Uppförandekod (engelska)

As employees you must at all times:

• respect and uphold the good name of MTG;
• act with honesty and integrity;
• obey all relevant laws and regulations in the countries in which you do business;
• abide by this Code;
• report any breach of this Code (or any other regulation or law) and co-operate with any enquiries

This Code applies to all employees of MTG (whether full or part-time) and to all temporary staff, and should be used alongside other MTG policies, guidance, work rules and contracts.

The Code applies in all countries and will prevail, subject to local law.  Failure to comply with any of the requirements of this Code may lead to disciplinary action.

Please note that this Code does not address all likely ethical dilemmas.  If you experience an ethical dilemma that is not covered within this Code of conduct – please consult your superior.

RELATIONS WITH COMPETITORS, CUSTOMERS AND SUPPLIERS

FAIR COMPETITION

As a Company…

• We are committed to free and open competition.
• We will comply with all competition and anti-trust laws wherever we conduct business.
• We will compete vigorously but honestly.

As employees…

• You should not engage in restrictive practices or otherwise act in contravention of anti-trust laws.
• You should take particular care to avoid contravening the law if meeting with competitors.
• Competitive intelligence must in all cases be gathered ethically and in compliance with laws and regulations that protect others’ proprietary information.

COMMERCIAL RELATIONSHIPS

As a Company…

• We should have sufficient information about competitors, customers and suppliers before we enter commercial relationships.
• MTG has strict procedures for entering into binding commercial relationships to minimise MTG’s exposure to risk.
• We avoid unnecessary litigation.

As employees…

• You should ensure that you have carried out research into any potential business partner.
• You should where possible attend meetings with business partners in at least equal numbers to the counterparty.
• You should have a financial approval and an appropriate authorised signatory(ies) before signing a binding agreement.
• You should seek resolution of disputes on favourable terms at an early stage.

CONFLICT OF INTEREST

As employees…

• You must not be involved with an activity for personal gain that is in conflict with MTG’s business interests.
• Any personal interests or interests of a member of one’s immediate family in relation to MTG’s business must be disclosed.
• A conflict of interest could include directorships, significant shareholdings, employment of family members and inter-company relations.

GIFTS AND INDUCEMENTS

BUSINESS GIFTS

As a Company…

• We believe that business decisions should be made for purely business reasons in the interests of MTG and not based on any favours that a supplier offers.
• The receiving of gifts, which could be construed as inducements to favour a supplier, is therefore strongly discouraged.

As employees…

• You may accept minor gifts as tokens of personal or professional esteem and with a value of 25 pounds sterling (and equivalent) or less.
• MTG has a “Notice to suppliers declaration”, which should be sent to all suppliers for clarification of our business gift policy.
• You must have prior approval of your Head of Department when giving a gift to a customer.
• In no case, however, may improper or illegal payments be made, directly or indirectly.

POLITICAL DONATIONS

As a Company…

• We do not participate in party politics or make donations to political party funds or candidates.

As employees…

• You must not make, offer, or authorise payments or inducements to political candidates, legislators, political parties, or party officials to secure sales or obtain favourable treatment.

PAYMENTS TO GOVERNMENT OFFICIALS

As a Company…

• We do not allow bribes, influence payments, kickbacks or other unlawful payments to any government or similar agency officials.  

As employees…

• You must not make, offer or authorise payments or inducements to government officials or employees of a local or national government or any similar agency, to secure sales or obtain favourable treatment.

INSIDER DEALING

As employees…

• You, your family and close acquaintances are subject to potential criminal liability with regard to trading shares and passing on material information that has not been made public and that could affect MTG’s or another public company’s share price. For further information regarding MTG’s insider dealing policy please see a copy of the Insider Rules available from Company Secretary, or at the Head Office in Stockholm. If you are an employee registered as an insider at the The Swedish Financial Supervisory Authority, you have received and confirmed written information regarding the insider rules in particular.

EQUAL OPPORTUNITIES

As a Company…

• We provide equal opportunities irrespective of race, ethnical background, religion, nationality, gender, mental or physical handicaps, marital status, age, sexual orientation, or any other status unrelated to the individual's ability to perform his/her job. 
• This applies to all employees, applicants for employment or promotion, suppliers, customers and members of the public with whom we come into contact.
• We value diversity. Employees from varied backgrounds enrich MTG’s culture and support our commercial success.
• We will not tolerate discrimination or sexual, physical or mental harassment (including bullying) of our employees.

As employees…

• You must not discriminate against anyone on the basis of race, ethnical background, religion, nationality, gender, mental or physical handicaps, marital status, age, sexual orientation, or any other status unrelated to the individual's ability to perform his/her job.
• Discrimination includes harassment. Abusive, harassing or offensive conduct is unacceptable, whether verbal, physical or visual.
• You have a personal responsibility to behave in a manner that is not offensive to others, and you must be sensitive to how others could perceive your behaviour. 

HEALTH & SAFETY

As a Company…

• We recognise the importance of health and safety within our business.
• We seek to provide a healthy, safe and clean working environment in line with local laws, regulations and industrial practice.

As employees…

• You must follow all environment, health and safety policies, procedures, and guidelines that apply to your workplace and exercise maximum care and good judgement.
• You must take appropriate steps to prevent accidents from occurring and eliminate hazards likely to cause accidents.

