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Code of Conduct

We want to do what is right – our Whistleblowing Service

We strive to maintain transparency as well as high business ethics. Our whistleblowing service provides an opportunity to communicate on suspected wrongdoings affecting people, our organisation, society or the environment. The whistleblowing service makes wrongdoings less likely to occur in the first place and shows our commitment to operate in a fair way. You do not need proof of your suspicions, but all messages must be made in good faith.

You can raise your concern anonymously by using our Reporting channel, managed by a third-party.

Reporting channel, allowing anonymous messaging and dialogue: https://report.whistleb.com/en/eos

The whistleblowing service is provided by an external partner WhistleB, Whistleblowing Centre, to ensure anonymity. The communication channel is encrypted and password-protected.

All messages will be processed in confidence.

1. INTRODUCTION

Purpose of this guidance is to make sure that all the subcontractors, suppliers and all companies concerning the supply chain of the EOS Group will require common ethical principles.

Code of conduct (”Code”) illustrates the values according to which EOS operates globally.

Code applies every company and their employees which are included to the EOS Group supply chain.

Compliance with this guide is strictly required.

By signing this Code, supplier will inform that it knows its own supply chain and commits to these Code of Conduct principles.


2. LEGAL COMPLIANCE

2.1 Ethical Conduc

  • EOS maintains all the applicable laws, regulations, and good manners in our business. EOS does not accept any illegal actions and we require that our suppliers will operate its business according to current local legislation.
  • In any operations, the supplier should be committed to ethical conduct and the respect for human rights in the spirit of the United Nations’ Universal Declaration of Human Rights.
  • Supplier will be under an obligation to orient with regulations and act as required. Supplier shall also make sure that its supplier and subcontractors act as required. If necessary, supplier must be able to demonstrate how to ensure that their subcontractors comply with the Code.


2.2 Corruptive practices

  • EOS expects its suppliers to have zero tolerance towards bribery and corruption. Supplier shall not engage in any form of bribery or kickback scheme or otherwise offer any incentive to EOS employees or their family or friends in order to obtain or retain any business.
  • Reasonable business courtesies, including gifts (max. 100€) and corporate hospitality (e.g. entertainment, business lunches and small gifts) are permitted, provided that they are given in compliance with applicable laws.


3. LABOR AND HUMAN RIGHTS

3.1 Labor

  • EOS respects and promotes human rights as they are defined in the United Nations’ Universal Declaration of Human Rights.
  • Supplier shall not use child- or forced labor under any circumstances or contract with subcontractors or suppliers in any point of supply chain using such labor.
  • EOS cherishes diversity and encourages fair and equitable treatment in every aspect in the supplier section. EOS will not accept any harassment or discrimination from supplier’s side either.


3.2 Health and safety

  • Supplier shall provide its employees a safe and healthy working environment in compliance with all applicable local laws and regulations.


3.3 Environment

  • Supplier shall make all reasonable effort to protect the environment and to keep the impact of its activities and products as low as possible.
  • Supplier shall obtain, maintain and comply with all needed environment permits and licences and EOS’ requirements for own operations


4. MONITORING AND IMPLEMENTATION

4.1 Monitoring of the Code

  • Supplier shall regularly monitor its conformance with the Code.
  • Upon request, the supplier shall provide EOS access to all relevant information and documents needed to verify the supplier’s conformance with the Code.
  • If the supplier has, in reasonable opinion of EOS, materially violated the Code, EOS is entitled to terminate the business relationship with immediate effect.
  • If the supplier has a serious concern that something is not consistent with this Code, the supplier should notify EOS’contact person.


4.2 Implementation of the Code

The implementation of this Code is based on the uncompromising example of the top management of and all supervisors employed by EOS.

Acting in breach of this Code has a detrimental effect on EOS Group’s brands and trust in EOS Group in addition to potentially causing significant business-related and personal liabilities. Each employee must ask for help when necessary and to immediately inform of any suspected or observed breaches. EOS’ confidential whistleblowing channel, https://report.whistleb.com/en/eos, must be used to inform EOS of any concerns or breaches, and employees are obliged to assist in any investigation into suspected inappropriate conduct if necessary. EOS Group’s operating principle is to prevent unethical and unlawful conduct and to intervene in such conduct as quickly as is reasonably possible after EOS Group has become aware of such conduct.

All whistleblowing reports are treated confidentially to the extent allowed by applicable law and when taking into consideration the Group’s obligation to investigate the conduct disclosed in the said reports. The identity of the employee who submitted the report will similarly be kept confidential. Employees are obliged to keep confidential any investigations they become aware of as well as the details of such investigations.


4.3 Publicity

  • Unless otherwise agreed upon, the supplier is not entitled to publicize its cooperation with EOS and use EOS trademarks without EOS’ written permission.
  • For further inquiries, please contact Purchasing Director Frank Bildat (frank.bildat@eos-sauna.de).


5. APPLICABILITY

  • Supplier shall confirm that it, and its suppliers, subcontractors and other possibly partners will comply with principles of this Code.
  • Agreeing cooperation with EOS Group’s companies supplier shall ensure that its suppliers, subcontractors and other partners comply with the principles of the Code.


EOS Code of Conduct

Whistleblowing guidelines

1. Introduction – what is whistleblowing, and why is it important?

Our organisation strives to achieve transparency and a high level of business ethics. Our whistleblowing service offers a possibility to alert the organisation about suspicions of misconduct in a confidential way. It is an important tool for reducing risks and maintaining trust in our operations by enabling us to detect and act on possible misconduct at an early stage. Whistleblowing can be done openly or anonymously.


