Code of conduct

Scope
Permanova Lasersystem AB's Code of Conduct has been adopted to emphasize the principles that will govern the business in relation to employees, business partners and other stakeholders. It applies to all board members and all employees in the company.
Permanova Lasersystem AB shall forward this Code of Conduct to particularly critical suppliers, consultants and other business partners and invite them to apply these principles as well.

Human rights
Permanova Lasersystem AB supports and respects the protection of internationally claimed human rights. Compliance with Swedish laws, adapted to applicable UN conventions, ensures that there is no involvement in human rights violations, e.g. slavery, forced labour or human trafficking.

Harassment and non-discrimination
Permanova Lasersystem AB recruits and treats its employees in a way that is not discriminatory regarding gender, race, religion, age, disability, sexual orientation, nationality, political opinion, trade union membership, social or ethnic origin. The company encourages diversity, and specific policies established within the framework of SAM (Systematic work environment work), Gender Equality Plan and Competence Supply Plan.
Harassment and other forms of victimizing behavior refers to behavior and actions that target one or several staff members in a derogatory, disparaging or other negative way and that may affect the health of the victims or lead to the victims being socially excluded in the workplace.
Harassment and other forms of victimising behaviour implies that a person has been subjected to harassment, victimisation or social exclusion and can have negative effects on the person’s work. An activity, interaction or process can be considered bullying if the behaviour in question has been recurring regularly for a long period of time.

Process to handle harassment, victimisation and discrimination
Our aim is to have a working climate characterized by a positive humanity and mutual respect alongside job satisfaction, well-being and
community. Permanova does not accept any form of victimisation, harassment or bullying.

Anyone who nevertheless detects tendencies towards victimisation, harassment or bullying should therefore primarily try to intervene by talking to the person or persons concerned. If this does not help, management should be informed.
Employees who themselves consider themselves to be victimised can turn to their immediate manager.

When will the organization come in?
1. When someone asks for help.
2. When the conflict negatively affects the business.
3. When third parties are affected by the conflict.

Organizational support:
1. Strive to be the sensible voice in the charged situations.
2. Strive for dialogue with the people involved regardless of role and attitude.
3. Defend active responsibility, ethical practices and "good behavior".
4. Assist with advice and expertise for labour law correct handling.
5. Counteract personal focus and think structural reasons for the problems.
6. Connect external help:
• As a neutral resource – e.g. when independence is questioned and important
• For complex cases
• As a relief for own organization / managers

How do we proceed?
The incident/information shall be handled with confidentiality as far as possible. The collected information may NOT be disclosed to any interested parties but should be used as a basis for managing the case and be seen as a desire for help from the organization in handling.

Workflow
1. The immediate manager represents the organization in the first place, if possible.
2. Make sure everyone behaves nicely IMMEDIATELY!
3. Speak to stakeholders individually and invite to a joint meeting for management together.
4. Focus on solving the problems that the work requires!
5. Identify clear factual and structural issues and solve them!
6. Sort between facts and what people think they know.
7. Help those involved distinguish between "the other" and the issues at hand.
8. Set requirements for clarity around needs and wishes.
9. Do not allow the parties' avoidance strategies – create the conditions for direct communication and structured investigative conversations.
10. Be generous with the opportunity for those involved to sort out their feelings and thoughts so that they can then focus on thesolution. (e.g. counselling, occupational health care...?)
11. As a manager/conflict manager, you are: Impartial, structured, logical, meticulous.
12. Create "response teams" and bring in help if you get stuck!
13. When the following is ensured, the case can be considered as closed:
i. The parties engage in finding a solution
Ii. The parties have accepted the agreement (preferably in writing)
Iii. The parties agree that the case is closed and promise to "move on" for continued courteous professional relationship in the workplace

The company is not a judiciary or court. As far as possible, the company strives for the parties involved in a conflict to resolve it themselves without the involvement of the organization.

Unwillingness to find a solution to conflict/case on the part of either party, person who does not comply with agreement or that the matter is considered, by the organization, to be of a serious nature leads to written warning / reminder.

