Code of conduct

Doing the right thing

At Sensys Gatso Group AB (publ), one basic principle guides everything we do: doing the right thing. For us, that means doing business ethically — not only observing the laws and standards that apply to us, but acting honestly and fairly in all our dealings, and taking responsibility for our actions and their consequences. It is a principle we ask of ourselves, and one we encourage our partners to share.

Taking responsibility

We are committed to protecting and promoting human rights wherever we operate. We do not accept child labour, forced labour, physical punishment or mistreatment in any form, and we comply with employment laws in all countries where we work. Everyone at Sensys Gatso has a part to play. We treat each other with mutual respect and trust, and we work together as one team towards shared goals. Violence, discrimination and harassment have no place in our company. This same spirit of fairness and respect extends to our relationships with suppliers and customers.

Confidential information

Information is one of our most valuable assets. Employees are obliged to safeguard company-confidential information, including new products and marketing plans, manufacturing processes, research and development concepts, as well as information on potential corporate investments. This responsibility continues even after employment has ceased.

Insider information

Employees at all levels will come into contact with information that could affect the price of Sensys Gatso shares, or shares in other companies, should the information become public. An example of such information would be new products, the winding up of activities, new manufacturing processes, information on acquisitions and sales, expansion or mergers, and acquisitions. Revealing this information to someone – even family members – before it has been made public can result in the employee and company facing criminal proceedings.

Insider trading is both unethical and illegal. So please be aware of and respect Sensys Gatso's “Silent periods”.

Accurate information

Sensys Gatso expects all information relating to its business activities to be complete and correct. It also expects all published information to be complete, impartial, up to date, correct and intelligible. It is therefore not acceptable for an employee to encourage or order another employee to act any differently.

Information channels

Inquiries about financial or business information concerning Sensys Gatso received from the media, press, financing companies, or the public should be directed to the company's CEO. It is essential that employees do not respond to such inquiries or contact themselves, as any inappropriate incorrect response, including a denial or a protest concerning the information, can result in negative publicity and could also seriously damage the company.

This policy does not apply to inquiries concerning publicly available financial information, such as annual or quarterly reports, or the company's promotional publicity activities.

Common sense

The following guidelines apply for the most common situations involving a conflict of interest: 1. Do not make any investments that could influence your business decisions. Sensys Gatso's policy includes a ban on employees owning shares or having a proprietary interest in any company that competes with Sensys Gatso. This ban does not apply if an employee owns a small number of shares in a listed company.

2. Ask for a go-ahead from your manager before doing business on behalf of Sensys Gatso with a company where you or a close family member could in some way benefit from your actions.

3. Do not work for a supplier, customer or competitor whilst employed at Sensys Gatso and do not carry out work for or provide assistance to any third party if there is a chance of this having a negative influence on your ability to perform your job or your opinion of your job.

4. Be aware of the fact that another member of your household could be employed in a position that could create or appears to create a conflict of interest.

If this situation arises, please ask your manager for guidance.