Ratos AB

The board holds the overall responsibility for Aibel's sustainability performance. The CEO and the executive management team (EMT) are responsible for establishing the company's sustainability agenda in compliance with the relevant governing documents. The day-to-day responsibility rests with the Sustainability Committee, which consists of specialists from several departments within the company (see figure for details). Union representatives are invited to participate and give input on the sustainability work. The committee reports continuously on its efforts to the Executive Management Team. [...] Aibel has a dedicated Ethics and Compliance department and a fully integrated compliance programme developed through a robust organisational culture and a clear directive from the top, including owners, the board and executive management. The Compliance department reports to the management group and the Board of Directors on a quarterly basis, providing a comprehensive annual report for a more thorough overview. Moreover, Aibel's owners actively participate in reinforcing our unwavering commitment to a resilient compliance programme and a sustainable mindset. Our comprehensive programme encompasses all critical elements of an effective compliance system, including training initiatives and regular audits. The anti-corruption programme is in line with the requirements set out by the Foreign Corrupt Practices Act (FCPA). [...] To mitigate these risks, we have implemented various risk-reducing procedures and processes. Of notable significance is our Country Risk Assessment procedure, which encompasses a comprehensive evaluation of factors such as corruption risk, political climate, economic conditions, safety and security measures, sanctions, human rights considerations and labour standards. This multifaceted approach is instrumental in fortifying our compliance framework and ensuring responsible business practices.

Semcon has an informal process where ethical concerns, including ethical concerns linked to customer assignments, shall be escalated and evaluated by Semcon's Ethical Committee (which consists of the Group Management and the Head of Sustainability). [...] Semcon has a whistleblower policy and a whistleblower reporting system, accessible on our website, where employees, customers, suppliers, other business partners, and third parties can report suspected breaches of applicable laws, violations of Semcon's Code of Conduct, and any other material irregularities that they may be hesitant to report through regular channels. Reports are submitted anonymously through an online tool, available on our website, and the policy explicitly prohibits retaliation against whistleblowers. The submitted reports undergo thorough review by both internal and independent external recipients, ensuring that the information is handled correctly and impartially. [...] The Board of Directors has the overall responsibility for ensuring that Semcon has a sustainable strategy with relevant targets that is aligned with applicable laws and regulations and selected standards. The responsibility for developing and proposing updates of Semcon's strategy, material topics, sustainability targets, purpose, values and mission statements, Code of Conduct, etc. is delegated to the CEO and material revisions thereof shall be evaluated together with, and approved by, the Board. The CEO is supported by Semcon's Head of Sustainability (who reports directly to the CEO, but is not a member of Group management), the Human Resource function, the Legal Team, Finance, as well as the Country Managers and other functions, see page 50 for further details. [...] Sustainability-related risks are included in Semcon's overall ERM process, as further detailed on page 46, and assessed by the Audit Committee. Updates of the internal sustainability agenda is addressed in one Board meeting each year, as well as ad hoc on a need basis. The external sustainability agenda is integrated into Semcon's ordinary business development process and business plans, which are presented to the Board of Directors and assessed regularly in business review meetings.