Code of conduct for suppliers

The purpose of the Netgroup Energy Code of Conduct for Suppliers is to define the general requirements of our suppliers.

1. Introduction

This Code of Conduct sets forth the requirements for all suppliers of Netgroup Energy Sweden AB (hereinafter referred to as “Netgroup Energy” or “we/our”). It is based on our own Code of Conduct and internationally recognized standards, including the UN Global Compact and the International Labor Organization’s (ILO’s) fundamental conventions.

The purpose of this Code of Conduct, together with Netgroup Energy’s own Code of Conduct, is to ensure that the entire supply chain—from all suppliers and subcontractors to our customers—complies with the laws, regulations, and industry standards set forth in this document.

Suppliers shall comply with the laws and regulations of the countries in which they operate, as well as the principles set forth in this document. Where this document establishes a higher standard than local law, this document shall apply unless doing so would result in illegal activity. Suppliers are required to communicate and promote these requirements throughout their supply chain.

2. Working Conditions and Human Rights

Netgroup Energy has a zero-tolerance policy toward any form of modern slavery, forced labor, or human trafficking within its operations or supply chain. Suppliers must ensure that all work is performed voluntarily and that no employee is subjected to coercion, exploitation, or involuntary labor under any circumstances.

We view respect for human rights and fair working conditions as fundamental to conducting business responsibly. We expect our suppliers—and their suppliers, in turn—to:

Comply with all applicable labor laws and regulations.
Prohibit child labor in accordance with ILO Conventions 138 and 182.
Eliminate all forms of forced labor, debt bondage, and human trafficking.
Provide written employment contracts in a language the employee understands, with wages and benefits that meet or exceed legal minimums or collective bargaining agreements.
Comply with applicable laws regarding working hours and rest periods.
Provide and maintain a safe and healthy work environment that meets all applicable legal standards.
Prohibit discrimination based on gender, ethnicity, religion, age, disability, sexual orientation, transgender identity, nationality, or any other protected characteristic.
Respect employees’ right to freedom of association and collective bargaining.
Be an equal opportunity employer.

3. Environmental Responsibility

Suppliers must comply with all applicable environmental laws and regulations and are expected to actively reduce their environmental impact throughout the value chain.

We expect our suppliers, and their suppliers in turn, to:

Apply the precautionary principle to actively avoid activities that may negatively affect the health or safety of people or the environment, take immediate action to remedy any negative consequences, and implement measures to prevent future occurrences.
Set measurable targets to reduce emissions, energy consumption, and waste; track progress accordingly; and work toward achieving them with the goal of establishing a circular economy.
Assess and reduce their climate impact, including greenhouse gas emissions, where applicable, in accordance with recognized frameworks such as the GHG Protocol or the Science Based Targets initiative (SBTi).
Handle chemicals and hazardous substances safely and replace them with less harmful alternatives whenever possible.
Source minerals and metals responsibly, ensuring full supply chain transparency and traceability for conflict minerals (3TG—tin, tantalum, tungsten, and gold) and cobalt.

Suppliers are encouraged to maintain an environmental management system to monitor and continuously improve their environmental performance.

4. Business Integrity

4.1 Anti-Corruption and Anti-Bribery

We have a zero-tolerance policy regarding bribery and corruption. Suppliers must conduct all business in accordance with applicable anti-corruption laws and must never offer or accept inappropriate benefits, including gifts, services, or hospitality intended to influence a business decision.

Particular caution is required when interacting with public officials, using agents or intermediaries, and in connection with donations or sponsorship activities. All records, reports, and invoices must be accurate, complete, and free from false or misleading information.

4.2 Conflict of Interest

Suppliers shall avoid situations in which personal interests may conflict with sound business judgment. Any actual or potential conflict of interest must be disclosed to Netgroup Energy promptly. Professional decision-making must remain independent of personal considerations.

In situations where a conflict of interest arises between businesses—such as a supplier’s engagement with an entity that competes with Netgroup Energy—this must be promptly reported to Netgroup Energy in writing. This also applies to employees’ outside employment and supplier engagements, as well as potential conflicts arising when working with clients that compete with one another or in situations where, for example, an engagement with a client conflicts with an engagement at a legal or regulatory body.

4.3 Fair Competition

Suppliers must comply with applicable competition laws and refrain from any agreements or arrangements that restrict or distort competition, including those relating to pricing, market shares, customers, or territories. The exchange of competitively sensitive information with competitors is also prohibited.

4.4 Ethical Business Practices and Human Rights Due Diligence

We are committed to conducting business in a responsible and ethical manner throughout our value chain. Suppliers must respect internationally recognized human rights and ensure that their operations and supply chains are free from any form of modern slavery, forced labor, or human trafficking.

Suppliers are expected to:

Prohibit all forms of forced labor, child labor, and human trafficking in their operations and throughout their supply chain.
Implement appropriate processes to identify, prevent, mitigate, and address risks related to human rights and labor conditions.
Conduct due diligence in their supply chain to ensure compliance with these principles.
Ensure that employees work voluntarily and are free to leave their jobs with reasonable notice.
Ensure that no recruitment fees or deposits are charged to employees.
Maintain transparency and, upon request, provide relevant information demonstrating compliance.