2. When to blow the whistle?

The whistleblowing service can be used to alert us about serious risks of wrongdoing affecting people, our organisation, the society or the environment.

Reported issues include criminal offences, irregularities and violations or other actions in breach of EU or national laws within a work-related context, for example:

  • Corruption and financial irregularities; for example, bribes, unfair competition, money laundering, fraud, conflict of interest
  • Health and safety violations; for example, workplace health and safety, product safety, serious discrimination and harassments that are against the law
  • Environmental violations; for example, illegal treatment of hazardous waste
  • Privacy violations; for example, improper use of personal data

Employees are asked to contact their supervisor or manager for issues relating to dissatisfaction in the workplace or related matters, as these issues cannot be investigated in the scope of whistleblowing.

A person who blows the whistle does not need to have firm evidence for expressing a suspicion. However, deliberate reporting of false or malicious information is forbidden. Abuse of the whistleblowing service is a serious disciplinary offence. 


3. How to blow the whistle?

There are different ways to raise a concern:

  • Alternative 1: Contact a supervisor or manager within our organisation.  
  • Alternative 2: Anonymous or confidential messaging through the whistleblower reporting channel to the whistleblowing team: report.whistleb.com/en/eos

All messages received will be handled confidentially. The whistleblowing channel is administrated by WhistleB, an external service provider. All messages are encrypted. To ensure the anonymity of the person sending a message, WhistleB deletes all meta data, including IP addresses. The person sending the message also remains anonymous in the subsequent dialogue with responsible receivers of the report.


4. The investigation process

The whistleblowing team

Access to messages received through our whistleblowing channel is restricted to appointed individuals with the authority to handle whistleblowing cases. Their actions are logged and handling is confidential. When needed, individuals who can add expertise may be included in the investigation process, upon consent from the whistleblower in case identity of the reporting person is disclosed. These individuals can access relevant data and are also bound to confidentiality.

Receiving a message

Upon receiving a message, the whistleblowing team decides whether to accept or decline the message. If the message is accepted, appropriate measures for investigation will be taken, please see Investigation below.

The whistleblower will receive an acknowledgment of receipt of the report within 7 days.

The whistleblowing team may not investigate the reported misconduct if:

  • the alleged conduct is not reportable conduct under these Whistleblowing guidelines
  • the message has not been made in good faith or is malicious
  • there is insufficient information to allow for further investigation
  • the subject of the message has already been solved

If a message includes issues not covered by the scope of these Whistleblowing guidelines, the whistleblowing team should provide the reporting person with appropriate instructions.

The whistleblowing team will send appropriate feedback within 3 months upon the date of receiving the report.

Investigation

All messages are treated seriously and in accordance with these Whistleblowing guidelines. 

  • No one from the whistleblowing team, or anyone taking part in the investigation process, will attempt to identify the whistleblower.
  • The whistleblowing team can, when needed, submit follow-up questions via the channel for anonymous communication. 
  • A message will not be investigated by anyone who may be involved with or connected to the wrongdoing.
  • Whistleblowing messages are handled confidentially by the parties involved.
  • Corporate or external expertise may be included in the investigation upon consent from whistleblower.


5. Protection and privacy

Whistleblower protection

A person expressing genuine suspicion or misgiving according to these guidelines will not be at risk of losing their job or suffering any form of sanctions or personal disadvantages as a result. It does not matter if the whistleblower is mistaken, provided that he or she is acting in good faith.

Subject to considerations of the privacy of those against whom allegations have been made, and any other issues of confidentiality, a whistleblower will be kept informed of the outcomes of the investigation into the allegations.

In cases of alleged criminal offences, the non-anonymous whistleblower will be informed that his/her identity may need to be disclosed during judicial proceedings.

PROCESSING OF PERSONAL DATA

This whistleblowing service may collect personal data on the person specified in a message, the person submitting the message (if not sent anonymously) and any third person involved, in order to investigate facts on the declared misdeeds and inappropriate behaviour eligible under our code of conduct or internal rules. This processing is based on statutory obligations and the legitimate interest of the controller to prevent reputational risks and to promote an ethical business activity. The provided description and facts under this processing are only reserved to the competent and authorized persons who handles this information confidentially. You may exercise your rights of access, of rectification and of opposition, as well as of limited processing of your personal data in accordance with the local data protection legislation. These rights are subject to any overriding safeguarding measures required to prevent the destruction of evidence or other obstructions to the processing and investigation of the case. Data is stored within the EU. For any further questions or complaints please address your request to info@eos-sauna.de

DELETION OF DATA

Personal data included in a whistleblowing messages and investigation documentation is deleted when the investigation is complete, with the exception of when personal data must be maintained according to other applicable laws. Permanent deletion is carried out 30 days after completion of the investigation. Investigation documentation and whistleblower messages that are archived will be anonymised under GDPR; they will not include personal data through which persons can be directly or indirectly identified. 

PERSONAL DATA CONTROLLER:

EOS Saunatechnik GmbH is responsible for the personal data processed within the whistleblowing service.

PERSONAL DATA PROCESSOR:

WhistleB Whistleblowing Centre Ab (World Trade Centre, Klarabergsviadukten 70, SE-107 24 Stockholm) responsible for the whistleblowing application, including processing of encrypted data, such as whistleblowing messages. Neither WhistleB nor any sub-suppliers can decrypt and read messages. As such, neither WhistleB nor its sub-processors have access to readable content.