Child labour & young workers
Permanova does not tolerate child labour, or that work is carried out through coercion or threat of violence as this is prohibited by Swedish law. The minimum age for employment is the age reached at the end of compulsory schooling.

Permanova will not directly hire workers under the age of 18 years old. The only exception is if temporary work is offered on an hourly basis as extra work to school children, e.g. to children of Permanova employees.

Wages and benefits
The company has a collective labor agreement for all its workforce which regulates that those wages and benefits are up to normal market conditions. The company has in addition other benefits like participation in healthcare programmes.

Working conditions
The necessary conditions for a safe and healthy working environment shall be provided to all employees. This shall be ensured through the work with SAM.

Freedom of association and collective bargaining
Freedom of association and the right to collective bargaining and agreements shall be respected through compliance with Swedish law.

Working hours
Working hours are regulated in the collective labor agreement which the company follows.

Resource efficiency
Permanova Lasersystem AB's production processes are designed in a way that efficiently utilizes energy and raw materials and minimizes waste and residues. When replacing the
components of the production process, new ones shall be chosen taking this principle into account.

Precautionary principle
Permanova Lasersystem AB applies the precautionary principle by avoiding materials and methods that may pose environmental and health risks, when suitable alternatives are available. Regular review shall take place in the framework of work on ISO 14001.
Environmental performance
Permanova Lasersystem AB regularly conducts auditing, monitoring and reporting of environmental within the framework of ISO 14001 which the company is certified by. This is aimed at constantly improving environmental performance.

Responsible sourcing
Responsible sourcing is to conduct purchases in a way which allows the company to identify the risk that violations of human and workers’ rights, environmental legislation or anti-corruption legislation. The suppliers should be informed of Permanova’s Code of Conduct policy. All our suppliers shall follow our policies and Code of Conduct and we reserve the right to terminate our contracts with our suppliers if non-compliance is detected.
Permanova does not buy minerals or metals but purchases components and parts. Permanova aims to only source components and parts from responsible suppliers are not sourcing products normally related to conflict areas but buys mainly “non-conflict materials” such as aluminum, glass/silica, copper and steel.

Obedience to laws
Permanova Lasersystem AB shall comply with the laws and regulations that apply to the business, and according to the commitment in ISO 14001.
In situations where the legislation does not provide any management, the company's own standards based on the principles of this Code of Conduct are applied. If the principles of this Code of Conduct are contrary to mandatory law, the law shall apply.

Relationships with business partners
Permanova Lasersystem AB's relations with business partners are characterized by impartiality. The Company or its representatives shall not offer customers, potential customers, governments, government agencies or representatives of such agencies any rewards or benefits that violate applicable law or reasonable and accepted business practices.

Permanova Lasersystem AB's employees may not accept payments, gifts or other forms of compensation from a third party that may affect, or which may be perceived to affect, the objectivity of business decisions.

Accounting and reportingPermanova Lasersystem AB's financial transactions must always be accounted for in accordance with generally accepted accounting principles and Swedish law. The ledger must show the nature of the transactions correctly and non-misleadingly. The accounts shall be transparent, truthful, relevant, understandable and published at the required time.

Conflicts of interest
Employees and directors of Permanova Lasersystem AB shall handle private or other external activities and financial interests in a manner that is not contrary to, or may be perceived to be contrary to, the company's interests.
In the event of such a conflict, the person subject to the conflict must immediately report this to the CEO.

Political engagement
Permanova Lasersystem AB takes a neutral position with regard to political parties and candidates. Neither the name nor the assets of the company may be used to promote the interests of political parties or candidates.
Communication with stakeholders
Permanova Lasersystem AB conducts an ongoing dialogue with the company's stakeholders, e.g. via monthly information to its owners, banks and auditors.

