statement by the board of directors

Transcription

1 Code of Conduct

2 statement by the board of directors 2

3 statement by the board of directors Statement by the Board of Directors Mannheimer Swartling is the leading business law firm in the Nordic region, with operations in a number of jurisdictions. We therefore have a great responsibility to provide our clients with the best possible advice, while running our own operations in a responsible and sustainable manner. We pride ourselves on our strong corporate culture and on the core values we adopted long ago quality, business focus, and team spirit. We have long worked systematically on issues related to equality, the work environment, the environment, anti-corruption, insider regulation, etc. and we have adopted a number of internal policies within these areas. This Code of Conduct outlines the expectations we have on our employees. It is designed to set out our existing expectations as well as the firm s position on its responsibility to respect human rights. We pride ourselves on our strong corporate culture and on the core values we adopted long ago quality, business focus and team spirit. 3

4 about the code of conduct About the Code of Conduct Purpose of the Code of Conduct The firm s Code of Conduct provides guidance for the firm s employees (including partners, associates, support staff, and temporary employees) and is used as a tool in the firm s daily practice both internally and in the course of conducting advisory services. The Code of Conduct sets out the principles that govern the firm in its role as an employer and its employees in their relationships with other employees, clients, suppliers, business partners, and society at large. While the Code of Conduct focuses on the most essential issues for the firm, it draws on the leading international standards for responsible business conduct, namely the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the UN Guiding Principles on Business and Human Rights. The Code of Conduct has been adopted by Mannheimer Swartling s Board of Directors and will be reviewed annually to ensure that it remains relevant and reflective of the firm s obligations, expectations, and future development. The Code of Conduct will be updated when necessary. The purpose of the Code of Conduct is to help the firm realise its core values. It seeks to translate these core values into tangible, comprehensive guidelines. How do we ensure the best possible quality in our work? How do we ensure that we keep the right business focus? How do we ensure that our work is permeated by a strong and clear team spirit? The Code of Conduct s guidelines not only refer to the legislation and regulations that govern the firm and its employees, but also to the firm s wider expectations both internal and external that extend beyond mere legal compliance. The Code of Conduct s relationship to the firm s other policies There are references to more detailed information on existing internal policies in each section of the Code of Conduct below. These references are intended to facilitate a better understanding of how the guidelines apply to the firm s operations. The purpose of the Code of Conduct is to help the firm realise its core values. 4

5 about the code of conduct 5

6 the firm s core values The firm s core values The firm has three core values that guides us in our daily practice quality, business focus, and team spirit. These core values are linked to the firm s True Partnership business model, which is based on the idea that success should benefit the entire firm rather than the individual employee. The True Partnership model means that the firm s earnings are divided equally between partners, with other lawyers salaries being determined solely by their level of experience. The model promotes knowledgesharing and cooperation between colleagues, practice groups, and offices. It is our foremost tool for guaranteeing that each client receives the best possible legal advice and ensuring the best possible work environment. quality We seek the highest quality in everything we do; this is an ambition that permeates the entire firm. This also means an ambition to engage in constant renewal and to drive development. Working with us should constitute a stamp of quality for our clients as well as our employees. business focus We regard business law as a tool to create success for our clients. This means that every employee is governed by two main objectives: developing both our clients business and our own business in a long-term perspective. team spirit We are driven by a strong sense of unity, without regard to individual prestige. We work across borders both within the firm and together with our clients. Commitment, satisfaction, and participation are fundamental principles for our firm. 6

7 the firm s core values The firm has three core values that guides us in our daily practice quality, business focus, and team spirit. 7

8 focus areas 8

9 focus areas Focus areas Human rights The firm has a responsibility to respect human rights in the conduct of its operations and in its relationships. The firm s work related to human rights is therefore based on the following overarching principle: respect for human rights We respect internationally-recognised human rights. Our respect for human rights means an undertaking not to cause, contribute to, or, through our business operations, be linked to negative effects on human rights. This means running our business based on values that include respect for internationally recognised human rights. This undertaking does not affect our employees ability to act in the best interest of their clients according to the rules on professional ethics for lawyers. We respect internationally recognised human rights. 9

10 focus areas Terms of employment the physical and psychosocial work environment As a knowledge-based company, Mannheimer Swartling is dependent on the professional qualities and personal skills of its employees. We strive to be a good employer for all employees and to offer an attractive workplace infused with our core values. The firm s work related to the physical and psychosocial work environment is based on the following principles: zero tolerance against discrimination We do not accept any form of discrimination based on gender, transgender identity or expression, ethnicity, religion or other beliefs, disability, sexual orientation, or age. We take forceful action against any transgressions. We strive actively to promote equal treatment and increase diversity and equality. The firm has an Equality and Diversity Plan that provides further details on how this principle is enacted. a workplace characterised by respect and sensitivity All employees are respectful in their treatment of others and treat other employees in the manner they wish to be treated themselves. All employees are loyal to the firm and to other employees. All employees act as good ambassadors for Mannheimer Swartling. safe and secure work environment We strive continuously to ensure the best possible physical work environment. To promote a good psychosocial work environment, we offer regular training in stress management and encourage and contribute to preventive healthcare. We believe in the importance of social activities and gatherings where our employees are able to create and maintain good relations with each other. The firm has a Work Environment Policy that provides further details on how this principle is enacted. responsible leadership and employee influence Partners and support managers set good examples and exercise their leadership based on our core values and this Code of Conduct. Partners and support managers are also responsible for advising on matters linked to the Code of Conduct. Employee influence is encouraged, as it is of great importance that everyone contributes to reinforcing a sense of team spirit and the firm s True Partnership culture. We strive actively to promote equal treatment and increase diversity and equality. 10

