Lemminkäinen Group

This is the basis for our responsible work, taking into account the expectations of customers, our own personnel and other stakeholders.

Our values are sustainable growth and development, constructive co-operation, and respect and trust, and our operations must comply with them.

This Code of Conduct applies to all our business operations and defines common operating models for all of Lemminkäinen’s hourly paid employees, salaried staff, and members of the management. When necessary, the Code will be complemented by more detailed principles and instructions.

1. Observance of law

We abide by the legislation in force both in Finland and any other country we operate in.

The most important international regulations and conventions guiding our operations are

• The Universal Declaration of Human Rights
• The United Nations Global Compact initiative to promote human rights, labour rights, protection of the environment and prevention of corruption
• The International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work
• OECD’s Guidelines for Multinational Enterprises, and
• Recommendations of the International Chamber of Commerce (ICC).

Each of us must know the laws, regulations, and instructions concerning our own work and commit to them. Supervisors are in charge of any required employee orientation and monitor the obeying of laws, regulations and instructions.

2. Financial responsibility

Corporate governance
We shall obey the principles and recommendations for corporate governance in Finnish listed companies. These principles and recommendations define the duties and operational procedures of the Group’s administrative bodies. The principles and recommendations will be regularly updated.

Insider information
Lemminkäinen is a listed company. Some of us handle insider information, in other words accurate unpublished information not available in the markets with a potentially significant effect on the Lemminkäinen share price. Persons in possession of insider information are not allowed to trade in the company’s shares. Nor are they allowed to reveal the information or offer advice on securities trading as long as the information is not made publicly available in compliance with the regulations.

The law, official instructions and rules of the stock exchange define the restrictions on the use of insider information. Lemminkäinen also has guidelines for insiders to be observed by all persons in possession of insider information.

Promotion of competition
A large part of our work is about executing projects, which means we constantly draw up bidding documents and contracts, which fall under the scope of competition legislation. We shall comply with the competition legislation in force in all our operations. This applies to all our dealings with Lemminkäinen’s competitors and customers as well as industry organisations. Should confusions arise, contact your supervisor or the legal department.

Use Lemminkäinen’s guideline on competition legislation, which discusses competition-related matters in more detail.

Conflicts of interest
We work for Lemminkäinen, and thus our personal interests must not be in conflict with those of Lemminkäinen.

We shall not work for or participate in, directly or indirectly, a business enterprise competing with the Group or business activities of a party in a business relationship with Lemminkäinen, nor seek personal benefit in business relationships.

We shall not pay nor accept any bribes or any other illegal payments to commence or advance a business activity.

We shall not offer nor accept any courtesy or a gift or benefit which could be reasonably assumed to influence decision making in our business or which exceed the limits of normal hospitality.

Relationships with customers
Satisfied customers and long-term customer relationships form the basis for our future success. Our goal is to be the first choice of our existing and future customers. Therefore we shall make sure that our actions comply with the promises made to our customers.

We monitor customer satisfaction with regularly repeated surveys, collect customer feedback in various ways and use the information when developing our products and services.

Relationships with subcontractors, suppliers and other co-operation partners
We need many kinds of subcontractors, suppliers and other co-operation partners in our work. Open communication, honouring contracts and achieving mutual trust is of prime importance both for our success and the success of our partners.

We shall select our co-operation partners on objective grounds, no personal reasons whatsoever may influence our decisions. The quality, reliability, prices, delivering capacity, and operating models of our partners must comply with Lemminkäinen’s requirements.

We expect our partners to comply with the law and regulations and universal human rights, labour rights, and environmental regulations. We shall promote the compliance with principles in line with this Code of Conduct among our subcontractors and suppliers and monitor their operations in this regard.

Relationships with authorities and political decision makers
Regional planning, land use planning and various permitting procedures are key aspects of any operation in the construction industry. Openness and good co-operation with various actors is important to achieve the best possible results for end users when planning operations and implementing the plans.

We shall actively participate in the development of best practices for the construction industry and promotion of transparency. In co-operation, we shall observe the requirements of free competition, objectivity, correct and fair treatment, and uncompromised professional integrity.

Our communications with decision makers, authorities and political parties and actors shall be transparent, and it must not jeopardise the impartiality of the parties nor be liable to cause any conflicts of interests or suspicion of such.

Lemminkäinen’s property and confidential information
We shall take good care of Lemminkäinen’s property, making no unauthorised use of it.

We shall protect any confidential material and information entrusted to us by subcontractors, suppliers, customers and other co-operation partners with no less care than Lemminkäinen’s own confidential materials.

3. Social responsibility

It is our goal to offer one another a good, safe and inspiring working environment. Lemminkäinen’s supervisors are expected to actively promote a leadership culture in compliance with the company’s values and this Code of Conduct. Our personnel is encouraged to participate in interactive development of the work community, for example by responding to various surveys.

As required by our values, we shall pay particular attention to individual development, occupational health and safety, coping at work, and balancing work and leisure.

We shall treat the people working in and joining our Group fairly in the practices, principles and procedures related to employment and recruitment. We shall actively participate in the activities of labour market organisations and respect our personnel’s freedom of organisation and right to collective bargaining.

We shall not accept forced labour or use of child labour nor any treatment or working conditions in violation of the fundamental international labour rights.

We shall in all our employment practices commit to fair and equal treatment of our personnel. We shall not tolerate discrimination on the basis of race, national or ethnic origin, citizenship, skin colour, language, gender, age, family conditions, sexual orientation, state of health, religion, social opinions, political or professional activism, or any other comparable reason. We shall not tolerate any kind of harassment or bullying at work.

4. Environmental responsibility

Lemminkäinen’s aim is to achieve a leading role in environmentally respectful and sustainable construction.

We are all responsible for the environment for our own part. Working in a construction company, we have both a special duty and the possibility to constantly aim at lower construction-related environmental effects and to promote sustainable development in construction and related activities. We shall take environmental aspects into account in all our operations and decisions.

The management of our environmental activities shall comply with Lemminkäinen’s environmental policy, and we shall continuously develop our environmental systems, practices and indicators. We shall aim at constant improvement in environmental matters.

We shall provide our personnel with systematic training and guidance in environmental issues. We shall openly communicate our environmental efforts to our stakeholders and expect our subcontractors and contract partners to support the accomplishment of our goals through their own actions.

5. Communication and relationships with stakeholders

In our internal and external communication, we shall provide our stakeholders with accurate information on Lemminkäinen’s goals and activities. The general principles in our communication shall be trustworthiness, openness and speed. Our communication activities shall comply with the law, official regulations, stock exchange rules, and our own communication policy.

We shall actively participate in the development of society’s and our industry’s operational preconditions through business organisations.

Any donations, sponsorships, and other stakeholder co-operation must comply with our principles of responsible action and support the accomplishment of our goals.