Code of Conduct

1. Background and purpose

Eltel Group, including companies, business units and entities belonging to Eltel group of companies (hereinafter referred to as “Eltel”), sets high ethical standards in performing its business by operating in an economically, environmentally and socially responsible manner, as specified in this Code of Conduct. Eltel and its employees have undertaken to act in accordance with these rules.

Eltel informs its customers and other interest groups of this Code of Conduct and encourages such parties to apply the principles expressed in this Code of Conduct. Regarding its subcontractors and suppliers (hereinafter referred to as “Suppliers”), Eltel contractually obliges such parties to apply the principles expressed in this Code of Conduct. Furthermore, the Suppliers shall ensure that their subcontractors comply with the principles set out in this Code of Conduct. Below “Eltel” shall mean Eltel and Suppliers.

The purpose of this Code of Conduct is to prevent criminal and/or unethical conduct. The Code of Conduct aims to promote an enhanced culture of trust, accountability and integrity, and it is intended to be a positive contributor to help improve Eltel’s and its Suppliers’ performance and to minimise the potentially negative social and environmental impacts which may result from non-compliance.

2. Ethical standards

In order to ensure that Eltel conduct its business in an ethical, transparent and fair manner the following ethical standards areapplied throughout Eltel.

2.1 Compliance with legislation, respect for culture and custom

Eltel will in all operations respect all relevant and applicable laws and regulations of any country of operation and/or is incorporated or which laws and regulations mandatorily apply to Eltel’s business (hereinafter referred to as “Legislation”) and abide by the high ethical standards set for Eltel’s business operations, including operating in an economically, environmentally and socially responsible manner. Eltel will also endeavour to respect the culture, structures and customs of the communities and countries, where business is performed and where to do so would not result in Eltel breaching the Legislation.

At Eltel, due diligence is exercised to prevent and detect criminal conduct and an organizational culture is promoted that encourages ethical conduct and a commitment to compliance with the Legislation.

Should any criminal conduct be detected within Eltel´s operations, all appropriate steps will be taken to respond appropriately to such criminal conduct and to prevent further similar criminal conduct.

2.2 Regulatory Investigations, Inspections and Inquiries

Eltel will be direct, honest and truthful in all discussions with regulatory and law enforcement agency representatives and government officials and will cooperate by responding to appropriate requests for information.

2.3 Respect for environment, quality standards

In all its operations, Eltel shall support a precautionary approach to environmental challenges and respect the environment and its sustainable development. In particular, Eltel is committed to compliance with high quality standards.

2.4 Labour

Eltel is committed to promoting decent and fair working conditions for all of its employees, directors and officers as well as among its subcontractors, suppliers and other contracting parties in all countries in which Eltel performs its business. Safety at work is a key factor in decent and fair working conditions. Furthermore, Eltel is particularly committed to the elimination of all forms of forced and compulsory labour, prevention of child labour and non-discrimination in respect of employment and occupation.

2.5 Human rights

Eltel respects internationally proclaimed human rights and is committed to not being directly or indirectly involved in human rights abuses.

2.6 Anti-corruption

Eltel is committed to detecting and stamping out bribery and corruption by promoting a zero tolerance approach across the group and implementing the policies further detailed under section 3 (Anti-corruption measures) below.

2.7 Payments, books and records

All payments by Eltel shall be effected only against receipt of a detailed invoice and a due approval of the same by an authorized Eltel manager, director or employee. All payments shall be made only against actually rendered services or provided goods and only to parties with whom Eltel has a valid and proper business relationship.

Eltel shall issue and submit to its customer’s detailed invoices and records. All invoices are based on actually rendered services or provided goods.

Eltel shall keep detailed books and records of all incomes and expenses and comply with good bookkeeping practises as required by relevant Legislation.

2.8 Fair competition

Eltel shall promote good business practises and the use of fair practises in its businesses. Eltel is particularly committed to avoiding the use of any measures intended to prevent, restrict or distort competition.Information regarding business secrets shall not be unjustifiably obtained or sought nor shall such information be used in an unjustifiable way.

2.9 Relations to interest groups

Eltel respects its customers, suppliers, subcontractors and other interest groups and in all contracting Eltel’s aim is to follow the highest standards of ethics.

3. Anti-corruption measures

The following anti-corruption measures are applied and implemented throughout Eltel.

3.1 Appropriate behaviour

Local custom must be disregarded in relation to the payment of sums of money to both public officials and private persons (including employees of third party private companies) which may not be considered as being bribes under local custom but which would amount to bribes under Legislation. Neither Eltel nor its directors, managers, employees, agents, sub-contractors or other partners who perform services on Eltel’s behalf will:

3.1.1. offer, pay, promise, authorise or give a financial or other advantage, or allow such benefit or advantage to be offered, paid, promised, authorised or given on Eltel’s behalf, to a third party with a view to influencing a person’s decision-making, for the purposes of obtaining or retaining business or an advantage in the conduct of business, inducing a person to act improperly, or rewarding a person for improper performance, including small payments made to facilitate routine government action (for example by encouraging a public official to process an application or grant a license more quickly);  or

3.1.2. request, agree to receive or accept, whether directly or indirectly, a financial or other advantage, whether for their own benefit or for the benefit of another, from a third party where such acceptance results in an improper performance of a function or activity whether knowingly or not and whether by a person connected with Eltel or not including where the advantage requested, agreed to be received or accepted constitutes a reward for improper performance.

3.2 Third party conduct

In relation to preventing bribery by third parties who provide services on Eltel’s behalf, Eltel places contractual obligations on such third parties requiring them to comply with applicable anti-corruption laws and to avoid engaging in bribery. However, Eltel will not be responsible for any conduct of a third party which is in breach of such anti-corruption legislation.

3.3 Monitoring and whistle-blowing

Eltel agents, sub-contractors, business partners, employees, managers and directors shall report any suspicions or concerns relating to bribery or other corrupt behaviour. The first point of contact is the Legal Counsel at the Eltel company in question or the General Counsel of the Group. However, if the person reporting feels that contacting the Legal Counsel or General Counsel is impractical, the suspicions/concerns may be reported to the person’s immediate supervisor or, in the case of a person not in Eltel’s employment, the relative person’s immediate point of contact at Eltel.

3.4 Hospitality and gifts

All hospitality, gifts, promotional and business expenditure provided or accepted by Eltel managers, directors and employees shall always be reasonable and proportionate in the ordinary course of business and made in good faith for the purposes of seeking to improve Eltel’s image, better to present its products and services or to establish cordial relations. All hospitality, gifts, promotional and business expenditure shall be motivated by genuine business reasons. Monetary gifts shall never be accepted or given.

4. Audit

The Supplier shall provide Eltel with necessary information and allow Eltel to audit Supplier’s relevant documentation on order to verify that the Supplier, its employees and relevant affiliates and subcontractors comply with this Code of Conduct.

5. Anonymous questions and reporting

Any questions or reporting regarding a potential or realized compliance risk may be reported to the Eltel Group General Counsel by anonymous e-mails or letters, if so chosen. The address is: Eltel Group Oy, General Counsel, P.O.B. 50, FI-02611 Espoo, Finland. The e-mail address is:

6. Policy updates

Eltel will periodically review this policy and, where necessary and appropriate, will amend and update this Code of Conduct.

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Eltel AB POB 126 23, SE-112 92 Stockholm, Sweden

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