Engaging with Society, Sponsorship, Lobbying and Donations
Senop engages with international and national bodies, governments and government agencies and officials at multiple levels and in many ways (e.g., as a corporate citizen, taxpayer, and employer). When interfacing with governments, agencies and officials, high ethical standards and transparency are to be applied. Special requirements apply to interactions with governments and state-owned enterprises including, for example, procurement, lobbying, gifts, and hospitality.
All Senop personnel shall act honestly, transparently, and truthfully when dealing with any stakeholders and follow Senop’s policies, guidelines, procedures and any applicable laws and regulations in all dealings with any officials and stakeholders.
Donations and sponsorship shall be carried out in a strictly transparent manner. Senop grants donations on a voluntary basis without demanding anything in return and adheres to applicable laws and local regulations. Sponsorship is used to affect Senop’s reputation and public perception in a positive manner. Sponsorship and donation targets are to be handled in a centralized manner and must comply with company-level guidelines.
Senop does not grant donations, sponsorships or other monetary benefits to political parties, candidates or individuals holding public office or support private individuals in pursuing their political aims.
Senop may, however, participate in public debate when it is of commercial significance or strategic importance to the enterprise. Collaboration with customers and other stakeholders is close and planned for the long term. For Senop, a gratifying partnership is defined as professional, reliable, open, and transparent collaboration that all parties involved can embrace. Stakeholder relationships are conducted with integrity, fairness, and confidentiality.
Adhering to Export Control Laws and Regulations
Senop is committed to conducting business everywhere in full compliance with applicable Export Control laws and regulations, at all times.
All of us are all accountable for ensuring compliance, throughout Senop, with Finnish requirements as well as with those of all other countries in which we operate. Senop is committed to a robust Internal Compliance Program that is able to identify and safeguard all controlled products, technologies and services; ensure appropriate export licenses exist to authorize any transfer involving suppliers, customers, business partners, and other third parties; screen all transactions for relevant sanctions and restricted party lists, confirm that the ultimate end-use, end-user, and destination are authorized, maintain accurate records and effective reporting mechanisms.
A Senop or Patria Group Export Control Officer should always be consulted if in doubt about the right course of action in any case involving import or export of controlled items.
Committing to Fair Competition and Antitrust
Senop promotes sound and effective economic competition in the markets in which it operates and complies with all applicable competition and antitrust laws. Senop will not enter into or accept any mutual agreements or practices between competing undertakings that may limit competition. Neither will Senop abuse a potential or actual dominant position in any market and will apply for all clearances required for closing any merger or acquisition.
Integrity Towards Customers
All our customers are treated with respect and integrity. We will address customers’ needs in the best possible manner within the framework of the commercial and ethical guidelines that apply to Senop. Regarding customers in a competitive bidding process, respect for the customer’s bidding rules are demonstrated in all contact with the customer.
Reliability Towards Suppliers
Senop strives for reliable, fair, and mutually beneficial relations with its suppliers. Supplier selection is based on free and fair competition and transparent supplier selection criteria, including objective factors such as quality, reliability, delivery, and price, without preference for personal reasons.
Senop expects its suppliers to work in accordance with the principles presented in this Code and to comply with the national laws of the countries in which they operate.
High Ethical Standards of Third Parties, such as Intermediaries, Market Representatives and Suppliers
In addition to our personnel, the agents, consultants, intermediaries, market representatives, service providers, suppliers, and other business partners that Senop engages, all represent Senop and act for or on behalf of Senop. As such, these third parties are expected to conduct their business in a way that meets high ethical standards and to comply with local legislation in all countries in which they operate. Business partners are to be evaluated and appointed in accordance with the applicable guidelines, including but not limited to the Business Partner Selection process. The evaluation and appointment processes are transparent, authentication is consolidated, measured and traceable, and the partners are supervised.
Communication
Senop’s communication is based on the Company’s strategy and values, code of conduct and operational guidelines. Our communication task is to distribute relevant, up-to-date, accurate and truthful information to all stakeholders of Senop while managing and reinforcing Senop’s image and brand.
Conflict Minerals
Senop is required to comply with regulatory and customer requirements regarding the prohibition and restriction of substances, including hazardous substances and conflict minerals.
To support the responsible sourcing of minerals within our supply chain, Senop’s suppliers are, with regards to certain minerals; including but not limited to cobalt, lithium, tin, tantalum, tungsten, and gold (including their derivatives) originating from conflict affected and high-risk areas such as the Democratic Republic of the Congo (DRC) or its surrounding countries, required to have in place a supply chain policy and processes to undertake:
- a reasonable inquiry into the country of origin of conflict minerals incorporated into products it provides Senop; and
- due diligence (with reference to OECD/RMI guidance or similar) of its supply chain, as necessary, to determine if conflict minerals sourced from the covered countries directly or indirectly support unlawful conflict there; and
- risk assessment and mitigation actions necessary to implement the country-of-origin inquiry and due diligence procedures, and
- avoid smelters and refiners without an adequate, audited due diligence process in place.
Committing to Quality
Senop provides high-quality products and services to its customers. Quality is regularly measured and assessed to ensure compliance with customers’ requirements and to improve customer satisfaction.
Senop maintains the approvals, licenses and certificates required by applicable laws and customers and acts in accordance with them. Senop’s operations are based on management that is in line with the ISO 9001 standard and Allied Quality Assurance Publications (AQAPs).
Protecting Senop’s Property, Assets, and Intellectual Property
All Senop property and assets shall be used for legitimate business purposes and are to be protected against any unauthorized use. In no event shall Senop’s assets be used for personal gain, fraudulent purposes, or in any other inappropriate manner. Senop also respects the valid intellectual property of others.
Senop’s intellectual property, which includes patents, inventions, software and other copyrighted materials, know-how, trade secrets, brands, and trademarks, is among its most valuable assets. Senop protects its own intellectual property and secret business information and does not share it without authorization. Equally importantly, Senop respects and treats as confidential the intellectual property and confidential information of our competitors, business partners and customers.
Respecting Information Security and Privacy
Senop maintains a level of physical and information security that protects and guarantees the confidentiality, integrity and usability of information and materials respective to business partners, customers, and other interest groups. Senop also guarantees reliability towards its partners and the authorities with respect to data protection and information security as a party to their critical projects.
Senop safeguards business and professional secrets and privacy such that the continuity of business operations is ensured also in the event of disturbances and exceptional situations. Senop ensures that every employee has access to the information they need to carry out their work tasks.
Senop respects the privacy of its Personnel, business partners and customers and expects strict compliance with applicable personal data related laws and regulations.
Sustainability and Responsibility at Senop
Financial Responsibility
We nurture and develop our business in a sustainable and responsible manner. Senop does not tolerate unethical or corrupt behavior from its personnel or business partners and actively works against it.
Environmental Policy
Senop is committed to operating according to the principles of sustainable development by responsibly utilizing natural resources, continuously improving its level of environmental protection, and preventing pollution.
Social Responsibility
Senop respects and promotes universal human rights as defined in the Universal Declaration of Human Rights by the United Nations in its operations.
Code of Conduct for Suppliers
Senop conducts business only with reliable suppliers and subcontractors whose operations adhere to Senop’s ethical guidelines.
Reporting Suspected Misconduct
All personnel are obligated to report to their immediate supervisor or legal counsel any concerns about compliance with the guidelines and suspected breaches of the guidelines.