Message from our Group CEO
In order to create trust and succeed, Paree Group and its subsidiaries Cubist IT AB, Innokas Medical Oy, Serres Oy and Vieser Oy (“Paree Group”) must operate responsibly. Compliance with laws, regulations and good corporate governance practices are our minimum requirements, only. Our operations are founded on the provisions of the Universal Declaration of Human Rights, the Core Conventions of the International Labor Organization (ILO), the OECD Guidelines for Multinational Enterprises, and the UN Global Compact.
Responsibility at Paree Group is everybody’s business. Our Code of Conduct applies to everyone in our company, at every level, including employees, management and board members. The Code of Conduct and related policies guide our daily work. They help us live our values, make the right decisions in our daily work while safeguarding our reputation – and ourselves. Our Code of Conduct is based on our commitment to conducting business ethically, honestly, in a responsible way that is both environmentally and socially sustainable. We must always act with integrity and do the right thing, even when the right thing is sometimes hard to do.
We use Code of Conduct also to decide whether to enter or continue relationships with suppliers and business partners. We want to do business only with partners whose social and environmental standards are consistent with our own, and who act in a way that is consistent with the principles and values of our Supplier Code of Conduct. That Code defines the minimum requirements to which we expect them to be committed. And we expect employees working with our third parties to hold them accountable.
Our Code of Conduct covers some areas of ethical and business issues, but it cannot provide all the answers. Additional guidance is provided in the form of policies, principles and guidance. The Group offers compulsory training on the topics covered by our Code of Conduct, and everyone must regularly take part in training to be familiar with it. You are expected to familiarize yourself with the Code of Conduct, participate in the training, commit to it, ask questions and voice your concern if you see or suspect misconduct of any form.
Failure to adhere to the principles presented here can expose us, our colleagues, and the various business partners to reputational risk, as well as legal and regulatory sanctions. By following our Code of Conduct, we aim to avoid that. Everybody’s daily decisions matter.
Our mission and values
Our mission is to make our impact today for a more sustainable and healthier tomorrow. This mission is supported by our values collaborate to win, consistent integrity, courage to renew, and creativity through diversity. Our values together with this Code guide our actions at Paree Group.
Our responsibilities
We follow applicable laws of the countries where we do business and adhere to Paree’s Code of Conduct, policies, principles and guidance. We personally set the example for each other and our stakeholders by being honest and fair. We also hold each other accountable to this Code of Conduct, and if we become aware of potential violations, we
promptly report them.
Every employee must read, understand, and follow our Code of Conduct and its policies and seek guidance when needed. If you are confronted with an ethically challenging situation, ask yourself:
Is this legal? Do I understand the risks and implications? Would I be comfortable if my actions were made public? Does it follow our Code of Conduct and policies? Would a colleague or other stakeholder approve this?
If you answered no to just one question, or still feel unsure, turn to your supervisor.
Everyone is also required to raise any compliance concerns through reporting to supervisor or through the whistleblowing channel. All of us must fully support anyone who raises a compliance concern and never retaliating in any way against anyone who does raise a question or concern. We also have to cooperate in all compliance investigations.
Paree Group leaders have even more responsibilities when it comes to ethics and compliance. They are expected to lead with example and drive a culture of integrity throughout their organizations. They are also accountable for compliance failures that result from their failure to advance this culture in their teams.
Compliance with laws
We are committed to act in compliance with applicable laws and regulations in all our business operations everywhere we operate. It is of the utmost importance that we are aware of and adhere to laws, regulations, policies and guidelines that apply to our work. However, playing by the rules is not enough. We go beyond compliance whenever possible and always strive to improve our way of acting.
Business Integrity
Anti-Corruption
We do not tolerate bribery or corruption in any form. We must not, either directly or indirectly, offer, give, accept or receive bribes or kickbacks of any kind, including money, benefits, services, or anything of value. We are not offering or accepting a gift or any other benefit if it is against the law or internal policies, unreasonably priced, offered or accepted secretly or too frequently, intended to influence decision making, or otherwise inappropriate in the relevant context. When we engage with regulators and public officials, we act ethically and in line with applicable rules and regulations. We make sure that all the payments to and contracts made with third parties are appropriate, for a legitimate business reason, and correctly recorded. We are truthful and accurate, and we follow applicable laws and Paree Group’s policies and procedures.
