Aspocomp’s Code of Conduct

Aspocomp is committed to sustainable business. We want to serve both our customers and other partners in the best possible way. We strive for good financial results in a legal and honest manner and we provide shareholders with relevant and truthful information about our operations.

Aspocomp’s Code of Conduct defines the basic requirements of our business practices and guides our employees to act responsibly in their daily work. Our Code of Conduct is based on our core values: We provide our customers with value-added services. Being streamlined makes us more efficient. Continuous development keeps us going. The working community is a strength.

Aspocomp’s way of operating in compliance with laws and regulations and in accordance with our values is determined in this Code of Conduct. The Code of Conduct has been approved by Aspocomp’s Board of Directors. Aspocomp’s Code of Conduct is maintained annually and updated as necessary.

All Aspocomp employees are expected to act responsibly and with integrity and honesty, and to comply with the requirements of those laws and regulations that apply to Aspocomp’s operations and to his/her job as well as with company’s code of conduct principles. Aspocomp’s employees are also expected to report on violations and protect the company against unethical conduct and superiors are obligated to endorse compliance with these principles among their subordinates.

Compliance with laws and regulations

We are honest and fair, and comply with all applicable Finnish laws and regulations. As a listed company, Aspocomp is also bound by securities market regulations as well as regulations and guidelines for good corporate governance. We take care of all our commitments to the authorities and other societal stakeholders.

In relation to the company’s Code of Conduct principles the laws concerning the status of employees, equality, privacy, prevention of bribery and corruption, competition and consumer protection, occupational safety, environmental protection and product safety are particularly significant.

Our working principles are in line with the Social Accountability International SA8000 standard. The main aspects of SA8000 relate to preventing the use of child and forced labor, working hours and remuneration, occupational health and safety, freedom of association and the right to collective bargaining.

Respect for human and labor rights

We respect and comply with the United Nations’ Universal Declaration of Human Rights and do not accept any violations of these rights. As a employer, we comply the International Labor Organization’s (ILO) Declaration and the fundamental rights of workers specified in it.  We also take care of our employees’ freedom of association and collective bargaining. We do not accept the use of any forced or child labor.

We adhere to the principle of equality regardless of gender, race, ethnic or national origin, age, religion or belief, disability, political opinion or other characteristics. Everyone has the right to a healthy and safe working environment and the inviolability of personal integrity. We do not tolerate discrimination, harassment, threats or insults in any form. Any form of harassment or bullying in the work environment is strictly prohibited.

Fair employment practices

We comply with pay and working time laws and our policies are in line with Social Accountability International’s SA8000 standard, including laws of minimum wages, overtime and mandatory benefits.

Healthy and safe working community

Occupational safety is a basic prerequisite for the welfare of our employees. We take care of our employees’ health and safety at work and want to shoulder the responsibility for our personnel’s well-being together with them. Aspocomp has internal rules for health and safety and we monitor compliance. Each employee is also personally responsible for obeying the company’s safety instructions.

Environment

We take the environment into account in everything we do, and want to contribute to a healthy environment and to develop more sustainable production and consumption patterns. We aim to minimize the impact on the environment caused by our own operations. Our plants are certified in line with the ISO 14001 environmental system and have related operational plans.

Environmental responsibility is an integral part of Aspocomp’s operations, management and decision making, seeking to minimize the company’s environmental impact. We seek to continuously develop our operations to prevent and reduce the emissions and wastes caused by our operations. We are committed to minimizing the use of materials that have a harmful impact on the environment throughout the whole life cycle of products.

Aspocomp complies with the environmental legislation and regulations that are in force as well as seeks to proactively boost the efficiency of its operations while taking environmental issues into consideration in all of its functions. The company is committed to continuously reducing its adverse environmental impacts, such as by cutting emissions, conserving natural resources, and using the best available and economically viable technologies.

In order to achieve these objectives, Aspocomp trains its employees and constantly works in cooperation with its customers, the authorities and other stakeholders. Aspocomp manages its environmental compliance with an environmental system that has been certified in line with the latest ISO 14001:2015 version.

Fair competition

Our business is honest and transparent. In all our activities, we adhere to good business practices and existing competition laws. We do not take any part in activities that might restrict or impede effective competition.

