Klintra Code of Ethics and Business Conduct

This Code of Conduct outlines the core values and ethical principles that guide the operations of Klintra. We strive to conduct ourselves with integrity, fairness, and respect in all our interactions, fostering a positive and responsible business environment.

General Principles

Compliance with Law: We will comply with all applicable laws and regulations in every jurisdiction we operate in.

Honesty and Integrity: We will conduct our business with honesty, integrity, and transparency. We will avoid any deceptive or misleading practices.

Fairness and Respect: We will treat all individuals with fairness and respect, regardless of their race, religion, gender, sexual orientation, age, disability, or any other protected characteristic.

Confidentiality: We will protect the confidentiality of all sensitive information entrusted to us, including customer data, employee information, and trade secrets.

Conflict of Interest: We will avoid any situations that may create a conflict of interest between our personal interests and our professional responsibilities.

Environmental Responsibility: We will strive to conduct our business in an environmentally responsible manner and minimize our impact on the environment.

Relationships with Stakeholders

Customers: We will provide our customers with high-quality products and services, treat them with courtesy and respect, and address their concerns promptly and professionally.

Suppliers: We will conduct our business with suppliers in a fair and ethical manner. We will strive to build mutually beneficial relationships based on trust and collaboration.

Employees: We will provide our employees with a safe and healthy work environment, promote diversity and inclusion, and treat them with fairness and respect. We will compensate them fairly and offer opportunities for professional development.

Community: We will be a responsible member of the communities in which we operate, and we will actively support local initiatives and charities.

Antitrust and Competition

We are committed to fair and ethical competition and will comply with all applicable antitrust and competition laws. This includes, but is not limited to, refraining from:

• Price fixing: Agreeing with competitors to set prices or restrict production.
  
  
• Market allocation: Dividing up markets or customers with competitors.
  
  
• Bid rigging: Colluding with other companies to submit non-competitive bids.
  
  
• Anti-competitive agreements: Entering into any agreements with competitors that restrict competition.

Improper Payments, Money Laundering, and Economic Boycotts

We have a zero-tolerance policy for corruption and bribery. We will not engage in any activities that violate anti-corruption laws, money laundering regulations, or trade sanctions. This includes:

• Bribery or facilitation payments: Offering or receiving anything of value to improperly influence a decision.
  
  
• Money laundering: Engaging in activities that involve disguising the source or ownership of illegal funds.
  
  
• Participating in illegal boycotts: Engaging in boycotts that violate trade laws or regulations.

Dealing with Government

We will conduct all interactions with government officials with transparency and integrity. This includes:

• Complying with government procurement regulations: Following all legal and ethical procedures when bidding on government contracts.
  
  
• Avoiding conflicts of interest: Avoiding any situations that could create a conflict of interest between our business and government officials.
  
  
• Proper disclosure: Disclosing all relevant information to government officials as required by law.

Lobbying of Government Officials

We may engage in lobbying activities to advocate for our interests. However, we will do so in a transparent and ethical manner, complying with all applicable laws and regulations. This includes:

• Registering all lobbying activities: Registering with the appropriate authorities as required by law.
  
  
• Disclosing all relevant information: Disclosing our interests and the specific issues we are advocating for to government officials.
  
  
• Avoiding improper influence: Avoiding any attempts to bribe or improperly influence government officials.

Trade Compliance Laws and Regulations

We will comply with all applicable trade compliance laws and regulations, including customs laws, export controls, and sanctions. This includes:

• Obtaining necessary licenses and permits: Obtaining all necessary licenses and permits for importing and exporting goods and services.
  
  
• Classifying goods accurately: Accurately classifying and labeling goods for customs purposes.
  
  
• Sanctions compliance: Following all applicable trade sanctions and embargoes.

Reporting Concerns

We encourage all employees and stakeholders to report any suspected violations of this Code of Conduct. Reports can be made anonymously through various channels.

• In writing: Submit a written report to your Manager, Administration Officer or a Senior Consultant. You can mail it in or send it through internal mail.
  
  
• Verbally: Report your concerns verbally to your Manager, Administration Officer or a Senior Consultant. You can schedule a meeting or approach them directly.
  
  

All reports will be investigated thoroughly and confidentially. You are not required to identify yourself when making a report. However, providing your contact information can be helpful during the investigation process.
All reports are handled in accordance with Klintra’s Privacy Policy.

Enforcement

We are committed to enforcing this Code of Conduct. Violations of this Code may result in disciplinary action, up to and including termination of employment or termination of business relationships.

Continuous Improvement

We will continue to review and update this Code of Conduct to reflect changes in our business and the legal landscape. We encourage all employees and stakeholders to familiarize themselves with this Code and to act in accordance with its principles.

Klintra Sp/f

Heykavegur 4
100 Tórshavn
Føroyar
+298 898989
klintra@klintra.fo