11 focus areas Environment Mannheimer Swartling is ISO certified and committed to implementing environmental best practice across its operations. The firm s environmental work is based on the objectives set out in its environmental management system. The purpose of the system is to continuously reduce the firm s negative environmental impact through ongoing improvement in a number of identified areas. The starting point is that our operations should be conducted with the least possible negative impact on the environment, to contribute to a lasting and sustainable development. The firm s environmental work focuses on the following areas, which are also mentioned in the firm s Environmental Policy: knowledge The firm continuously trains and inspires its employees on environmental issues to increase awareness and commitment. transport and travel To reduce carbon emissions per employee in the long term, the firm ensures, where possible, that goods are delivered to and from its offices using the most environmentally sustainable means of transportation. When travelling for business, our employees select the means of transportation that is best suited for the trip, giving due regard to environmental considerations alongside other factors such as cost, time, and safety. The firm has a Meeting and Travel Policy that provides further details. purchasing goods and services The firm considers its environmental impact when selecting every one of its goods and services. The firm s Purchasing Policy provides further details. This policy has a clear environmental focus and ensures that relevant environmental requirements are a part of every procurement. waste The firm maintains its level of sorted waste and strives to reduce its total amount of waste. Hazardous waste is handled in a manner that minimises negative environmental impact. All employees contribute to this work through routine use of the waste sorting facilities. energy consumption The firm optimises its energy consumption in the Swedish offices and uses green energy on the premises. 11

12 focus areas Business ethics and anti-corruption Business ethics and compliance underscore the firm s core value of quality, and are of major importance for the firm s daily tasks and long-term work. We constantly make ethical assessments, and always strive to act according to the firm s values and to achieve the highest quality results. Good business ethics are fundamental to all of the firm s practice areas and all employees are required to comply with applicable legislation, regulations, and internal policies, as referenced within the following principle statements: zero tolerance against corruption All employees must comply with the firm s Anti-Corruption Policy when engaging in in relationship-building activities such as corporate hospitality, sponsoring, or involvement in corporate events. Events arranged by the firm are always of professional relevance for the participants, and any entertainment activities are subordinate to the element of professional relevance and are of limited value. Our employees are not allowed to accept gifts in the form of cash or gift vouchers. Gifts worth over SEK 500 are reported to the Head of Quality and Risk Management (QRM). Enquiries relating to the scope and application of the firm s Anti-Corruption Policy shall be referred to the firm s Managing Partner or the Head of QRM. avoidance of conflicts of interests For ethical and business reasons, it is important that employees are loyal and trustworthy in relation to the firm and its clients. Before a new client assignment is accepted, all parties in the potential matter are checked against the firm s client register so as to avoid potential conflicts of interest as defined by the Code of Professional Conduct for Members of the Swedish Bar Association and the firm s Policy for the Management of Conflicts of Interest and Decisions prior to the Acceptance of New Assignments. The final decision as to whether to accept a new assignment is made by the partner in charge of the potential matter in consultation, if required, with the Managing Partner or the Head of QRM. 12

13 focus areas money laundering and the financing of terrorism All employees work actively to prevent the use of the firm and its assignments for money laundering or terrorist financing. Central to these efforts is the ongoing need to establish good knowledge of clients and an understanding of the purpose of each assignment. The partner in charge of a matter is ultimately responsible for ensuring that new assignments are accepted in accordance with legislative provisions and the firm s policy. All employees undergo continuous training in this field. For more detailed information, please refer to the firm s Policy regarding Act (2017:630) on Measures against Money Laundering and Terrorist Financing. information security, it security and duty of confidentiality Our employees are duty-bound to maintain confidentiality and discretion regarding information we gain access to in our practice. All employees use safe information channels offered by the firm, and they are individually responsible for reporting any detected information security breaches or losses of information. The firm s employees should also report any incidents that may entail a risk of information being lost to their immediate partner, support manager, or QRM. All employees uphold good information management, information safety and IT safety, and attend regular training within these areas. For more detailed information, please refer to the firm s Information Security Policy, IT Security Policy, Policy regarding the Treatment of Personal Data and the Code of Professional Conduct for Members of the Swedish Bar Association. insider regulation The firm acts as an advisor in a great number of transactions and matters involving companies whose shares or other financial instruments are traded on regulated markets. All employees must comply with the firm s Insider Policy. No employees are allowed to trade in listed financial instruments (such as shares). 13

14 implementation All employees are individually responsible for complying with the Code of Conduct. 14

15 implementation Implementation All employees are individually responsible for complying with the Code of Conduct. Partners and support managers are responsible for ensuring that the other employees understand, have access to advice on, and act in accordance with, the Code of Conduct. The partners and support managers responsibilities includes providing regular training to employees on the contents of the Code of Conduct and its relevance to day-to-day operations. All employees are encouraged to report potential breaches of the Code of Conduct or the firm s other policies to their immediate partner or support manager. If an employee suspects that one of the firm s partners or support managers is in serious breach of this Code of Conduct, the Code of Professional Conduct for Members of the Swedish Bar Association, the firm s Insider Policy, Information Security Policy, Anti-corruption Policy or the Policy regarding Act (2009:62) on Measures against Money Laundering and Terrorist Financing, or that any of them have been involved in serious financial irregularities or serious irregularities involving the life and health of individuals, such suspicions may be reported through the firm s whistleblowing system. The system is described in more detail in the firm s Whistleblowing Policy. All employees may report their suspicions anonymously, and such reports are investigated promptly by a speciallyappointed whistleblowing team consisting of the firm s Chairman of the Board, the Chairman of the Committee for Partner Development, and the Head of QRM. Stockholm, May 2016 (revised June 2017) klas wennström Chairman of the Board jan dernestam Managing Partner and CEO 15

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