Anti-corruption and conflicts of interest

Aspocomp does not tolerate fraudulent behavior or activities in any form. We do not offer or accept bribes, nor do we accept bribery or corruption in any form. We comply with legislation and internationally recognized principles for preventing corruption and bribery.

The personal interest of an Aspocomp employee must not influence his or her behavior at Aspocomp. Our employees must avoid situations where their personal or his or her related parties’ financial interests are in conflict with the interests of Aspocomp. A person working at Aspocomp may not be involved in making decision concerning a matter or transaction from which he or she gains or seems to gain a personal advantage or an advantage benefiting his or her related parties or an entity represented by him or her.

Acceptable hospitality or gift is casual and of little value and does not rise to explicit or implicit obligations for either party or create expectations of anything in return.

Politics

We do not support political parties and other political organizations directly or indirectly, nor do we participate in funding the election campaigns of individual candidates. The employees involved in political activities act solely as individuals and not as representatives of the company.

Accurancy of accounting records

Aspocomp accounting records must be accurate and reliable in all material aspects. Unrecorded funds are prohibited. The records must not contain any false, misleading, or artificial entries.

Open Communication

Communication within Aspocomp as well as communication with stakeholders and authorities shall be open, transparent and factual. However, in some situations other considerations may restrict such openness and transparency, for example securities market regulations or protection of confidential information.

Trust and protecting confidentiality

All employees are required to take the necessary steps to protect all of Aspocomp’s tangible and intangible assets, as well as the company’s confidential information. Aspocomp’s assets may not be used for political purposes. We never act in a way that could harm Aspocomp’s reputation or competitiveness.

We maintain the secrecy of confidential information entrusted to us at work regarding the company’s operations, personnel, customers and business partners, as well as all matters pertaining to security arrangements (such as cash processing, data security, alarm systems), and we will not disclose this information to unauthorized parties. We always ensure that confidential or important information is not lost or passed on to third parties.

Aspocomp’s trade secrets and confidential information are valuable business assets and therefore all employees must keep such information confidential and may not, for other than Aspcomp’s business purposes, disclose any such information to third parties (including friends and family members).

Processing personal data

All personal data collected by Aspocomp is subject to absolute confidentiality. We comply with the law, company’s Privacy Policy and the applicable privacy practices.

Personal data are collected only on a legal basis and for purposes permitted by law. The company’s data protection policy defines the principles and methods to be followed for the processing of the company’s personal data. The company’s Privacy Policy is regularly updated to meet, inter alia, the requirements of the EU Data Protection Regulation (GDPR). Aspocomp has surveyed the personal data processed in its systems and clarified the legal grounds for processing personal data and the purpose for which personal data were used.

Guidelines for Insiders

All Aspocomp personnel must comply with the provisions on the management of inside information in force, Market Abuse Regulation (MAR) and its implementing provisions, the Securities Markets Act, the Penal Code, the law of the Financial Supervisory Authority and the Nasdaq Helsinki’s Guidelines for Insiders, as well as the instructions issued by the Finnish Financial Supervisory Authority and the European Securities and Markets Authority (ESMA). Aspocomp has in use its own Insider Rules set out by the company’s Board. These Insider Rules have been drawn up observing the above laws and regulations as well as clarifications concerning the company. Note that each employee is personally responsible for following all applicable laws and regulations.

How to report suspected violations (whistle blowing)

If you observe any violations related to the compliance with Aspocomp’s Code of Conduct or legislation, report these observations via company’s Whistleblowing Channel. The report should be made honestly and in good faith.

Reported concerns can be made under your own name or anonymously. All reports are handled with strict confidentiality. To ensure confidentiality, the channel is maintained by an external partner, EasyWhistle Oy. The reports are submitted via encrypted connections and protected by passwords. All reports are handled in strict confidence.

Aspocomp’s Whistleblowing Channel does not track IP-addresses or other information that could identify the reporter. All information, reports, and follow-up questions are encrypted, and password protected.

Whistleblowing channel

Sanctions

Violations of this code may lead to a warning, the termination of employment, and the payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.