Business ethic policy

In Adapt's operations, all employees are expected to act responsibly and ethically. This policy and its accompanying guidelines provide information and guidance on how employees should act on business ethical issues.

Anti-corruption

Adapt does not tolerate any form or expression of corruption.

Employees may not give, promise, offer, request or take receive compensation or benefits contrary to applicable law, good business practice or that may affect, or be perceived to affect, the objectivity of decisions. All the management of gifts, representation and other benefits shall be transparent; moderation and responsibility. An employee can receive a gift from an external as a customer or supplier/partner and which is of a one-off nature and does not exceed SEK 450 [recommended amount limit for bribe]. An employee may: never receive money or any kind of commission or kick-back, regardless of the amount.

There may also be a risk of corruption when other persons or companies acting on adapt's behalf. Employees should therefore take special control and precautionary measures before and in cooperation with subcontractors partners.

Competition

Employees may not participate in any form of agreement, contacts or actions with the aim or results of preventing, restricting or distort competition. Employees shall maintain contacts with competitors with: respect and caution, as well as in a way that ensures a good business ethics and compliance with competition rules. Are you unsure about general or specific competition rules, you have a duty to find out what applies.

Marketing

Employees shall present Adapt's products and services in a correct and fair manner . All marketing shall be designed in one responsible, relevant and truthful manner and be done in accordance with applicable good marketing practice and legislation, not least rules relating to personal data protection (mainly GDPR).

Conflicts of interest

Employees should avoid contexts where their own, relatives' or friends' interests may risk conflicting with what is best for Adapt. Private interests and external activities shall not affect or be able to: perceived to affect an employee's judgment or behaviour when performing their work for Adapt.

Where there is, or is suspected, a risk of conflict of interest, the immediate manager shall be informed and responsible for taking appropriate measures. Are a management person and/or owner in question, the company's chairman of the board is consulted. Where a conflict of interest is suspected, the employee concerned, not be involved in or make decisions in the adapts case bill.

Information management

Information about Adapt's operations should always be handled with good judgment and caution.

Information that is business critical, valuable or sensitive toAdapt shall be considered confidential. When exchanging with an external party, in particular: supplier or partner, a non-disclosure agreement should always be concluded.

Processing of personal data

Adapt's processing of personal data shall take into account: protection of privacy and in accordance with applicable law. Processing may only take place if there is an explicit stated purpose and legal basis for the processing. All forms of personal data processing shall follow relevant and necessary legislation and regulations, such as gdpr.

Tax and money laundering

Adapt shall comply with applicable tax and measures laws and regulations anti-money laundering. Employees must not accept, support or facilitate tax violations and money laundering.

Circumstances to be considered as warning signs are if: counterparty proposes that payments be made in cash or using unusual currency, if the proposed business arrangement appears to be unjustified or excessive complex or if requests are made to involve countries that are unconnected to the store. In all cases where there is doubt or if the counterparty does not wish to complete information, the Company's Board of Directors shall always be consulted for decision or in order to take action.

In case of doubt

If any kind of hesitation arises in connection with a transaction or an assignment that is suspected of touching or threatening Adapt business ethics, the precautionary principle and the company's management and/or board of directors are consulted. An employee, regardless of position, acting on its own in case of doubt, may become personal responsible for negligence.

It is the responsibility of each company manager to ensure that quality assurance of the work. The Company's Board of Directors has a special responsibility to: ensure that Adapt's business ethics are of a high and consistent level and that it is and develop in a good way.