Anti-Corruption policy

Introduction

As part of LMG’s commitment to maintaining high standards of business conduct, direct or indirect participation in the giving or taking of bribes or the use of company funds or assets for any other illegal, improper or unethical purpose is unacceptable and prohibited. This commitment must be reflected in all aspects of the business. Therefore, there is an obligation to prevent Corruption and Bribery by adhering to this policy.

A detailed version of this policy will be provided by the Integrity Team (contact details below) upon request.

Objective

LMG and all its subsidiaries is committed to the prevention, deterrence and detection of bribery, fraud and any other corrupt practice. It is LMG’s policy to conduct all of its business activities with honesty, integrity and the highest ethical standards.

Scope and responsibility

This policy applies to all LMG and all its subsidiaries employees, officers, project trainees, temporary/contract staff, board members, etc. The policy also applies to all external stakeholders such as consultants, vendors, third parties or others working or acting on behalf of LMG.

No stakeholder may waive compliance with this policy.

Applicable laws and guidelines

All national/international laws on bribery and corruption that apply where LMG and its stakeholders have or may perform work.

If local laws or regulations establishes more stringent requirements, LMG will comply with such more stringent requirements.

Anti-corruption policy

• LMG expects all its Stakeholders to comply with the policy.
• LMG prohibits anyone acting on its behalf, including directors, officers, employees, or others performing functions on its behalf, from, directly or indirectly, giving or receiving improper Benefits.
• This policy prohibits any and all forms of Improper payments, including:
  • Payments to gain an undue advantage for LMG.
  • Payments to influence an act or decision by any Public official or employee in the private sector.
• This policy prohibits the receipt of Bribes by or for the Benefit of an LMG employee, supplier, agent, consultant, distributor, or business partner. The situations in which Corruption may most commonly occur are:

a. Gifts
b. Hospitality events
c. Facilitation payments
d. Business relations
e. Political, community and charitable contributions
f. Other misconducts

A. Gifts

1. The default position is that accepting and giving gifts or providing entertainment should be avoided unless they are moderate, proportionate, and legitimate and comply with applicable laws and company policies. Each employee must be careful not to violate the law by offering or accepting gifts and/or entertainment that could be construed as a Bribe, whether on behalf of the Company or for their own.
2. To determine whether an offered gift or entertainment is acceptable, the following should be followed:
   
   a. The giving or receiving of the gift should be left open (the benefit should normally be directed to the Company and not to a specific individual);
   b. The gift is made or received in good faith and without the intention of gaining an undue advantage;
   c. The value of the gift must be moderate and reasonable;
   d. Ordinary lunches and simple dinners can be considered as moderate;
   e. The giving or receiving of the gift must comply with the anti-corruption laws applicable to the Company;
   f. The giving or receiving of the gift must comply with LMG’s Code of Conduct and this policy;
   g. The gift must be fully documented in an identifiable manner, through receipts and accurately recorded in the Company’s books
   h. The gift must not be designed to be behavioral, i.e. influence or risk influencing the recipient’s decision or way of performing their duties. 
3. Before giving or receiving gifts, ensure that the value does not exceed the approved amounts.
4. LMG discourages the acceptance of any type of gift if the value of the gift exceeds 450 kr including VAT.
5. When receiving a gift whose value exceeds 450 kr including VAT, registration must be made clearly and correctly together with adequate documentation (required approvals, name and designation of the donor and the recipient, etc.). The same applies if the value of the gift is less than 450 kr including VAT on one occasion but is provided on repeated occasions. If the criteria in this paragraph are met, the gift register must be completed within 5 working days, both for the giving and receiving of gifts.

B. Hospitality events

1. Customer events may be offered or received when deemed legal and proper. It should be reasonable and comply with the accepted customary standards/practices and legislation of the country including meals, accommodation and transportation and customer specific hospitality events.
2. Cases where an individual must exercise extra care when accepting or offering hospitality events include the following:
   
   a. During business negotiations for the renewal or acquisition of new business;
   b. Interactions with the respective supplier before LMG awards any contracts;
   c. Interactions with government agencies or Public officials prior to government approvals.
   
3. Travel, Lodging & Boarding (except meals & refreshments) can be provided to Public official only when the same is required under statutory or contractual provisions. Hospitality events provided to customers require prior approval of the Integrity team. In addition to such approvals, the following procedures shall also be followed:
   
   a. Costs due to such activity must be clearly and accurately recorded in the accounts.
   b. There shall be adequate documentation (original receipts, required approvals, name and designation, etc.) to support such expenditure.
   c. A separate Customer Activity Request Form shall be completed and submitted to the Integrity Team for approval. See Appendix, Customer Activity Request.
   d. Monetary thresholds as per Company policy should be observed while offering hospitality. In case of any exceptions, the same should be explained and Integrity team while granting approval shall record rationale and justification for such exceptional expenses.
   
