Click to download a PDF version of the Elekta Code of Conduct
Purpose
All Elekta employees (hereinafter “Elekta Professionals”), suppliers, consultants, agents and distributors (hereinafter “Elekta Partners”) are expected to observe high standards of business and personal ethics while performing their duties in their work with Elekta.
The purpose of this document is to set out the main ethical principles which Elekta expects all Elekta Professionals and Partners to comply with and uphold in the business conducted for and with Elekta.
This Code of Conduct is an important building block in strengthening the Elekta brand in support of long term sustainable market presence and growth of our business while respecting good principles of social, environmental and economic responsibility. It should be read in the context of the Elekta Vision, Mission, Quality Policy and Elekta Values as well as the Elekta Environmental Policy.
While the Elekta Code of Conduct gives guidance on applicable standards of integrity and business conduct, it is impossible to foresee all situations, which Elekta Professionals and Partners are likely to encounter in their day-to-day business. This Code of Conduct cannot replace each individual’s responsibility to exercise his/her good judgment in each particular situation. There may also be a need to seek guidance on proper conduct in a particular case from a supervisor, any member of Elekta Management or the CSR Officer.
Each Elekta Professional and Partner should use his/her best judgment and attempt to abide by the spirit of this Code of Conduct as well as the actual wording of the Code as such.
Failure to abide by this Code of Conduct may lead to disciplinary action, the level of which may include termination of employment or contractual relationship.
Scope
This Code of Conduct is applicable to all Elekta Group companies and Elekta Professionals.
The Code will also be communicated to and implemented in all contractual relationships with Elekta Partners to the extent that this is reasonably possible.
Implementation
It is the responsibility of each Elekta Professional and Partner to know and understand the Elekta Code of Conduct.
The president and managing directors of each legal entity within the Elekta Group have the ultimate responsibility to ensure that all Elekta Professionals and Partners are made aware of the Elekta Code of Conduct and its contents as well as provide assistance and guidance in its implementation and interpretation.
Definitions
CSR
Corporate Social Responsibility (herein meant to include social, environmental and economic responsibilities as set out in this document)
Elekta Professionals
All Elekta employees
Elekta Partners
All Elekta suppliers, consultants, agents and distributors
CSR Officer
Shall be the person appointed by the President & CEO to perform all or part of the duties for the Elekta CSR officer set out herein
1. Background and context
This Code of Conduct provides practical, day-to-day guidelines on what we consider to be high ethical standards of business and personal conduct for Elekta Professionals and Partners in representing or working within or with Elekta.
2. Summary of basic principles
The Elekta Code of Conduct sets out general principles in order to promote honest and fair behavior as well as integrity, trust and responsibility of the business of Elekta.
The Code focuses around the following basic guidelines:
General
(I) Abiding by laws and regulations applicable within each specific area, country as well as line of business etc., in which Elekta is active;
(II) Complying with all relevant disclosure requirements applicable to Elekta;
Social
(III) Using fair employment practices and respecting employee rights, including;
(a) Striving for a healthy and safe working environment;
(b) Protecting employees against inhumane or degrading physical and psychological treatment;
(c) Securing minimum/living wages;
(d) Ensuring the right to rest, leisure and paid holidays;
(e) Ensuring equal opportunities in employment;
(f) Striving to ensure freedom of association and collective bargaining;
(g) Combating exploitative child labor or forced/compulsory labor;
(IV) Respecting personal privacy;
(V) Striving to obtain the highest possible degree of product safety;
Environmental
(VI) Acting in an environmentally responsible manner by minimizing the environmental impact of Elekta’s business and products;
Economic
(VII) Avoiding all connection with any type of improper payments, transactions or inducements (bribery, fraud, money laundering etc.);
(VIII) Avoiding conflicts of interest;
(IX) Using Elekta resources carefully and for the purpose of conducting Elekta business;
(X) Respecting codes and key policy documents from trade associations etc. that have been signed by Elekta;
(XI) Respecting competitive regulations and insider trading rules;
(XII) Respecting confidentiality, both internally and in our relationship with customers and Partners.
