CONTENTS

1. INTRODUCTION
2. MISSION
3. RULE OF LAW
4. BUSINESS ETHICS
5. DUE DILIGENCE MEASURES
6. INFORMATION POLICY
7. WORK ENVIRONMENT
8. ECOLOGICAL FOOTPRINT

 

INTRODUCTION

This Code of Conduct (hereafter CoC) defines our mission and fundamental values underlying our business activities in pursuit of that mission. The CoC also contains information on our self-control measures adopted to guarantee adherence to the principles herein and our policies toward gathering and sharing information as well as workplace environment and our ecological footprint.

The CoC applies across all our activities and in conjunction with existing policies, procedures and standards adopted. The CoC is binding to Milrem AS (hereafter Milrem), our employees, management and we also expect our associates, partners and other stakeholders to follow the principles contained herein.

The CoC is in accordance with Milrem’s policy of ethical development of systems with intelligent functions [1].

We have a zero tolerance policy to unethical business behaviour and we  act honestly and respectfully in all our endeavours. We monitor and follow the principles of Corporate Social Responsibility (hereafter CSR), which  are integrated into our everyday activities, business and management.

Every employee of Milrem who notices or has suspicions relating to any violations of the CoC is encouraged and must immediately notify their direct manager or company board of such violation.

[1] Policy of Ethical Development of Systems with Intelligent Functions

MISSION

Our mission is to provide innovative robotic solutions for challenging environments. We believe that our cutting edge robotic solutions fulfil a higher purpose – enabling more meaningful lives.

Respect for the value of human life being our top priority, we aim to enable people to stay outside the danger areas and liberate them from dirty, dull and dangerous tasks. Throughout our range of products and services, we seek to increase safety and labour efficiency in a number of targeted industries, particularly in defence, agriculture, forestry, municipal services, rescue and mining.

Our innovative technology is meant to protect and to spare lives. We promote the idea of dedicating time to open up the true potential of humans. We treasure lives lived lively.

Our vision is to be a global innovation leader of robotic solutions and the largest player of the unmanned ground vehicle market in Europe.

RULE OF LAW

We sell our products and services to and cooperate with customers who share our values and adhere to the laws and regulations set by their governments, the European Union and NATO. We strictly follow export compliance regulations and the sanctions imposed by the Government of Estonia, the European Union and NATO.

We consider ourselves as responsible members of the international society and comply with domestic and international laws, rules and regulations applicable to our actions.

We follows specific rules and regulations introduced by governments to counter bribery and corruption and fight against money laundering and terrorism in jurisdictions where we operate.

We promote education and organize trainings to ensure that every employee of Milrem understands the laws, rules and international regulations related to his/her work.

In case of violation of any law, we will cooperate with respective authorities and assist in legal enquiries and investigations.

BUSINESS ETHICS

NO TOLERANCE FOR BRIBERY AND CORRUPTION

We consider any form of bribery and corruption unacceptable.

Where we are faced with threat of financial harm or loss of business, bribery of any kind is not allowed and tolerated.

Our zero-tolerance policy for bribery and corruption does not distinguish between public officials and private sector organizations, condemning such behaviour in both sectors.

Our employees, management and associates are prohibited from offering bribes and  unlawful advantages as well as from accepting bribes or unlawful advantages.

Our policy towards facilitation payments and secret commissions, whether direct or through third parties, follows the same zero-tolerance principle. Facilitation payments and secret commissions violate most anti-corruption laws, and we strictly prohibit them even in the unlikely scenarios where such payments may be legally permissible or not expressly prohibited.

 

GIFT POLICY

We consider it acceptable to offer and accept corporate souvenirs and memorabilia as gifts in so far as they are deemed to not influence or create the appearance of influencing business decisions. Use of one’s position within the company to solicit a gift of any kind is not acceptable. Gifts, hospitality and entertainment must never be given or received with the intention of influencing a business decision or securing an unfair business advantage.

 

LOBBYING AND DONATIONS

We engage in lobbying activities to provide policy makers with data and insights to enable widely informed decision-making conducive to improving sustainable business.

Our lobbying activities are carried out openly, are never used for any corrupt or illegal purposes, or to improperly influence any political decision. We adhere to relevant functions (e.g., Public & Government Relations), on how lobbying should be conducted based on the values of transparency, honesty and integrity.

We prohibit political donations by or on behalf of Milrem. This includes among other, donations to politicians, registered political parties and political organizations other than parties (e.g. NGOs closely associated with or established by acting politicians or political parties).