Fair Competition
We support free and fair competition. The Group’s policy is to compete in a way that is compliant with applicable anti-trust and competition laws in every jurisdiction in which the Paree Group operates. We do not enter into agreements and practices that would have a detrimental effect on competition, such as price-fixing, market allocation or abuse of dominant position. We do not either discuss competitively sensitive topics with competitors, such as price, contract terms, or marketing plans. Even casual conversations could be considered anti-competitive. If you witness conduct that violates fair competition laws, remove yourself from the situation and notify your supervisor immediately.
Trade Sanctions
We comply with all trade controls applicable to our business, and provide accurate and truthful information about our business to relevant authorities. Some countries have trade controls that restrict certain business transactions and movement of goods across borders. There are also various sanctions regimes that have been implemented by the United Nations (UN) and/or the European Union. We make sure that we are aware of them, and act accordingly.
Privacy
We protect the personal data of employees, customers, suppliers and business partners. We only process, store, and share personal data when there is a legitimate business purpose for doing so. We follow applicable laws and our own privacy rules which ensure that we treat personal data with a high level of care. Compliance with relevant national legislation, together with the provisions and principles laid out by the European General Data Protection Regulation (GDPR) is required from all Paree Group employees.
Intellectual Property (IP)
We respect the intellectual property of others and will not
knowingly violate the valid IP rights of third parties. Intellectual property (e.g innovations, discoveries, ideas, etc.) is critical to the continuing success and operation of the company and must be protected as confidential and proprietary information. All of us have a responsibility to identify, protect and defend our IP and promptly identify and report any conflicts including unauthorized disclosure and violations of infringements by any third party of Paree Group’s IP.
Safeguarding the company’s assets
We protect the company’s property, resources and information systems, and ensure that they are kept secure at all times. We use these assets appropriately and responsibly, and protect them against loss, theft, damage, fraud or misuse. We use assets and resources only for their intended business purpose or other approved purposes.
Confidential information
We safeguard the company’s confidential information. This includes for instance business strategies, technical knowhow, financial information, customer lists, personal data and passwords. We only use confidential information for legitimate business purposes and share such information on a need-to-know-basis. We also respect the intellectual property of others and only use it if we have obtained permission to do so.
Conflicts of interest
We each make decisions in the Paree Group’s best interests at work, and our decisions must not be influenced by personal or private considerations. If a potential conflict may exist, we discuss it with our supervisor. In situations where personal interests may conflict with the interests of Paree Group, employees are required to abstain from decision-making and assign the issue to a non-conflicted person.
Fair and respectful treatment of people
Respecting human rights
We recognize the human rights of all people as outlined in the Universal Declaration on Human Rights and the UN Guiding Principles on Business and Human Rights. We take responsibility for avoiding infringement of human rights and for remediating the impact on human rights resulting from our activities and our products. We expect our suppliers and business partners to apply equivalent values and we support them in their implementation where needed.
Paree Group complies with all applicable human rights, labor and employment legislation. We expect our suppliers and other business partners to do the same. This includes for instance paying a living wage, providing safe working conditions, and complying with working hours. We do not tolerate, in any context, the use of child labor, forced labor, human trafficking or slavery in our operations in any region in which we operate or in any part of our supply chains.
We encourage our colleagues, suppliers and business partners and people affected by our activities or products to raise complaints and grievances about any potential human rights impact or breach of our Code of Conduct through our whistleblowing channel. We address these complaints and grievances fairly, in confidence and in accordance with laws.
Diversity, Equity and Inclusion
We hire the best people for the job based on equality of opportunity. We do not tolerate discriminatory practices regarding job assignment, training and development, promotion, remuneration and other benefits, or general conduct in the workplace. We support diversity and treat people with dignity and respect.