Anti-Money laundering

Money laundering means exchanging money or assets that were obtained criminally for money or other assets that are ‘clean’. Examples of money laundering can be:
• conducting a financial transaction which involves criminal property
• the concealment or disguise of the true nature, source, location, disposition, movement, rights-with respect to, ownership or control of criminal property
• the acquisition, possession or use of criminal property-promoting the carrying on of unlawful activity

Where any suspicions arise that criminal conduct may have taken place involving a customer, colleague or third party, you should consider whether there is a risk that money laundering or terrorist financing has occurred or may occur. Some examples can be:
• A customer provides insufficient, false or suspicious information or is reluctant to provide complete information
• Methods or volumes of payment that are not consistent with the payment policy or that are not customarily used in the course of business, e.g., payments with money orders, traveller’s checks, and/or multiple instruments, and payments from unrelated third parties
• Receipts of multiple negotiable instruments to pay a single invoice-Requests by a customer or partner to pay in cash
• Early repayments of a loan, especially if payment is from an unrelated third party or involves another unacceptable form of payment
• Orders or purchases that are inconsistent with the customer’s trade or business-Payments to or from third parties that have no apparent or logical connection with the customer or transaction
• Payment to or from countries considered high risk for money laundering or terrorist financing-Payments to or from countries considered to be tax havens or offshore jurisdictions
• Payments from countries unrelated to the transaction or not logical for the customer-A customer’s business formation documents are from a tax haven, or a country that poses a high risk for money laundering, terrorism or terrorist financing not logical for the customer
• Overpayments followed by directions to refund a payment, especially if requested to send the payment to a third party

Responsibilities of managers and employees
The respective responsible manager at Permanova is responsible for informing and presenting the content and spirit of this document within its area of responsibility.
Employees should be encouraged to report behavior that is not consistent with theseprinciples. Explicit or implicit acceptance of questionable acts will not be tolerated.

Violations of this Code of Conduct may be reported anonymously and confidentially via an anonymous deviation report that can be printed through the usual non-compliance reporting programs internally and submitted to the Human Resources Manager. Persons who report such crimes in good faith are not liable to penalties.

This Code of Conduct shall be applied promptly and continuously. Non-compliance with the rules may lead to disciplinary action.

This Code of Conduct has been adopted by the Board of Directors of Permanova Lasersystem AB and can only be amended or revoked by the Board of Directors. Any additions or changes will be notified.

Fair competition and anti-trust policy
The policy is valid for Permanova and applies to all our employees as well as consultants. It also applies to business partners such as suppliers as well as and other third parties.

Permanova believes in fair trade and honest competition based on integrity, product quality, price and customer service and it should be the base in our day-to-day business practices.

The consequences of breaching antitrust laws are very serious where authorities can impose fines, agreements may be void and damages actions from private parties negatively affected by anti-competitive behavior is both common and costly. In addition, antitrust violations have a negative impact on a company’s reputation, as well as triggering criminal liability for individuals, leading to fines, imprisonment and director disqualification in some jurisdictions. All Permanova employees are expected to understand and conduct their activities in strict accordance with this Policy and the antitrust laws.

Permanova will not engage in any of the following practices
• price fixing – agreeing formally or informally with anyone outside Permanova the prices we charge to our customers (or the discounts or other terms we offer)
• market sharing – allocating territories, customers or markets between Permanova and anyone outside Permanova
• bid rigging – agreeing with anyone outside Permanova the terms on which Permanova will (or will not) take part in any tender process

Dos and don’ts

DOS
Do proceed very carefully whenever interacting with competitors (in meetings, e-mails, calls, socializing, etc.).
Do react to anti-competitive offers or suggestions to make it very clear that Permanova does not wish to be involved. End the discussion or contact and ensure that your responses are kept on file.
Do seek legal advice before cooperating with a competitor in a strategic alliance, joint tender or sub-contracting arrangement.

DON’T
Do not discuss pricing or other commercial conditions with competitors. This includes timing, rebates, discounts or any other such strategic parameters. The same rules apply to bidding situations, e.g. who should bid and how.
Do not discuss and agree to share customers, volumes, supplies or divide geographic markets with competitors.
Do not discuss, agree or exchange information on bidding strategies with competitors. Tender preparation and submission should be an independent process. No sensitive information should be exchanged.
Do not agree bidding schemes with competitors.