3. Main Principles
The following sections will further develop the meaning of these main principles.
Legal requirements
Elekta Professionals and Partners must at all times abide by all laws, regulations and international conventions applicable in the countries in which Elekta operates or with which Elekta Professionals and Partners may otherwise come into contact. Elekta respect and comply with competition rules, environmental legislation, labor laws, safety requirements or other provisions applicable for our operations. Should any of the requirements stated in this document be in violation of or contrary to the law in any country, the local law should always take precedence. In such case, the local entity must immediately inform the CSR Officer of this fact.
Disclosure
Elekta, its Professionals and Partners are committed to comply with all relevant laws, regulations as well as internationally recognized standards of accounting in order to ensure correctness and transparency and give a fair picture of Elekta’s activities, structure, financial situation and performance. Elekta also aims at integrity in all communications in order to ensure timely and accurate reporting of financial information as well as other relevant information on its business to the public.
In particular, Elekta’s accounting shall fulfill the requirements of Swedish GAAP standards, as well as the rules and regulations for making information public which have been issued by the Stockholm Stock Exchange. All local Elekta legal entities as well as Elekta Partners are expected to comply with all local requirements on accounting and reporting as well as submitting tax returns and supplying all other information required by local authorities in a timely manner.
Elekta’s accounting and reporting standards are set out in detail in the Elekta Financial Guide. Elekta’s Communication Policy also contains rules for how Elekta communicates information to the investors and the general public.
Fair Employment Practices – Employee rights
Elekta supports and respects international conventions concerning human rights and everyone who works (directly or indirectly) for Elekta should be entitled to his or her fundamental rights, as set out e.g. in the United Nations International Bill of Human Rights. Elekta does not accept the use of exploitative child labor, nor forced or compulsory labor.
Elekta is also committed to abiding by local employment laws in all countries where it is active and expects all Elekta Professionals and Partners to also do so.
All forms of harassment and abuse, for whatever purpose, are unacceptable. Employees at Elekta or Elekta Partners should not be subject to corporal punishment or mental or physical disciplinary action.
Elekta promotes diversity and equal treatment and no employee should be discriminated against because of age, race, gender, religion, sexual orientation, marital status, social origin, political opinion, ethnic background, disability or for any other reason prohibited by local law. Dismissal of female employees due to pregnancy is not acceptable.
Elekta also aims to ensure that all employees with the same experience and qualifications should receive equal pay for equal work in accordance to local standards and have equal opportunities based on merits and qualifications or similar work-related criteria.In jurisdictions where this is required, Elekta shall have policies for its work on equal opportunities.
Elekta also respects the rights of each Elekta Professional (and expects the Elekta Partners to also do so) to associate freely with any workers’ association or group of their choosing or collective bargaining in accordance with local legislation and applicable conventions.
Elekta is firmly committed to ensuring the health, safety and welfare of its employees, and expects each Elekta Professional and Partner to respect and to contribute to this goal in all business activities within or with Elekta.
All local laws and regulations on employee working conditions and safety should be respected by all Elekta Professionals and Partners.
Personal Privacy
Elekta is committed to maintaining the confidentiality of any personal or individual information to which we gain access in the course of our business. All Elekta Professionals should contribute to this goal by (I) avoiding gathering of any personal information with a purpose to dissemate except where necessary, (II) not disclosing any such information to any other Elekta Professionals or to third parties, except where this is necessary in order to fulfill Elekta’s assignment or contractual obligation, and (III) limiting access to personal information on Elekta Professionals, for use only for necessary, lawful and ethical purposes and in accordance with local data protection legislation, where applicable.
Product safety
Elekta is committed to providing the market with safe products and solutions. All products must comply with the legal requirements of the intended market places and compliance with relevant international and national standards for safety. Safety shall be managed throughout the product lifecycle including hazard analyzes and risk elimination/ mitigation. Elekta Professionals and Partners shall co-operate and strive toward continual improvement within this area.
