Code of Conduct

Leden Group

Leden Group
Code of Conduct

This Code of Conduct applies to Leden Group and its subsidiaries. In Leden Group we expect everybody to comply and act in accordance with this Code of Conduct and its underlying policies, rules and regulations. We also encourage our employees and stakeholders to raise any concerns that they might have and to highlight good practices.

General

Leden Group is a full-service contract manufacturer with roots in Finland and Estonia. Comprehensive production services, extensive competence in the entire process and our smart added-value services make us the most inspiring contract manufacturer in Northern Europe.

Our Vision is to be a preferred partner.

Our Mission is to improve our stakeholders´ lives. That Mission is the basis of our strategy, and it means we do more for the customer.

Our Values are to Cooperate with all stakeholders, to be Accountable for giving our best in all our activities and to Respect and be fair to our colleagues, customers and our partners, together with maintaining high Environmental, social and governance standards. We CARE.

Our Code of Conduct applies to all Leden Group employees and operations regardless the position or location. It determines our daily work behaviour and sets out the principles for responsible and ethically sound decisions.

Labour standards and human rights

Leden Group is committed to respecting human and labour rights within the UN Declaration of Human Rights as well as the UN Global Compact and International Labour Organization’s principles (ILO).

We are also committed to ensuring that to support and respect human rights, our products do not contain conflict minerals.

This Code of Conduct is based on these and other internationally recognized standards.

Child labour
Leden Group has zero tolerance for child labour. All employees are over the minimum legal working age of the country  in which they work. We expect all organizations that do business with us to be committed to these principles.

Forced labour
Leden Group has zero tolerance for forced or compulsory labour. The working relationship with Leden Group employees is freely chosen and free from threats. We expect all organizations that do business with us to be committed to these principles.

Employment practices and hiring
Leden Group provides a safe and inspiring working environment for all its employees. We respect each other and we know that our employees, with different backgrounds and skills, are the guarantee of our success. We treat all employees fairly and equally.

Leden Group respects the value of diversity and fair treatment, together with equal opportunity for the recruitment, remuneration, development and promotion of

employees. Our employees are chosen based on their achievements, qualifications, merits and skills.

We have zero tolerance for discrimination in requirements, remuneration, development and promotion of employees, regardless of age, gender, ethnic or national origin, language, marital or parental status, political opinion or union membership, religious beliefs, sexual orientation or disability.

Freedom of engagement
Leden Group recognizes the fundamental right to freedom of expression and the rights of employees to participate as individuals in, for example, political activities based on local laws and regulations. However, it should be made clear that personal opinions and views are personal and do not represent those of Leden Group.

Harassment
Leden Group has zero tolerance for any form of harassment, whether it be sexual, mental or physical violence or bullying towards employees or business partners.

Respect for the law

Leden Group is committed to full compliance with applicable national and international laws and regulations. We also expect all our suppliers and business partners to comply with applicable legislation.

Relations to national laws
Leden Group strives to maintain the highest ethical and legal standards. We actively follow up compliance with national and international legislation and regulations. We do not accept any violation of applicable laws and regulations from our employees, suppliers and partners.

Legislative follow-up and awareness in all activities
Leden Group ensures that its employees are familiar with the applicable laws and regulations related to their daily activities and responsibilities. Managers and supervisors must ensure knowledge of, the availability of, and compliance with applicable regulations. We expect the same from all our suppliers and business partners.

Legislation concerning the status of the environment, employees, equality, freedom of association, occupational and product safety, the protection of competition, consumers and customers, and the prevention of bribery and corruption are important to us. Through good corporate governance, Leden Group complies with its operating environment.

Health and safety

Leden Group is committed to operating according to the strictest health and safety regulations and standards. The wellbeing and safety of our employees is important to us. Our target is zero hazards. All our factories are already or will be ISO 45001 certified.

Safe working environments
Leden Group strives to provide a healthy and safe workplace. We continuously work to prevent accidents and injuries to by identifying health and safety risks and taking corrective action. We are responsible for a healthy and safe workplace.

