Code of Conduct

The Code of Conduct sets out the fundamental group wide principles which each employee, in each Sanitec function, must follow in their everyday work for and on behalf of the Sanitec Group companies.

I) Compliance with the Law
We in Sanitec are fully committed to comply with applicable national and international laws and regulations where and whenever we operate. Where the regulation is considered by us to be inadequate or ambiguous, our aim is to set a high ethical standard exceeding the basic requirements of applicable law.

All Sanitec employees must be familiar with the basic legal requirements that apply to their job responsibilities. Sanitec Legal Services will provide resources such as workshops to assist employees to become familiar with the legal requirements of their job. In case of even a slightest legal uncertainty or any doubt of any matter related to legal compliance, the employee in question must always contact Legal Services or local law office to avoid any inconsistency with legal environment.

II) Conflict of Interest 
According to general definition “Conflict of Interest” occurs when an employee allows the prospect of personal gain to influence his/her actions in the conduct of company business. Potential conflicts of interest must be avoided or, if unavoidable, carefully managed as early as possible after the suspicion of potential Conflict of Interest situation has arisen. We require that all employees disclose to their supervisor any financial interest that might influence an employee's decisions or actions on the job, including interests in any of our business associates and competitors. The matter shall be processed and discussed openly, promptly and straightforwardly in co-operative spirit and the process shall be documented in writing. Business dealings with relatives (including recruitment), outside employment or activities, investments, and private arrangements with suppliers may be potential sources of conflicts of interest.

Employee must not use his/her position or the knowledge gained as a result of their position for private or personal advantage or use or allow any other person to use the assets or facilities of Sanitec for personal gain or business.

III) Confidential Information
Confidential information is critical to a business’ success in a competitive marketplace. Improper or unauthorized use or handling of confidential information is damaging to the business and may impact on the operational and financial performance of Sanitec Group. Various laws protect confidential information from use by others as well as the handling of such information but at the end of a day it is all about the behaviour of the individual employee which really makes a difference.

Therefore, every employee must take appropriate steps to protect confidentiality and respect confidential information belonging to others. The significance of the know-how and trade secrets possessed by the Sanitec Group companies and our employees is huge and we all must strive to protect such information by all available means. Same applies to employee’s personal and private information. In Sanitec Group we want to ensure that the privacy of each and every employee is respected in full. Data and other information about our employees shall be kept confidential and not used without employees’ consent except where permitted or required by law.

IV) Bribery
Bribery is a form of corruption, which can take place in relation to both private and public operators. It is the giving to or receiving by any person of anything of value (usually money, a gift, loan, reward, favour or other consideration) exceeding the level of normal hospitality, either directly or indirectly, as an inducement to gain an undue advantage or influence contrary to the principles of honesty and integrity.

You must never offer, give, accept or receive, directly or indirectly, a bribe in any form. Neither is it permitted for third parties acting on our behalf, such as agents and consultants, to do what we will not do ourselves. In some business areas, “facilitation payments” are demanded in return for the performance of certain “routine governmental actions”. It is sometimes difficult to draw a distinction between facilitation payments and corrupt payments and therefore facilitation payments are generally not acceptable. In case
you ever come across threat or actual bribery in any form, immediately contact your supervisor and Legal Services.

V) Customers and Suppliers
The welfare of our customers is in the essence of our daily work. We all work daily in order to continuously meet and exceed our customers’ expectations and to create sustainable and mutually profitable relationships with them.

Sanitec Group follows best business practices in all of its business operations and fosters high standards of honesty and integrity in all relationships with its suppliers and business partners. Suppliers and business partners are expected to conduct their business in compliance with international and national laws and regulations as well as human rights and environmental laws and practices. Especially the compliance with the following principles shall be closely monitored:

• Employment is freely chosen without any mean or level of compelling and no child labour is used;
• Working conditions are safe and hygienic, no harsh or inhuman treatment or discrimination is allowed; and
• Working hours are not excessive, wages are paid accurately and the freedom of association is respected.

VI) Use of External resources and Third parties
In Sanitec Group, vast majority of services necessary for conducting our business are provided internally. External resources and performance provided by third parties are used only when external assistance is crucial for the success of our activities. In case the need for external assistance emerges, always contact your supervisor before approaching external service provider.

VII) Health and Safety
We are dedicated to safeguard the health and safety of our personnel at work. Our target is zero rate in injuries and accidents; profit shall not be made in the expense of physical and mental welfare. To reach the target, new processes are launched and guidance given continuously.

Every employee must respect the safety and comfort of others and restrict himself of all actions that might endanger the health and safety of others. Every employee must immediately contact his/her supervisor if he has been assigned to work with something with lack of a required competence or knowledge. In addition to that, every employee is under an obligation to report his/her supervisor if he notices a defect or omission that might endanger his/her or his/her co-workers health and safety at work.

In Sanitec Group we understand and encourage our employees to achieve the balance between business and private life. However, we consider our employees as our representatives and expect them to live in accordance with the laws, regulations and under the requirements of good citizenship also in their spare time.

While at work, Sanitec Group expects its employees to conduct themselves in a businesslike manner in all situations. Drinking, gambling, fighting, swearing, bullying and similar unprofessional activities are strictly prohibited and will not be tolerated. Furthermore, all facilities, assets, tools etc that belong to Sanitec shall be treated in a professional manner and in accordance with the given instructions.

VIII) Harrasment and Discrimination
In Sanitec Group, all employees shall be treated as equal no matter their sex, age, nationality, language, religion, political or other opinion, national or social origin, association with a national minority, property, birth or other status. We are committed to equal opportunity in all fields of employment, including recruitment, remuneration, development, advancement and other procedures and practices of work.

Every employee shall respect each others privacy and integrity in full. All actions, provocations and other communications, whatever the means with offensive or suggestive form or objective, are strictly prohibited and will not be tolerated in Sanitec Group.

IX) Environment
With globalisation and increased international focus on the environment, companies have been challenged to become a part of the solution rather than a part of the problem. Sanitec Group recognizes its responsibility as a global citizen and is continually improving its environmental performance for the benefit of our neighbours, employees, customers, suppliers, business partners and ultimately the end consumers of sanitary products.

X) Media
Employees must take care to separate their personal roles from their organisational positions when communicating on matters not involving Sanitec Group business. Employees must not use organization identification, stationery, supplies, and equipment for personal or political matters.

Employees are not allowed to communicate publicly on matters involving Sanitec Group’s business unless they are certain that the views they express are those of Sanitec Group, and it is the organisation’s desire that such views are made public by the employee in question.

In case an individual employee is contacted by an outside media representative, the employee is obliged to forward the request immediately to his/her supervisor and Sanitec Corporate Communications without further comments to media. Similarly, the employee shall inform and request consent from his/her supervisor prior to any publication of articles or contributions to conferences or other public events that are related to the Sanitec Group’s business activities.

XI) Other issues
Sanitec Group is not a political organisation and will refrain from making any contribution, whether in cash or in kind, to any political candidate, political party or organisation whose activities are designed to promote the interests of political parties or political ideologies. When dealing with anyone outside Sanitec Group, including public officials, employees must take care not to compromise the integrity or damage the reputation of Sanitec.