Charitable donations are allowed but must always be made in accordance with applicable law. Charitable donations and sponsorship may take place only upon prior written approval of the Management Board of Milrem.

Charitable donations or sponsorships are never made to influence any decisions or gain an improper advantage to Milrem’s business and not used as a means of camouflaging an illegal activity.

 

COUNTERING TERRORISM FINANCING AND MONEY LAUNDERING

We abide by the rules of the Money Laundering and Terrorist Financing Prevention Act of Estonia and strictly prohibit terrorism financing and money laundering.

We apply due diligence measures for processing cash payments of over 10 000 euros or an equal sum in another currency. The due diligence measures include identification of a customer or a person participating in such transaction and verification of the submitted information based on information obtained from a reliable and independent source, including using means of electronic identification and of trust services for electronic transactions.

We do not do business with customers where it is known, suspected or reasonably expected that the funds were derived from illegal activities.

 

CONFLICTS OF INTEREST

A conflict of interest exists where one’s professional duties and personal interest are in conflict.

Our employees and associates must guard against any potential conflict of interest while acting on behalf of Milrem. If a conflict of interests should arise, they are encouraged and must immediately notify their direct manager or company board of the nature of the conflict and when instructed, withdraw themselves from respective actions.

We prohibit making, influencing or participating in Milrem’s business decisions that provide personal benefit or benefit to friends or family in a situation of conflict of interests.

DUE DILIGENCE MEASURES

We have adopted a systematic process to identify business ethics related risks. Set out below are the key measures that we have implemented as integral part of our compliance system.

 

SELF-AUDIT

Our employees must be aware of who they are doing business with. Our employees are responsible for ensuring that associates engaged on behalf of Milrem are legitimate market operators and that there is an understanding of the parties and business relationship contemplated.

We notify our associates that they may be subject to appropriate due diligence measures as a precondition to their engagement.

If an employee has any concern as to the legitimacy of an associate, the employee is encouraged and must immediately notify their direct manager or company board of such concerns.

 

RECORD-KEEPING

We keep an accurate record of all transactions, payments made and received. False or misleading entries in our accounting and records. “Slush funds,” or other “off-the books” accounts are strictly prohibited. Our financial statements are audited periodically by internationally recognized financial auditors.

 

TRAINING

Training on the regulation contained in the CoC and other existing policies, procedures and standards forms part of the introduction process to the company for all employees. Following the introduction process, employees will be provided with periodic training, as appropriate to their roles.

Senior executives and certain employees identified by the company who are more likely to find themselves in delicate business ethics situations will be required to undertake more detailed training on a regular basis.

INFORMATION POLICY

We maintain strict confidentiality of any proprietary information disclosed to us. Our employees are instructed to always conclude an appropriate non-disclosure arrangement before sharing proprietary or confidential information.

Our non-disclosure agreements describe the terms of disclosing information with confidential nature during co-operation. As a standard approach, we consider as confidential information any and all technical, financial, commercial or other information and trade secrets, in any form or medium, including but not limited to agreements, the contents of such agreements, data, reports, transactions, forecasts, analysis, records, designs, illustrations, style and text.

Milrem’s employees are trained and follow legislative and internal regulations regarding processing of information and data, information security and prevent improper use of and unauthorized access to work related devices and networks.

WORK ENVIRONMENT

We ensure fair payment and reasonable working hours for our employees and condemn every form of forced or child labour. We honour the privacy of our employees and protect relevant information.

We do not allow discrimination against employees – all employees have the right for fair and equal treatment. We prohibit any discrimination based on race, sex, sexual orientation, national origin, age, physical disability or religion. Employees who have the same qualification, experience and work results receive equal payment for equal amount of work.

We strive to create a safe and healthy working environment for our employees.

Each individual employee has the responsibility to follow all internal health and safety procedures to maintain a safe and healthy workplace. All workplace accidents, unsafe equipment, unsafe practices and conditions must be reported to their direct manager or person responsible for workplace safety.

We provide employees with appropriate health and safety information and training on how to evacuate from Milrem’s facilities safely, how to correctly handle equipment, tools and chemical substances at the workplace.

ECOLOGICAL FOOTPRINT

We are committed to the sustainable use of natural resources and committed to reducing the ecological footprint of our activities.

Milrem upholds legal regulations that apply to the protection of the environment.

We are committed to ensuring that the negative environmental impact of our daily activities is minimal and we continue to monitor our activities in order to ensure continuous improvement. We continuously evaluate the environmental aspects of our activities to deliver products and services with the lowest environmental impact possible.