Environmental issues
Elekta is committed to complying with all relevant environmental laws and regulations. Additionally, Elekta Professionals and Partners are required to fulfill the terms of Elekta Environmental Policy, which contains requirements over and above those demanded by law. Elekta is committed to minimizing any adverse effects of its operations on the environment whilst providing the community with the benefits of excellent, safe, environmentally sustainable products.
Environmental impact is minimized by reducing all types of operational and manufacturing waste, emissions to air and water and by avoiding the use of hazardous materials where ever practical.
Principles on bribery, money laundering and fraud
Elekta Professionals and Partners must never offer, promise, give, receive or demand a bribe or any other undue advantage to obtain or retain business. Remuneration to representatives or agents will be appropriate if for legitimate services performed only. In addition to compliance with local laws, Elekta is also committed to abiding by the principles on money laundering set out in relevant conventions against corruption.
Elekta Professionals and Partners should at all times use their good judgment to avoid the appearance of improper payments. Particular care should be taken in all relationships with government officials or employees.
Elekta should not contribute funds or make company assets available or otherwise support local political purposes, without prior written approval from the CSR Officer.
Elekta, Elekta Professionals and Partners should not participate in any type of fraud.
For purposes of this Code, the definition of fraud is when someone prepares or takes action to conceal or convert profit from specific sources to others for personal gain or to the personal advantage of others. Should suspicion of fraud arise the employees should contact the closest responsible manager or the CSR Officer.
Elekta is committed to complying with applicable anti-money laundering laws which exist in such parts of the world where Elekta is active. Elekta is therefore committed to only work with such Partners which are reputable, legitimate business operators whose funds come from legitimate sources. Elekta Professionals or Partners shall pay specific attention to payments to persons other than our contracting partners and according to existing contracts, cash payments etc.
Conflicts of Interest
Elekta respects the right of each individual Elekta Professional to take part in legitimate financial and other activities outside working hours. However, Elekta does require that such activities of Elekta Professionals as well as Partners are in keeping with applicable laws and that it does not put the Elekta Professional or Partner in a situation of conflict of interest in relation to Elekta.
All Elekta Professionals are expected to devote their best efforts and attention to the performance of their assignment with Elekta and to avoid situations that create an actual or potential conflict between personal interests and those of Elekta. A conflict of interest exists when the Elekta Professional’s loyalties or actions are divided between Elekta’s interests and those of another, such as a competitor, supplier or customer.
If the Elekta Professional in a particular situation is unsure as to whether a certain transaction, activity, or relationship constitutes a conflict of interest, he/she should discuss it with his/her immediate supervisor or the CSR Officer for clarification.
This guideline does not attempt to provide an exhaustive list of all possible conflicts of interest that could develop. Some of the more common conflicts from which you should refrain include:
- Accepting expensive personal gifts or entertainment from competitors, customers, suppliers, or potential suppliers, that is inappropriate (taking local standards and legislation into consideration), especially during periods of negotiation to enter into binding agreements, contracts, etc.
- Working for competitors, suppliers, or customers or holding significant shares in any such entities at the same time as holding a position within Elekta.
- Engaging in any work in competition with Elekta.
- Employing close relatives, especially when such relatives report directly or indirectly to the employing Elekta Professional.
- Developing a relationship with a subordinate employee of Elekta that could interfere with the exercise of impartial judgment in decisions affecting Elekta or employees of Elekta.
- Using proprietary or confidential Company information for personal gain or to Elekta’s detriment.
Care should also be taken to avoid risk of and actual conflict of interest.
It should be clear that this Code of Conduct does not intend to prevent Elekta Professionals and Partners from engaging in reasonable, business related entertainment within the normal course of business of Elekta and at limited value but in full compliance with local rules, regulations and standards.