For more information, please see Health and Safety Policy

SMOKING

As a Company…

• We recognise that it is an individual’s right to smoke but it is also important that the rights of non-smokers are protected.

As employees…

• You may smoke only in designated smoking areas outside our offices. All our offices are smoke-free.

ALCOHOL AND DRUGS

As a Company…

• We do not condone the sale, purchase, possession, supply or consumption of controlled substances during working hours, whilst on MTG business or when using MTG vehicles. 
• However, we recognise that chemical dependency is an illness, and, commit to helping any employee should he/she acknowledge a problem.

As employees…

• You must not during working hours or whilst on MTG business or when using MTG vehicles sell, purchase, possess, supply consume or use controlled substances. 
• If you choose to drink alcohol (such as when you are entertaining customers) you are expected to limit your consumption to a reasonable level, and always to maintain an acceptable standard of behaviour.

More information can be found in the internal Drugs and Alcohol Policy.

CONFIDENTIALITY

As a Company…

• We respect and uphold the confidentiality of our employees, customers, clients and suppliers.
• We ensure that appropriate measures are taken to prevent unauthorised access to personal data.

As employees…

• You must not, except in the proper course of your duties, give anyone any information concerning the business dealings or affairs of MTG, any associate Company or its officers or employees. Confidentiality remains after your employment. 
• You shall not either during or after your employment disclose information from customers, clients and suppliers which you know to have been provided to MTG on a confidential basis.
• You must take particular care to ensure that security is maintained when any data is downloaded to personal computers, and in respect of printouts and derived material supplied to other users. 

USE OF COMPANY RESOURCES

As employees…

• You should to the maximum extent possible restrict use of MTG resources to the carrying out of MTG business – this includes email, internet, telephone and all other MTG resources. 

INTERNET POLICY

As a Company…

• We must protect ourselves against viruses, damage to our reputation and inappropriate use of work time.
• We maintain that all information downloaded from the internet, all messages sent and received are and remain the property of MTG, and we reserve the right to access employee emails and folder if deemed necessary.

As employees…

• You should not surf the internet or download information except for work purposes, and take particular care when opening email attachments. Download of software is not permitted. Don’t open unknown attachments from unknown sender.  
• You should respect the normal rules for acceptable behaviour in email correspondence.
  

More information can be found in the internal MTG IT Policy.

EXTERNAL COMMUNICATIONS

As a Company…

• We believe that the disclosure of information must be carefully managed to protect and promote MTG. PR and other dealings with the press and other media, is one of our most important tools. 

We have a policy that:

• for issues that effect MTG at a wider level, only the President, Chief Financial Officer and MTG’s Head of Press, are authorised to make comments to the media and to talk to politicians and other officials and to authorise other employees to do so.
• for country specific issues, only the Country Managers and Information Managers in each office are authorised to make comments to the media and to talk to politicians and other officials and to authorise other employees to do so. All comments are to be cleared by MTG’s Head of Press.

As employees…

• If you are approached by the press, you must refer them to the relevant press officer.  
• If you wish to contribute to other media by way of speeches, articles in trade papers and the like where it does not interfere with your obligations towards MTG and/or your work/performance, you must obtain permission from your Head of Department and from MTG’s Head of Press, who have the right to refuse such permission at their absolute discretion.

ACCEPTABLE STANDARDS OF BEHAVIOUR

As employees…

• When acting on behalf of MTG, you must behave within generally accepted standards of behaviour.
• Your actions must at all times be consistent with the MTG’s values.

DISCIPLINARY ACTION

BEHAVIOUR LEADING TO DISCIPLINARY ACTION

In addition to breaches of specific provisions of this Code, the employee’s contract and any local MTG rules, the following actions are deviations from acceptable standards of behaviour and will therefore be regarded as reasons for disciplinary action:

• Poor job performance including unacceptable quality of work, excessive errors or carelessness
• Poor time keeping
• Unauthorised absence
• Wasting work time
• Unseemly or disruptive conduct

Examples of conduct which may render an employee liable to summary dismissal include, but are not limited to, the following:

• Assault or attempted assault.
• Theft or attempted theft of either the employer’s or other employees’ property.
• Falsification of records.
• Insulting, aggressive or abusive behaviour.
• Indecent or immoral behaviour.
• Refusal to carry out a reasonable instruction given by management
• Serious or persistent breach of any terms set out in your contract of employment.

DISCIPLINARY PROCEDURE

Any breach of this Code, the employee’s contract or any local MTG rules may result in disciplinary action. The disciplinary procedure is subject to local laws and regulations, as well as local business standards. For more information, please contact your local HR department. 

GRIEVANCE PROCEDURE

The framework for resolving grievances, which you may have concerning any aspect of your employment with MTG, is based on the local regulations and standards in each country we operate in. For more information, please contact your local HR department.     

PUBLIC INTEREST DISCLOSURE (“WHISTLEBLOWERS”) POLICY

MTG has in place a procedure under which individuals who have reasonable grounds to believe that an incident of illegal activity, workplace malpractice or mismanagement, or a contravention of this Code has occurred, is occurring or is likely to occur within MTG, are able to raise their concerns without fear of retribution.

MTG encourages employees to raise their concerns about any incidents of malpractice in the work place at the earliest possible stage. For more information, see separate Public Interest Disclosure Policy section.