participate in any form of anti-competitive behaviour such as bid-rigging, price-fixing or illegally cooperating with competitors or suppliers.

8. Following export controls and sanctions

We will not export to or work with countries, entities or individuals subject to sanctions by the UN, EU or applicable national law. We will follow all export controls, in particular those relating to encryption technology.

9. Bribery, corruption and conflicts of interest

We will follow all applicable laws in the jurisdictions in which we operate, relating to bribery and corruption and will not tolerate bribery or corruption of any kind.

We will not offer, promise or give any advantage to any person with the intention of encouraging them to act improperly or as a reward for doing so. We will not request or accept any advantage from any person that is intended to encourage us to act improperly or in circumstances in which it could be perceived to have that effect.

We will not pay ‘facilitation’ payments to public officials in any country. We will ensure that we comply with our duty to place our responsibilities to Proact above our personal gain. This includes avoiding situations in business relationships and in personal or community activities that create, or may create, a conflict of interest between our personal interests and those of Proact. Gifts, hospitality, donations, sponsorships and similar benefits must always be reasonable, proportionate, transparent and never intended to influence a decision improperly.

10. Discrimination and equal opportunities

We will recognise and respect each person in the workplace as an individual and will not tolerate any form of discrimination. We will make all employment decisions including decisions about who to recruit, hire, train and promote based only on valid job requirements and objective assessments of suitability without considering a person’s sex, race, colour, religion, age, disability, national origin, sexual orientation or any other characteristics protected by law.

11. Use of IT systems

We will only use Proact and third-party IT systems responsibly for the business purposes for which access is given, in a manner that preserves the integrity and security of the systems. We shall not use any IT system in a way which contradicts the other sections of this Code of Conduct.

12. Data protection

We will follow all applicable data protection laws affecting the acquisition, maintenance and use of personal data.

13. Reporting concerns and protection of whistleblowers

We will report breaches or suspected breaches of this Code of Conduct or the law. Third parties may also report breaches or suspected breaches to the Chair of the Board of Directors of Proact at chairoftheboard@proact.eu.

All reports will be investigated. Where applicable, we will protect any individual who reports concerns in good faith from any retaliation.