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TransLegal Sweden AB’s Code of Conduct

We comply with all relevant legislation and rules

TransLegal complies with locally applicable legislation and the rules and regulations of relevant competent authorities in all their activities.

Each employee is entitled to a written employment contract, which is written in a manner and worded in a way that the employee understands. Wages, as well as procedures for how and when wages are to be paid, shall also be agreed in writing and paid regularly and on time.

The working week is 40 hours and all overtime work is consensual and duly remunerated. Only in exceptional circumstances shall the sum of regular and overtime hours exceed 60 hours.

Our products and services meet our customer’s needs

TransLegal should always strive to act in the best interests of its customers and offer products and services that customers need and want. The products and services should be fair and comprehensible and environmental, social and governance (ESG) considerations, including climate change, should be taken into account in product and service development.

Furthermore, TransLegal should ensure that all customers are treated equally and that no individual customer is given preferential treatment at the expense of other customers. The company also needs to ensure that suitable products are sold to each individual customer in line with their specific risk profile.

Sales, marketing, and product information must be professional, comprehensive, accurate, balanced, and never misleading. It should also be easy for customers to provide feedback and complain if they are dissatisfied.

Data privacy is a priority

TransLegal is committed to processing personal data in a lawful, fair, and transparent manner, while respecting human rights in all aspects of data management. The company should aim to ensure that the privacy of the employer, employees, customers, and other stakeholders is not breached.

We maintain high levels of information security

TransLegal is committed having effective internal controls, high-quality systems, and infrastructure to ensure information security. Requirements in relation to information security and cybersecurity are set and expected to be met.

 All TransLegal employees must adhere to the information security rules and guidelines, using appropriate tools, and acting responsibly at all times.

We do not disclose inside or confidential information

TransLegal prohibits employees, management, and members of the Board of Directors from engaging directly or indirectly in insider trading, or unlawfully disclosing inside information or other confidential information.

We do not engage in money laundering, terrorist financing, corruption, or bribery

TransLegal complies with the applicable local anti-money laundering and counter-terrorist financing rules and legislation, as well as various sanctions regimes that have been implemented by the United Nations (UN) and/or the European Union.

Corruption, the abuse of entrusted power for private and/or corporate gain, can take many forms, such as bribery, excessive business entertainment, facilitation payments (i.e., financial payments that are made with the intention of expediting an administrative process), kickbacks, extortion, fraud, and embezzlement. TransLegal Group does not accept any kind of conduct that could create the appearance of improper influence and expects its employees, customers, suppliers, and other business partners to behave in the same way. Employees must ensure that all payments to third parties are appropriate, for a legitimate business reason, and correctly recorded.

We respect human rights and treat everyone fairly

TransLegal complies with all applicable human rights, labor, and employment legislation and aims to prevent complicity in human rights violations and reports all human rights violations.

We respect each individual’s human rights and do not tolerate any kind of discrimination, bullying, harassment, or any other type of abusive behavior. All employees must be treated fairly and equally. Discrimination is strictly prohibited, for example, on the grounds of age, disability, ethnic origin, family commitments (including pregnancy), gender, gender identity, political attitude, employees’ representative activities, religion, sensitive medical conditions, sexual orientation, social background, or any other personal characteristics. We treat everyone fairly and equally. We respect freedom of association.

In addition, discriminatory practices regarding recruitment, job assignment, training and development, promotion, remuneration and other benefits, or general conduct in the
workplace, are not tolerated. TransLegal is also committed to gender pay equality. Ignorance and inaction do not constitute a valid excuse for discrimination.

We are committed to having appropriate health and safety standards

TransLegal complies with all local health and safety regulations and works to ensure high standards regarding safety and mental and physical health and is committed to reducing and preventing the number of work-related accidents and occupational diseases. In addition, employees have a duty to take every reasonable precaution to maintain a safe and healthy working environment and to avoid the possibility of personal injury or putting others at risk.

TransLegal respects employees’ freedom of association

TransLegal guarantees the effective exercise of trade union rights and employees must be free to join organizations of their choice that represent them and which are consistent with local laws.

The environment and the climate are important

TransLegal complies with the existing legislation and regulations regarding the environment and climate and has routines to minimise or eliminate emission of greenhouse gases as well as contamination and waste in production and transport. Local and regional environmental issues shall be taken into account.

Revised and Approved 2021