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Ethical operating guidelines

1. Our way of working

We operate according to our values.

By operating in a responsible and sustainable manner we ensure that SRV’s customers, subcontractors and other partners will continue to consider us as a desirable and reliable partner.

Our values – sustainability, enthusiasm, profitability, bold in development and open in cooperation – form the basis of these ethical operating guidelines. Our ethical operating guidelines constitute our approved operating guidelines, which define the principles by which we make decisions, act and behave in all situations.

All of SRV’s companies, Board members, management and employees are obligated to comply with our ethical operating guidelines – regardless of their position.

We also seek to get third parties, such as subcontractors and other partners, to commit to our ethical operating guidelines, or to ensure that they apply corresponding practices in their own activities.

2. Compliance with legislation and regulations

Compliance with legislation and regulations is everyone’s business.

SRV complies with legislation and regulations in all of its operations and requires the same of its employees, subcontractors and other partners.

We are committed to act in a right way.

3. Sustainable and responsible operations

Responsibility is about caring. Sustainability and responsibility can be seen in all of our operations. Excellent customer experience and maintaining trust are of the highest importance to us.

SRV is committed to operating responsibly and sustainably. In accordance with our sustainability programme, we are a responsible actor in the society, we provide high-quality construction and sustainable environments and spaces, we are a safe workplace supporting personnel wellbeing, and we have a reliable and cooperative partner network.

Excellent customer experience is one of our main goals. We want to earn our customers’ trust by operating openly and through high quality and safe construction.

Sustainable and responsible operations generate added value for our business and increase wellbeing in the society. We listen to our stakeholders and take their opinions into account when developing our operations.

Sustainability is part of our strategy, and everyone at SRV has a duty to promote compliance with our sustainability programme in their own work. We also encourage our subcontractors and other partners to promote our sustainability programme in their work.

4. The environment

We reduce the environmental impact of our activities and construction sites by taking environmental aspects into account in all our operations. We consider the environmental impact of buildings throughout their entire lifecycles.

Developing more sustainable construction methods that are better for the environment is important in terms of SRV’s values and operating model. We are committed to developing our sustainability related activities and reporting on the impact of our operations.

We continually develop our operations in order to reduce harmful environmental effects. Our key objective is to optimise material efficiency and enhance waste management on our construction sites.

An environmental plan is drawn up for all our Finnish construction sites. The plan, which everyone working at the site has to follow, is a part of SRV’s quality management system. In our own construction projects, we define project-specific environmental targets together with our customers.

We comply with environmental legislation, permits and other regulations under all circumstances, and we require the same of our subcontractors. We encourage all of our partners to continuous development of environmentally sustainable operating methods.

5. Safe working conditions

We look after our own safety and the safety of our colleagues. We are familiar with site safety guidelines and committed to act according to the guidelines and other instructions we receive. We immediately report any deviations regarding occupational safety in order to avoid accidents and injuries and to continuously develop our operations.

SRV’s goal is to be a pioneer in safe construction. We are committed to offering all our employees and subcontractors a safe workplace. Our long-term objective is to achieve a zero-accident level. Everyone working on our construction sites is obliged to take care of both their own safety and that of others. All observations relating to deficiencies in occupational safety must be reported immediately.

On-site safety is based on preventive measures, induction training, and strict compliance with safety legislation and instructions. The grey economy and economic crime have negative effects on occupational safety risk management. Transparency and knowing your business partners are therefore important requirements for promoting occupational safety.

SRV’s corporate safety objective is to ensure uninterrupted operations under all circumstances. We maintain a safe working environment for all of our personnel, both in offices and on construction sites. Proactive measures seek to prevent all potential damage, disturbance, crime and vandalism.
6. Data security and privacy protection

We keep SRV’s and our customers’ confidential information strictly confidential. We handle personal data as privileged. We respect personal privacy and use personal data only for purposes permitted by law.

SRV’s trade secrets and other confidential information are part of the company’s valuable intangible assets and must therefore be appropriately protected and used only for the company’s benefit.

We comply with SRV’s data security policies and act with sufficient caution and care when handling data and using IT systems.

All customer data and personal data are protected and kept confidential. SRV has defined specific purposes for which the data can be used for each personal data register and personal data will only be collected and used for purposes permitted by law.

7. Equality, non-discrimination, and respecting human rights

We maintain a good working atmosphere. We treat each other fairly and with respect. We respect human rights.

Everyone at SRV is treated equally regardless of gender or gender identity, language, religion, nationality or ethnic origin, opinions, family relations, age, union or political affiliations, and health. Discrimination or harassment is not tolerated under any circumstances.

We adhere to a principle of equality in recruitment, task definition and transfers to other tasks, ending employment contracts, payroll administration, and planning training. SRV is committed to promoting equality within the working community.

SRV is committed to respecting and promoting internationally recognised human rights in all of its operations. We will not tolerate violation of human rights in any form, and take steps to ensure that our subcontractors and other partners are also committed to respecting human rights.
8. Relations with business partners

We know who our partners are. We only deal with reputable and reliable partners.

