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 defines the requirements placed on all suppliers of Netgroup Energy Sweden AB (henceforth Netgroup Energy or referred to as we/our). It is based on our own Code of Conduct and internationally recognised standards, including the UN Global Compact and the (International Labour Organization’s (ILO’s) fundamental conventions.

The purpose of this Code of Conduct, along with Netgroup Energy’s own Code of conduct, is to ensure that the complete chain from all suppliers and sub-suppliers to our customers adhere to laws, regulations and industry standards as 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 out in this document. Where this document sets 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 within their supply chain.

2. Working Conditions and Human Rights

Netgroup Energy has zero tolerance for any form of modern slavery, forced labour, or human trafficking within its operations or supply chain. Suppliers must ensure that all work is freely chosen and that no employee is subject to coercion, exploitation, or involuntary labour under any circumstances.

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

Comply with all applicable labour laws and regulations.
Prohibit child labour in accordance with ILO Conventions 138 and 182.
Eliminate all forms of forced labour, 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 agreements.
Comply with applicable legislation on working hours and rest periods.
Provide and maintain a safe and healthy work environment meeting 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 shall 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, as well as taking immediate action to remediate any negative outcome as well as implementing measures to prevent future occurrences.
Set measurable targets to reduce emissions, energy consumption, and waste, measure accordingly and strive towards fulfilling them with the goal of establishing a circular economy.
Assess and reduce their climate impact, including greenhouse gas emissions, where relevant, in line with recognised frameworks such as the GHG Protocol or Science Based Targets initiative (SBTi).
Handle chemicals and hazardous substances safely and substitute them with less harmful alternatives where 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 operate with zero tolerance for bribery and corruption. Suppliers shall 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 where personal interests may conflict with sound business judgement. Any actual or potential conflict of interest must be disclosed to Netgroup Energy promptly. Professional decision-making must remain independent of private considerations.

In situations where conflict of interest arises between businesses, such as a supplier’s engagement with an entity competing with Netgroup Energy, this shall be promptly reported to Netgroup Energy in writing. This also applies to employees’ outside employments and supplier engagements as well as potential conflicts arising when working with clients competing with each other or in situations where e.g. an engagement with a client conflict with an engagement at a legal or regulatory body.

4.3 Fair Competition

Suppliers shall 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 shall respect internationally recognised human rights and ensure that their operations and supply chains are free from any form of modern slavery, forced labour, or human trafficking.

Suppliers are expected to:

Prohibit all forms of forced labour, child labour, 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 labour 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 employment 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 of 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 Control

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

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 as per governing 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 only be shared with those who need it to perform their tasks, 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 unauthorised disclosure occur, all concerned 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 relevant.
Refrain from sharing confidential, sensitive, or proprietary information with AI tools without appropriate safeguards and authorisation.
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 compliant with applicable legal and contractual requirements.

7. Data Protection

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

Suppliers processing 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 follows up on selected suppliers through structured self-assessments to ensure compliance with this Code of Conduct and to support continuous improvement. Suppliers are requested to complete questionnaires covering relevant areas of sustainability and compliance, including environmental impact. This Code of Conduct forms 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. The requirements apply throughout the supply chain, and suppliers are expected to ensure that their subcontractors meet equivalent standards.

As part of supplier follow-up, Netgroup Energy will request carbon footprint and environmental compliance self-assessment of selected suppliers in order to track progress and support climate-related improvements. Suppliers subject to such measurement will be informed accordingly and are expected to cooperate and provide relevant data.

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

9. Reporting of 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. Prioritised Global Goals for Sustainable Development

Netgroup Energy prioritises 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 — specialist services within nuclear, wind, solar, hydro power electricity generation, and 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 resource-efficient and responsible use of natural resources across 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 impact them. Where relevant, we encourage alignment with Goal 7 and Goal 12 in procurement decisions, reporting and sustainability initiatives.

11. Enforcement

Breaching this Code of Conduct may result in the termination of the supplier status as per the statutes in any existing supplier agreement and/or according to local laws and regulations. Unless the breach is considered serious, the supplier will be given the opportunity to rectify the situation before such a termination is enforced. All correspondence in these matters shall be documented in writing.

12. Acknowledgement

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.