We provide a workplace which permits a balance between work and family life and  the different stages of life are taken into consideration.

Consideration and communication of health and safety obligations
We encourage our employees to take care of their own safety and conduct their daily activities without endangering their own safety or that of co-workers, the worksite of the community in their daily work. We expect our employees and everyone we work with to follow and respect health and safety laws and regulations as well as Leden Group commitments and requirements.

We encourage our employees and partners to report all incidents, close calls and safety or health risks. All Leden Group employees should know and follow local OHS policies and instructions. We ensure that our employees are trained for safe work and we do not do anything that is not safe.

We are a drug-free and alcohol-free workplace. Working under the influence of drugs or alcohol is prohibited.

Environment and quality

Leden Group is committed to operating in an environmentally responsible manner. All our factories are ISO 14001 certified.

Minimizing environmental impacts
Leden Group is committed to operating in an environmentally sustainable way. We use materials and natural resources efficiently and we strive to minimize our environmental impact by continuously developing and improving our processes.

Consideration and communication of environmental obligationsf
We encourage our employees to work in  an environmentally friendly way. All our employees are aware of and comply with our QEHS commitments and requirements.

We comply with relevant legislation and contribute to global sustainability

We encourage our employees and partners to report any violations regarding our environment.

Ensuring product quality
Leden Group is committed to continuous improvement activities to ensure product quality and safety. We take our customers’ expectations and requirements into account in all our operations, with lean principles.

We listen to our customers and appreciate their feedback. By complying with industry standards and maintaining high level of quality and process control, we strive to avoid any quality problems. If such problems occur we take all the necessary action to find the root causes and to implement corrective measures to prevent recurrence.

 

Ethical principles

Leden Group operates with the highest level of business ethics. We respect the applicable laws and regulations in every action and every location where we working.

Leden Group´s Code of Conduct is never in conflict with existing legislation and we set even higher standards.

We do not accept any corrupt activities including bribery and we avoid conflicts of interest. We protect our own and our stakeholders´ confidential information, intellectual property and assets.

Corruption
Leden Group has zero tolerance for corruption and bribery. We do not sponsor any activities that conflict with Leden Group´s principles and values. We operate in compliance with laws and regulations against corruption, money laundering and terrorism.

We refuse to make any donations or payments to political parties or individual politicians.

Gifts and improper payments
At Leden Group, we do not accept or give any gifts expect those considered to be reasonable hospitality in the ordinary course of business. We comply with all legislation concerning the giving or receiving of entertainment and gifts. We do not accept or offer bribes. Any gifts, entertainment or other personal benefits that might influence our decisions or business relationships or damage the reputation of Leden Group stakeholders are prohibited.

Conflict of interest
Leden Group avoids situations where private interests may conflict with the interests of Leden Group. We expect our employees to promote the interests of Leden Group and by acting responsibly to avoid activities which lead to a conflict of interest.

We do not accept the gaining of personal benefit by employees regardless of their working position. We take into account conflict of interest of our stakeholders, when we are making decisions. If such conflicts appear or might develop it is our employees’ duty to inform or consult their supervisor in writing.

Confidential information
It is Leden Group’s and its employees’ responsibility to protect the confidentiality of our own and our stakeholders’ confidential business-related information from any misuse or third-party awareness. We ensure that confidential information can be accessed only by those who need it in their daily work and we avoid discussing it in shared spaces and with third-party stakeholders.

We respect our own and others’ intellectual property and assets.

Transparency of operations
Leden Group avoids situation in which private interest may conflict with the interests of Leden Group. We expect our employees to promote the interests of Leden Group and, by acting responsibly, they avoid activities which would lead to a conflict of interest.

We do not accept the gaining of personal benefits by employees regardless of their working position. We take into account conflicts of interest of our stakeholders when we are making decisions. If such conflicts appear or might be develop, it is our employees’ duty to inform or consult their supervisor in writing.

Monitoring and reporting of obligations
Leden Group continuously follows up the implementation of the Code of Conduct. All concerns will be handled duly with continued improvement of business practices in mind.