Discrimination is strictly prohibited, for example, on the grounds of age, disability, sensitive medical condition, nationality, citizenship, racial and ethnic origin, sociocultural background, neuro-diversity, color, religion, marital status, family commitments, gender, gender identity, sexual orientation, political opinion, membership or non-membership in a trade union, employees’ representative activities, or any other personal characteristics or expression. We want to create a positive workplace where employees are able to do their jobs without fear of harassment or discrimination. To create and maintain a safe and productive work environment, it’s up to all of us to respect the unique character of every colleague and to treat each other with respect and professionalism.
Harassments, abuse, violence
We work to provide a safe and secure workplace to our employees. We do not tolerate any forms of discrimination or harassment, bullying, intimidation, abuse, exploitation, or any other unacceptable behavior, whether towards colleagues, business partners or any other stakeholders. This includes, for example, any verbal, physical, or other interaction that could be construed as hate speech, trolling, harassment (sexual or otherwise), or bullying, whether done face-to-face or electronically. Our communication with one another and third parties is always professional and respectful. And we never tolerate retaliation against employees who report this activity in good faith.
Occupational Health and Safety
We aim to make sure that everyone who works for Paree Group goes home safely at the end of the day. Our goal is to achieve zero injuries and serious incidents. We do this by applying consistent and leading standards in people, product and process safety. Whatever the context, we are committed to complying with safety-related laws, and we all play our part in the company’s safety performance. At Paree, safety starts with management but it is also everyone’s personal responsibility to work safely and help others to do the same. We believe in creating an open safety culture where everyone can give feedback and make observations about safe and unsafe behaviour and conditions.
We take immediate action to correct situations where we identify areas for improvement, and we build sustainable, scalable, and repeatable solutions. We expect our suppliers and other business partners to meet the same standards and place equally high priority on health, safety, and labor conditions in their operations.
Environmentally sustainable business
We are committed to comply with environmental laws and regulations in every country we operate in. We focus on reducing our environmental footprint and growing our environmental handprint. We work closely with our suppliers and business partners to do more with less in an environmentally responsible way. The Paree Group aims to raise awareness, encourage participation, and train employees on environmental matters, and bring sustainability into core of the business.
Responsible sourcing and
business partnerships
We want to ensure that the products that we offer to customers are safe and of high quality and that they have been produced responsibly in ethically and environmentally acceptable production conditions through the whole supply chain. We select our suppliers and business partners carefully, and expect them to commit to our Supplier Code of Conduct.
We demand our suppliers and business partners comply with legislation and international norms concerning human rights, labor rights and other corporate responsibility matters, and set the same demands for their own suppliers. We supervise our supply chains and seek to minimise the associated corporate responsibility risks.
Responsible communications and marketing
Open, transparent and accurate communication
We are committed to communicating in an open, factual and timely manner, while following legal and business obligations. To be sure that we comply with law and protect the company’s interests, we refer media enquiries to people who are authorized to speak on behalf of the company. We consider our business communications carefully, regardless of the method we use to communicate, and ensure that they meet high standards. We each use consideration and common sense when we use social media at all times. We do not share confidential information about Paree Group, our customers, suppliers, or other business partners on the internet. We respect copyrights and never share anything that may be seen as a threat, harassment, or bullying.
Ethical marketing
We follow the marketing laws, regulation and compete for business openly and honestly. Unless there is sufficient research to substantiate a comparison between a Paree Group product and a competing product, we do not use comparative advertising of any sort. We promise only what we can deliver and deliver on what we promise. We respond to customer feedback or complaints in a polite, efficient and timely manner.
Reporting violations and consequences to violations
We take action, if we believe that our Code of Conduct or policies is being, or is about to be, breached. We expect everyone to raise concerns regarding suspected unethical behavior or misconduct. Paree Group takes every report seriously. There are no consequences for reporting a breach of the Code in good faith, even if the report is unfounded.
We take action, if we believe that our Code of Conduct or policies is being, or is about to be, breached. We expect everyone to raise concerns regarding suspected unethical behavior or misconduct. Paree Group takes every report seriously. There are no consequences for reporting a breach of the Code in good faith, even if the report is unfounded.
Based on the findings of the investigation, appropriate corrective and disciplinary action will be taken, such as giving warnings or, in severe cases, termination of an employment relationship. Any suspected criminal activities
will be reported to the relevant authorities.
