Code of Conduct

Code of Conduct

❋ Intentional Structure

1. Purpose and Scope

This Code of Conduct sets forth the ethical guidelines, principles, and standards of conduct that apply to Elvate’s operations. Its purpose is to ensure that the company’s operations are conducted in accordance with applicable laws, good business practices, and high standards of integrity and accountability.

The Code of Conduct applies to all individuals acting on behalf of or representing Elvate, including but not limited to:

  • employees

  • senior executives

  • board members

  • consultants

  • contractor

  • temporary staff

All of the above are collectively referred to below as employees.

Employees are required to read, understand, and comply with this Code of Conduct in the course of their work.

2. Compliance with laws and regulations

Elvate shall conduct its business in full compliance with:

  • Swedish law

  • relevant EU legislation

  • regulatory requirements

  • industry standards

  • internal policies and guidelines

Employees are required to comply with the laws and regulations applicable to their area of work. If in doubt, they should seek guidance from their immediate supervisor or company management.

No employee may, through action or inaction, contribute to the company violating the law or other binding rules.

3. Business Ethics and Anti-Corruption

Elvate has a zero-tolerance policy toward corruption, bribery, and improper benefits.

It is prohibited to:

  • offer, solicit, or accept bribes

  • give or receive improper benefits with the intent to influence business decisions

  • use the company's resources for personal gain

Entertainment, gifts, and other benefits may only be provided if they:

  • are moderate

  • has a legitimate business purpose

  • are in compliance with the law and sound business practices

All business relationships must be characterized by transparency, integrity, and professionalism.

4. Conflicts of Interest

Employees should avoid situations where their personal interests may conflict with the company’s interests.

A conflict of interest may arise, for example, when:

  • an employee has a financial interest in a company that is a customer or supplier

  • Personal relationships influence business decisions

  • side jobs affect the objectivity or quality of the work

Employees are required to immediately inform their immediate supervisor of any actual or potential conflict of interest.

The company's management will decide how to handle the situation.

5. Workplace Environment and Equal Treatment

Elvate is committed to providing a safe, respectful, and non-discriminatory work environment.

The company does not accept:

  • discrimination

  • harassment

  • sexual harassment

  • bullying

  • discriminatory treatment

Discrimination based on, for example:

  • gender

  • gender identity or gender expression

  • ethnic background

  • religion or other belief

  • disability

  • sexual orientation

  • age

is prohibited.

All employees are expected to contribute to a professional, inclusive, and respectful work environment.

6. Information Management and Confidentiality

Employees must protect confidential information relating to:

  • the company

  • customers

  • suppliers

  • business partners

Confidential information must not:

  • be disclosed to unauthorized persons

  • used for personal gain

  • handled in a way that could harm the company or its business relationships

Personal data must be processed in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

The confidentiality obligation remains in effect even after employment or an assignment with Elvate has ended.

 

7. Protection of the Company’s Assets

The company’s resources and assets must be used in a responsible and businesslike manner.

This includes, among other things:

  • financial resources

  • equipment

  • IT systems

  • intangible assets

  • information and data

The improper use, misuse, or embezzlement of the company’s assets is prohibited.

8. Relationships with customers and suppliers

Elvate shall conduct its business relations in a professional and responsible manner.

The company shall:

  • treat customers and suppliers fairly

  • make business decisions based on objective and sound business principles

  • honor agreements and commitments

The selection of suppliers shall be based on criteria such as:

  • quality

  • expertise

  • price

  • sustainability

  • business ethics

9. Reporting of violations

Employees who suspect or become aware of violations of this Code of Conduct, laws, or internal policies should report this to:

  • immediate supervisor, or

  • the company's management.

It must be possible to report incidents without fear of reprisals.

Elvate does not tolerate any form of retaliation against anyone who reports suspected irregularities in good faith.

10. Accountability and Disciplinary Measures

Violations of this Code of Conduct may result in disciplinary action.

Depending on the nature of the violation, measures may include:

  • reminder or warning

  • labor law measures

  • termination or completion of an assignment

  • legal action

The company's management is responsible for investigating suspected violations.

11. Adoption and Updates

This Code of Conduct is established by the company’s management or board of directors and shall be reviewed regularly to ensure that it remains up to date and consistent with applicable laws and the company’s operations.

12. Entry into force

This Code of Conduct takes effect as of the date of adoption and remains in effect until further notice.

All Elvate employees must review this document and confirm that they will comply with its contents.