Failure to meet these requirements may result in corrective actions or termination of the business relationship.

4.5 Reporting Concerns

Suppliers are expected to report any suspected violations of this Code of Conduct or applicable laws. Further guidance is provided in Section 9.

Suppliers are expected to report any suspected violations of anti-corruption laws or this Code of Conduct.

5. Trade Sanctions and Export Controls

Suppliers must comply with all applicable trade sanctions and export control laws and regulations. This means no transactions with sanctioned countries, companies, organizations, or individuals. Export controls restrict the transfer of controlled goods, software, and technology without the required licenses.

Suppliers are responsible for ensuring their own compliance and that of their subcontractors. Violations can result in significant legal and financial consequences for all parties involved. Any actual or suspected violation must be reported promptly to Netgroup Energy and in accordance with applicable laws and regulations.

6. Confidential Information and Intellectual Property

All information and intellectual property shared in the course of a business relationship is confidential unless otherwise agreed in writing. Information shall be shared only with those who need it to perform their duties, and only to the extent necessary.

Upon completion or termination of the business relationship, all confidential information and data must be returned to the rightful owner or securely deleted, as agreed. Should any unauthorized disclosure occur, all affected parties must be notified immediately and an investigation initiated.

6.1 Artificial Intelligence (AI)

Suppliers may use artificial intelligence (AI) in their operations, provided that such use is responsible, secure, and compliant with applicable laws and regulations, while protecting confidentiality, integrity, and compliance.

We expect our suppliers, and their suppliers in turn, to:

Ensure that AI is used responsibly and with appropriate human oversight.
Ensure that AI-generated output is reviewed before use, where applicable.
Refrain from sharing confidential, sensitive, or proprietary information with AI tools without appropriate safeguards and authorization.
Do not use AI to create misleading, false, or deceptive information.

Suppliers are expected to monitor relevant regulatory developments and ensure that their use of AI remains in compliance with applicable legal and contractual requirements.

7. Data Protection

Suppliers must comply with the GDPR and all applicable data protection laws when processing personal data in connection with their operations. Suppliers must implement appropriate technical and organizational measures (TOMs) to ensure a level of security appropriate to the risk, including measures to prevent unauthorized access, accidental loss, destruction, or disclosure of personal data.

Suppliers that process personal data on our behalf must comply with the specific contractual provisions agreed upon. Any data security incident must be reported immediately to all relevant parties.

8. Monitoring and Continuous Improvement

Netgroup Energy monitors selected suppliers through structured self-assessments to ensure compliance with this Code of Conduct and to support continuous improvement. Suppliers are asked to complete questionnaires covering relevant areas of sustainability and compliance, including environmental impact. This Code of Conduct is part of Netgroup Energy’s management system and is integrated into our supplier evaluation processes.

Suppliers are expected to continuously improve their sustainability and compliance practices and, upon request, provide documentation demonstrating compliance with this Code of Conduct. These requirements apply throughout the supply chain, and suppliers are expected to ensure that their subcontractors meet equivalent standards.

As part of its supplier follow-up process, Netgroup Energy will request that selected suppliers conduct self-assessments of their carbon footprint and environmental compliance in order to track progress and support climate-related improvements. Suppliers subject to such assessments will be notified accordingly and are expected to cooperate and provide the relevant data.

Netgroup Energy reserves the right to review suppliers to verify compliance. Audits shall, where possible, be agreed upon in advance by the parties, and all parties are expected to cooperate fully.

9. Reporting Concerns

We encourage an open and transparent relationship with all our suppliers. Any suspected violations of this Code of Conduct, applicable laws, or regulations should be reported promptly to Netgroup Energy.
Reports may be made confidentially, and personal details are not required. Netgroup Energy does not tolerate any form of retaliation against individuals who raise concerns in good faith.
Concerns can be reported via info@netgroupenergy.se.

10. Prioritized Global Goals for Sustainable Development

Netgroup Energy prioritizes two of the UN’s Sustainable Development Goals: Goal 7—Affordable and Clean Energy—and Goal 12—Responsible Consumption and Production. These goals reflect the direct link between our core business—specialized services in nuclear, wind, solar, and hydroelectric power generation, as well as electricity transmission—and the transition to a climate-neutral society.

Through our operations, we contribute to a safe, reliable, and fossil-free energy system and promote the resource-efficient and responsible use of natural resources throughout the value chain.

We expect our suppliers, customers, and partners to be familiar with these goals and to consider how their operations contribute to or affect them. Where relevant, we encourage alignment with Goal 7 and Goal 12 in procurement decisions, reporting, and sustainability initiatives.

11. Enforcement

A violation of this Code of Conduct may result in the termination of the supplier’s status in accordance with the provisions of any existing supplier agreement and/or local laws and regulations. Unless the violation is deemed serious, the supplier will be given the opportunity to rectify the situation before such termination is enforced. All correspondence regarding these matters shall be documented in writing.

12. Acknowledgments

This Code of Conduct is signed digitally via Assently. By signing, the supplier confirms that it has read, understood, and agrees to comply with this Code of Conduct for the duration of the business relationship with Netgroup Energy. The signed document is legally binding and will be stored securely for both parties.