Communications

Leden Group encourages you to voice your concern and it is our responsibility to maintain Leden Group’s Code of Conduct. If any violation occurs, it must be reported. Contact your manager in order to speak up and report a matter, we are all obligated to do. All concerns are taken into account and reviewed and the notifier is protected.

General
At Leden Group, all communication no matter what channel we use must be in line with Leden Group’s Code of Conduct and values.

We communicate Leden Group’s Code of Conduct principles to our employees, supervisors, suppliers and business partners. We expect all our stakeholders to operate according to this Code of Conduct. Any violations may result in disciplinary action or jeopardize the business relationship with Leden Group, up to and including termination of contract.

Your concern
If any violations occur, please contact your supervisor or HR Manager, or make a private OHS report via Leden Group’s Sharepoint.

A whistleblowing channel is coming soon.

Non-compliance
Violations of the Leden Group Supplier Code of Conduct can be reported confidentially in any of the following ways:

By telephone….

Website….

Mail…..

Leden Group
Supplier Code of Conduct

This Code of Conduct applies to all suppliers and partners that provide products or services to Leden Group and its subsidiaries.

Leden Group requires suppliers and partners and their employees to comply with this Code of Conduct when doing business with Leden Group and its subsidiaries.

General responsibilities

Leden Group suppliers must comply with this Code of Conduct including with the laws, regulations, rules and Leden Group policies in the locations and countries in which they operate.

Suppliers are expected to be familiar with the business practices of their suppliers and partners and suppliers are responsible for ensuring that they operate according to this Code of Conduct.

Leden Group may terminate co-operation with suppliers who fail to comply with this Code of Conduct.

Key expectations

Labour and human rights and the environment

Labour standards and human rights
Leden Group is committed to respecting human and labour rights within the UN Declaration of Human Rights as well as the UN Global Compact and International Labour Organization’s principles.

We are also committed to ensuring that to support and respect human rights, our products do not contain conflict minerals.

This Code of Conduct is based on these and other internationally recognized standards.

Child labour
Leden Group has zero tolerance for child labour. All employees are over the minimum legal working age of the country in which they work. We expect all organizations that do business with us to be committed to these principles.

Forced labour
Leden Group has zero tolerance for forced or compulsory labour. The working relationship with Leden Group employees is freely chosen and free from threats. We expect all organizations that do business with us to be committed to these principles.

Employment practices and hiring
Leden Group provides a safe and inspiring working environment for all its employees. We respect each other and we know that our employees, with different backgrounds and skills, are the guarantee of our success. We treat all employees fairly and equally.

Leden Group respects the value of diversity and fair treatment together with equal opportunity for the recruitment, remuneration, development and promotion of

employees. Our employees are chosen based on their achievements, qualifications, merits and skills.

We have zero tolerance for discrimination in the requirements, remuneration, development and promotion of employees regardless of age, gender, ethnic or national origin, language, marital or parental status, political opinion or union membership, religious beliefs, sexual orientation or disability.

Harassment
Leden Group has zero tolerance for any form of harassment whether it be sexual, mental or physical violence or bullying towards employees or business partners.

Respect for the law
Leden Group is committed to full compliance with applicable national and international laws and regulations. We also expect all our suppliers and business partners to comply with applicable legislation.

Health and Safety
Leden Group is committed to operating  according to the strictest health and safety regulations and standards. The wellbeing and safety of our employees is important to us.  Our target is zero hazards. All our factories are already or will be ISO 45001 certified.

Safe working environment
Leden Group strives to provide a healthy and safe workplace. We continuously work to prevent accidents and injuries by identifying health and safety risks and taking corrective action. We are responsible for a healthy and safe workplace.

We provide a workplace which permits a balance between work and family life and the different stages of life are take into consideration.

Environment
Leden Group is committed to operating in an environmentally sustainable way. We use materials and natural resources efficiently and we strive to minimize our environmental impact by continuously developing and improving our processes.

We encourage our employees to work in an environmentally friendly way. All our employees are aware of and comply with our QEHS commitments and requirements.