Appropriate use of company property and funds
Elekta Professionals should use the company’s property and funds in a correct and efficient way and for fulfilling his/her work as an Elekta employee. Elekta does not accept any inappropriate use. Elekta has established internal control procedures to ensure that assets are protected and properly used and that financial records and reports are accurate and reliable. All Elekta Professionals are expected to refrain from converting assets of Elekta to personal use.
Competition
Adhering to laws and regulations, Elekta Professionals and Partners shall perform their business activities in a competitive manner and shall refrain from entering into anti-competitive arrangements with third parties. Elekta Professionals and Partners shall respect all local legislation on anti-competitive behavior. Such behavior, whether written or oral, may result in penalties for the Elekta Professional and Partner as well as to Elekta.
Examples of such non-competitive arrangements with competitors in which Elekta Professionals and Partners should not be involved are: (i) agreements with a competitor for the setting of any terms of sale, e.g. price, discounts and credit terms, (ii) rigged bidding, (iii) market or customer division between competitors, and (iv) boycotts.
All contacts with competitors must therefore be made with care and consideration, in order to avoid even the suggestion of anti-competitive behavior.
Some countries in which Elekta is active have restrictions on the use of e. g. exclusivity, controlling of reselling prices and territorial restrictions also for down-stream or upstream arrangements (i.e. for arrangements with distributors or suppliers). Therefore, any arrangements which may have an effect on free competition must be discussed with and approved by the CSR Officer.
Insider trading
All Elekta Professionals and Partners (and their close relatives, as per the definition in Swedish legislation) are expected to follow Swedish legislation and recommendations on insider trading (up to date rules and regulations can be obtained from the Elekta Legal upon request). The recommendations and legislation contain a prohibition to trade in stock or other securities of a company while having access to inside information on that company, as well as a prohibition to disclose inside information to another person which enables that person to trade based on this information.
In addition to this, Elekta Professionals and Partners shall comply with all local laws and regulations that may exist on insider trading, spreading of material, price-sensitive and non-public information and dealing in each region where Elekta is active.
4. Local variations
Elekta is active in many countries around the world, which leads to a wide variety of rules and regulations as well as proper business practices within the areas of our business and that of our Partners.
The Elekta Code of Conduct has been created in order to establish basic, generally accepted principles which are intended to be applicable in all parts of the world in which Elekta or its Partners do business. Thus, unless the Code of Conduct is contrary to local laws and regulations, the principles of the Code apply as basic requirements for all parts of our business as well as that of our Partners.
Based on these general principles, each region or legal entity may choose to establish such more detailed supplements for the region in question, which may be warranted for each particular case, in order to respect proper business practices in that region. Should such supplements be drawn up, they need to be in keeping with this Code of Conduct.
It is for the Board of Directors of each legal entity within a region to adopt such supplementary provisions.
An English language version of any adopted supplements should be submitted to the CSR Officer for review and filing.
5. Administration of the Code and handling of complaints
The CSR Officer shall report directly to the Elekta AB (publ) President and CEO and the Board of Directors on all issues related to this Code. The CSR Officer shall assist all Elekta managers in educating all Elekta Professionals and Elekta Partners upon request.
It shall be possible for the CSR Officer to delegate some of his/her responsibilities as a CSR Officer to other Elekta Employees.
All employees shall have access to the CSR Officer and be able to give feed-back on the compliance with the Code or bring forth allegations of suspected non-compliance with this Code with the CSR Officer without risking sanctions. Contacts with the CSR Officer may also be made anonymously.
The CSR Officer shall be responsible for monitoring compliance with the Code, e.g. through the conduct of recurring audits (external or self audits) or such other reasonable, appropriate means as the CSR Officer sees fit.
The CSR Officer shall also be responsible for reporting on compliance with this Code on a regular basis to the Elekta AB(publ) Board of Directors.
Should you have any questions, wish to make a complaint or bring up any issue relevant to the Code of Conduct please contact your immediate superior/manager or the CSR Officer on email csr@elekta.com or on phone +46 8 587 254 25.