4. LMG discourages receipt of any type of hospitality/entertainment/travel by its internal stakeholders from its external stakeholders (including customers, vendors and other Third parties). Receipt of reasonable hospitality/travel by internal stakeholders from external stakeholders is permitted if arising out of business activities in normal course and the same shall be reported to the Integrity team within 5 working days. When assessing if hospitality/entertainment is reasonable the monetary threshold of SEK 2000 per person shall apply.The following is a list of possible red flags that may arise during the course of provision of gifts/ hospitality/hosting/entertainment/business courtesies (to private/Public official(s)), which may raise concerns under this policy. The list is not intended to be exhaustive and is for illustrative purposes only. If any Stakeholder(s) encounter any of these red flags, they must report them promptly using the procedure set out in our “Whistle Blower Policy”
   
   a. When demand is received for booking accommodation/travel at a location, which is different from geographic location of operations/purpose.
   b. Giving gifts/entertainment/hospitality/business courtesies during or immediately after a bidding process but before award of project.
   c. Demand for gift Items like liquor, wines, lavish meals, luxurious stays, spa facilities, visit to clubs/holiday homes, etc.
   d. Demand for personal favours,
   e. Demand for sexual favours, adult entertainment.
   f. Demand for extended stay in the disguise of inspections, audits, etc.
   g. Demand for lavish travel facilities during their visits, etc.
   h. Incomplete travel expenses (missing receipts/ inadequate descriptions) for concealing expenses.

Facilitation payments

Facilitation payments are prohibited and do not exist within LMG’s operations.

Business Relations

1. LMG’s business activities require maintaining business relationships with customers and Third parties. When dealing with such business relationships, LMG expects all Stakeholders to comply with this policy.
2. LMG shall demonstrate the highest standards of integrity and transparency. 
3. This policy prohibits corrupt offers, requests, demands, promises and payments made or received through Third parties.
4. LMG’s Third Party Due Diligence policy shall be applicable in relation to all LMG’s business relations. 

Political contributions / charitable donations / sponsorship

No political contributions or charitable donations or sponsorships shall be made by LMG. Moderate sponsorship of sports or corporate event or activities which are unrelated to LMG activities may occur. LMG shall comply with the tax rules on sponsorship.

Other misconducts

1. Misconduct related to fraud, cartels and other anti-trust/anti-competition offences, collusion, coercive practices or money laundering shall tantamount to a Corrupt practice and LMG strictly prohibits such practices across its business functions. LMG’s internal and external stakeholders should refrain from such kind of misconducts and in case if they become aware of same, it should be immediately reported to the Integrity Team. The business unit heads and function heads should ensure that respective business units / functions do not form any kind of cartel or engage in anti-competitive behavior while bidding for tenders, and the following shall apply:
   
   a. Disclosure of Engagement of Third Parties in the Bid submission. 
   b. Disclosure of complete information under Tender documents. 
   c. Specialized Training on misconducts for project leaders.
   d. Engagement of relatives of Politically Exposed Persons and engagement of Third party(ies) owned or controlled by Public Authority (including Politically Exposed Persons or their relatives). 
   e. Hiring of Former Public Officials. 
   
2. Unauthorised forms of benefits
   LMG may never provide, promise, or offer a Benefit to employees or contractors of another company or public body if the Benefit is related to: 
   
   a. monetary gifts, gift cards and similar items that are equivalent to cash;
   b. loans of money, provision of security (guarantee), waiver of debt, repayment of principal, interest and the like on terms which are not in conformity with market conditions;
   c. work on the premises of the recipient or the supply of goods or services for private purposes and on non-market terms;
   d. anything which is subject to conditions of consideration and is not accepted by the employer or principal of the recipient;
   e. a hidden commission to an employee or contractor (i.e. other than the enterprise);
   f. the provision of a vehicle, boat, holiday home or similar for private use;
   g. entertainment or holiday travel paid for in whole or in part; or
   h. offers which are considered to be generally unethical, e.g. sexual services or similar, visits to pornographic clubs.

Non-compliance and sanctions

Failure to comply with this policy may result in the following consequences for the Company including but not limited to:

a. Civil penalties for LMG including fines;
b. Serious damage to the reputation of LMG;
c. Debarment from tendering for contracts; and
d. The unenforceability of contracts entered into because of acts of Bribery, fraud or other illegality.

Failure to comply with this policy may result in the following consequences for employees, including but not limited to:

e. Personal criminal liability such as fines or imprisonment;
f. Disciplinary action initiated by LMG, including possible dismissal and termination of contracts with third parties; and
g. Personal reputational damage.

LMG shall not be liable for fines/penalties imposed on a Stakeholder for violation of law or this policy. 

Reporting of violations

LMG encourages its Stakeholders to report in good faith or based on a reasonable belief attempted and as soon as possible any suspected, attempted or actual Bribery, or violation of this policy.

All Stakeholders who report such suspicions are protected from retaliation in accordance with the Company’s Whistleblower Policy. 

This policy should be read in conjunction with LMG’s Whistleblower Policy.

Comments and amendment of this policy

LMG is committed to continually reviewing and updating policies and procedures based on experience and changes in relevant laws and regulations.

The Integrity Team monitors the effectiveness and reviews compliance with this policy and regularly evaluates its applicability, adequacy and effectiveness.

Any exceptions to this policy must be compliant with applicable laws and have the prior written approval of the Board of Directors.

Integrity team

The Integrity Team consists of the following persons. The head of the Integrity Team is Mats Berg who shall be the Integrity Compliance Officer (ICO).

In case of registering any complaint or for any questions about the policy, or if you want to request a full version of this policy, please contact the Integrity Team at the following email address:

elenore.roing@linjemontage.se
anders.akerberg@linjemontage.se
sofia.backstrom@linjemontage.se
mats.berg@linjemontage.se

Appendices

1. Employee ABAC declaration
2. Gift register
3. Request for customer activity

Last updated: 2023-09-01