We comply with relevant legislation and contribute to global sustainability. Our suppliers must provide information about prohibited and restricted substances (REACH, RoHS, etc.) in their products

We encourage our employees and partners to report any violations regarding the environment.

Ethics

Gifts and improper payments
At Leden Group, we do not accept or give any gifts expect those considered to be reasonable hospitality in the ordinary course of business. We comply with all legislation on giving or receiving entertainment and gifts. We do not accept or offer bribes. Any gifts, entertainment or other personal benefits that might influence our decisions or business relationships or damage the reputation of Leden Group stakeholders are prohibited.

Conflict of interest
Leden Group avoids situations where private interests may conflict with the interests of Leden Group. We expect our employees to promote the interests of Leden Group and, by acting responsibly, to avoid activities which lead to a conflict of interest.

We do not accept the gaining of personal benefits by employees regardless of their working position. We take into account the conflicts of interest of our stakeholders, when we are making decisions. If such conflicts appear or might develop. it is our employees’ duty to inform or consult their supervisor in writing.

Confidential information
It is Leden Group’s and its employees’ responsibility to protect the confidentiality of our own and our stakeholders’ confidential business-related information from any misuse or third party awareness. We ensure that the confidential information can be accessed only by those who need it in their daily work and we avoid discussing it in shared spaces and with third party stakeholders.

We respect our own and others’ intellectual property and assets.

Transparency of operations
Leden Group competes fairly and strives for open competition and free markets. We act as a good corporate citizen in all our operations and locations. Our communication is accurate, fact-based and honest.

We do not enter into any cartel-like activities with our competitors including pricing, market shares or other similar activities.

Supplier Management System
Leden Group expects suppliers to have a management system which ensures they comply with applicable laws, regulations and Leden Group policies conform to this Code of Conduct and identify and reduce all operational risks related to this Code.

Quality, Environmental and Occupational management systems, such as ISO 9001, 14001 and 45001, are highly recommended.

Communication
At Leden Group, all communication no matter what channel we use, must be in line with Leden Group’s Code of Conduct and values.

We communicate Leden Group’s Code of Conduct principles to our employees, supervisors, suppliers and business partners. We expect all our stakeholders to operate according to this Code of Conduct. If any violations occurs, it may result in disciplinary action or jeopardize the business relationship with Leden Group, up to and including termination of contract.

Contact information

Your concern
Leden Group encourage you to voice your concern and it is our responsibility to maintain Leden Group’s Code of Conduct. If any violation occurs, it must reported. Get in touch with your contact person in order to speak up and report a matter, as we are all obligated to do. All concerns are taken into account and reviewed and the notifier is protected.

Non-Compliance
Violations of the Leden Group Supplier Code of Conduct can be reported confidentially in any of the following ways

Whistleblowing coming soon

By telephone–coming soon

Website-coming

Mail-coming soon

Leden Group Conflict Minerals Policy

Leden Group is committed to respecting human and labour rights within the UN Declaration of Human Rights as well as the UN Global Compact and International Labour Organization’s (ILO) principles.

We are also committed to ensuring that, to support and respect human rights, our products do not contain conflict minerals.

We provide our customers with products and services that are produced responsibly, as stated in our Code of Conduct

We are committed to full compliance with applicable national and international laws and regulations. We also expect all our suppliers and business partners to comply with applicable legislation.

Leden Group respects and supports human rights and we ensure that our products and processes do not contain conflict minerals as defined by the EU Conflict Minerals Regulation and Section 1502 of the US Dodd-Frank Act regarding conflict minerals.

Leden Group does not directly source conflict minerals for its products and processes. We expect all the materials and components from our suppliers to be free of conflict minerals.

We will do our best in identifying processes, products and suppliers impacted by the conflict minerals regulation.

Compliance with our Conflict Minerals Policy and our Code of Conduct determines our procurement decisions.

We expect our suppliers to have a conflict minerals policy and we exercise due diligence in investigating the source of these minerals. We request our suppliers to provide a Conflict Minerals Template supplied by the Responsible Minerals Initiative (RMI).

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