SRV works only with reliable and reputable partners in Finland and abroad.

We conduct reliable background and business checks of our subcontractors and other partners before commencing cooperation in order to prevent e.g. money laundering and funding terrorism.

9. Combating the grey economy

We combat economic crime and the grey economy. Before signing any contracts, we make sure that our partners are fulfilling their social obligations.

SRV works to combat the grey economy. We are continually developing our operating methods and new tools to ensure the manageability and transparency of our entire operating chain, compliance with law and the safety of our construction sites.

SRV seeks openness in its relationships with subcontractors and other business partners. We cooperate with established subcontractors and partners, who commit to agreed operating methods and can demonstrate the sustainability of their operations. We supervise our subcontractors and partners and provide them training and support for implementation of common working methods.

In the management of new suppliers and existing supplier relationships, we adhere to SRV’s procurement procedures and make use of the SRV Network Register.

10. Fair competition

We support fair and undistorted competition. We comply with competition laws in our operations.

We act in the market where effective competition promotes the development of the industry as a whole and benefits all industry stakeholders.

We refuse to discuss or fix pricing, market shares with our competitors or be engaged in other activities that restrict competition. We do not use unethical business methods.

We require the same from our subcontractors and other partners.

11. Procurements

We make responsible procurements and ensure the highest possible level of sustainability throughout the lifecycle of our products.

In procurements, we are committed to operating responsibly and sustainably throughout the lifecycle of our products. We proactively monitor and predict market changes and evolving sustainability requirements.

In order to reduce risks and ensure that requirements are met, the quality of materials sourced from outside Finland (international procurement) is assured by third party audits.

12. Conflicts of interest

At work we make decisions always in SRV’s best interest. We avoid situations in which our own interests could be in conflict with SRV’s interests.

We act loyally and in the best interest of SRV. We use SRV’s property and resources for the sole benefit of the company. Both at work and outside work, we avoid situations in which our personal interests could be in conflict with the company’s interests.

SRV employees may not engage in activities that compete with SVR’s business. Employees may not use internal information or their position, or any opportunities arising therefrom, for their own benefit or help others take advantage of such information or position.

13. Preventing bribery and corruption

We do not offer or accept bribes. Business-related hospitality should be moderate and of minimal value.

None of SRV’s employees may directly or indirectly accept or give a bribe. Any sort of gift or benefit which intends to affect the recipient’s actions can be considered as a bribe.

No person at SRV is allowed to accept or give gifts that could have influence on business-related decision-making. Business related hospitality should be moderate and of low value.

Complying with anti-corruption practices is an absolute requirement in SRV’s operations, and zero tolerance for corruption is required from SRV’s subcontractors and other partners.

14. Trading in securities

We comply with SRV’s insider guidelines and all applicable legislation on securities markets. Our actions promote confidence in both the company and the stock market.

SRV Group Plc’s shares are listed on Nasdaq OMX Helsinki’s main list. We provide our stakeholders information on our business activities and operating environment in order to enable them to form a correct and justified picture of our company. Our communication is timely, open and consistent.

All employees, management and the Board of Directors should act in a manner that maintains confidence in both the company and the stock market. Everyone at SRV must comply with our insider guidelines. The abuse of insider information is strictly forbidden.

15. Protecting our reputation

Every employee is an embodiment of SRV’s brand. We never act in a way that would harm SRV’s reputation or brand.

We promote the SRV brand in every encounter. We protect our company’s reputation and build an ever-stronger brand by operating in line with our values and ethical operating guidelines. We never act in a way that would harm SRV’s reputation or brand. We act appropriately and responsibly also in social media channels.

Compliance and reporting violations

Internalise the ethical operating guidelines and comply with them in all of your activities. Avoid any kind of behaviour that could lead to illegal activity, suggest inappropriate activity or damage SRV’s reputation.

If you observe or suspect any activity that contravenes SRV’s ethical operating guidelines, report it immediately. By reporting any potential violations, you help the company to intervene in problems before they can have an adverse impact on SRV’s finances or reputation.

Any observed or suspected activities may be reported confidentially. SRV has an Ethics Channel through which anyone can make such reports, either in their own name or anonymously. Additionally you can always discuss your observations with your supervisor or the legal department.

All observations relating to violations of ethical operating guidelines that are reported in good faith, will be investigated impartially. SRV is responsible for ensuring that employees do not suffer any unfavourable work-related consequences as a result of reporting such violations.

Any activities that are in conflict with the ethical operating guidelines must be rectified immediately. They will also lead to disciplinary actions, as last resort even termination of employment.

Before making a decision or taking action, ensure:

Is the action or decision legal?
Is it in line with our values and ethical operating guidelines?
In your opinion, has it been correctly and independently carried out?
How would it look from the outside if the matter were to become public knowledge?

If you are unsure, always check with your supervisor or the legal department.

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