Anti-corruption policy

1. Purpose and Scope 

Airam’s good governance is based on the Code of Governance approved by the Board of Directors and appendices of the Code. The ethical principles guiding our operations and management are described in Airam’s Code of Conduct. The Anti-Corruption Policy is an appendix to the Code of Governance and complements both the Code of Governance and the Code of Conduct. It outlines our commitment to anti-corruption principles in all our business activities.  

All individuals working for Airam Electric Oy Ab, including employees, management, and members of the Board of Directors, are required to comply with this Policy. The same requirement applies to partners acting in Airam’s name or on its behalf. In addition, we expect our suppliers, subcontractors, and other business partners to commit to equivalent principles. 

All Airam employees are responsible for complying with Airam’s Code of Governance, Code of Conduct, this Anti-Corruption Policy, and all other applicable Airam policies and guidelines. All employees are required to familiarise themselves with this Policy and complete the training assigned to them. Regular training is provided to those employees whose roles expose them to the highest risk of encountering corruption-related risks in their work. 

2. Definitions

Corruption refers to the abuse of entrusted power for personal gain. In addition to financial benefit, gain may also include other, non-material advantages. Corruption commonly manifests itself through the offering and acceptance of improper benefits, conflicts of interest, favouritism, and unethical decision-making outside formal decision-making structures. Corruption also includes the misuse of one’s position to obtain a specific advantage. The most common form of corruption is the acceptance of an undue benefit, which is criminalised under the legislation of many countries.  

Bribery is a common form of corruption. Bribery generally refers to a gift, money, favour, service, or any other tangible or intangible benefit offered with the intention of influencing, or that could be perceived as influencing, the recipient’s actions or decision-making in favour of the giver or another party. A bribe does not necessarily need to be of significant value.  

A bribe is not given openly, and some form of consideration or benefit is expected in return. In practice, a bribe may take the form of a payment, facilitation payment, gift, hospitality, reimbursement of expenses, political or charitable donation, sponsorship, and/or promotional expenditure.  

A facilitation payment is a payment or service typically made or offered to a public official or another official party. The purpose of a facilitation payment is to expedite or facilitate the performance of a routine procedure, such as customs clearance, a tax inspection, or the processing of a permit. Facilitation payments are considered bribes. 

3. General Principles

Airam does not tolerate corruption or bribery in any form within its business operations. Airam applies a zero-tolerance approach to corruption and bribery. The consequences of violating this principle are described in the section “Breaches and Sanctions”. 

Corruption and bribery are illegal activities and may expose both Airam and the individuals involved to serious legal consequences. In addition, corruption and bribery damage Airam’s reputation and are contrary to Airam’s values.  

3.1. Giving and Receiving a Bribe

The offering, promising, acceptance, solicitation, or receipt of a bribe or any other improper payment or benefit for the purpose of obtaining an undue advantage is strictly prohibited. This prohibition applies both to direct transactions and to the offering, giving, requesting, or accepting of bribes through intermediaries.  

3.2. Conflicts of Interest 

A conflict of interest typically arises in situations where personal interests may conflict, or appear to conflict, with the interests of the employer. Airam employees must not pursue, directly or indirectly, personal gain or the interests of a related party while performing their work duties. Depending on the circumstances, conflicts of interest may also constitute corruption, and therefore they require particular attention and careful management. Examples of conflict of interest situations: 

• An employee or their relative or family member has a financial interest in a company that acts, directly or indirectly, as a supplier to or customer of Airam, or otherwise benefits from interactions with Airam. 

• Personal relationships between parties in recruitment situations or in a manager-subordinate reporting relationship. 

In situations involving a conflict of interest, whether internal or external, individuals must not participate in the decision-making process and must recuse themselves from making the decision. Any recusal must be documented in writing to ensure there is evidence of the decision to step aside. All conflict of interest situations must be reported to one’s own supervisor immediately upon becoming aware of them. 

3.3. Gifts and Hospitality 

The principles governing the giving and receiving of gifts and hospitality are set out in the Code of Conduct. Any gift or hospitality must constitute a customary business courtesy and must not improperly influence the outcome of business decisions, the selection of business partners, or the tendering and procurement of products or services. The distinction between a gift and a bribe may sometimes be unclear, and even a customary gift may be perceived as a bribe. Cash or cash equivalents (such as gift cards) must never be given or accepted as gifts. 

The offering or acceptance of gifts or hospitality is not permitted if Airam is engaged in a tendering process or contract negotiations with the respective counterparty. However, customary meeting refreshments, including a lunch of the standard typically provided in a staff canteen, are permitted. 

Only low-value (symbolic) gifts and very modest hospitality may be offered to public authorities and government officials. Particular care must be taken when dealing with public authorities and government officials to ensure that no actual or perceived attempt to influence their actions or decisions arises. 

With regard to business travel, the principles set out in the Travel & Representation appendix to the Code of Governance shall be followed. Airam may pay for either the travel expenses or the accommodation expenses of third parties (customers, suppliers, or other business partners), but not both, and not any other personal expenses. Similarly, the travel expenses or accommodation expenses of an Airam employee may be paid by a third party (customer, supplier, or other business partner), but not both, nor any other expenses related to the travel. 

The following monetary limits apply to the giving and receiving of gifts and hospitality: 

• Gifts: the value of an individual gift must not exceed EUR 100, and the total value of gifts given to a single recipient or received from a single party must not exceed EUR 200 per year. 

• Hospitality: the value of hospitality must not exceed EUR 200 per event, and the total value of hospitality offered to a single recipient or received from a single party must not exceed EUR 600 per year. 

When giving or receiving gifts and hospitality, the principle of equal treatment shall be followed, and efforts should be made to avoid repeatedly directing such benefits to the same individuals. The euro amounts stated above include value-added tax (VAT). 

Exceptions to the rules governing gifts and hospitality are permitted only in exceptional circumstances and only with the approval of Airam’s Managing Director. Any exceptions involving the Managing Director must be approved by the Chair of Airam’s Board of Directors. All exceptions must be documented in a separate Gifts and Hospitality Register, the maintenance of which is the responsibility of Human Resources (HR). 

3.4. Donations and Sponsorship 

Donations and sponsorships must be appropriate from a business perspective and aligned with Airam’s values. Donations and sponsorships must not be used to obtain any undue business advantage. 

Airam makes charitable donations. Making a donation to a third party is prohibited if the donation is accompanied by an expectation of reciprocity between Airam and the third party. 

Airam may enter into sponsorship agreements with selected organisations or initiatives. Particular care must be exercised when selecting sponsorship partners, and the principles set out in this Policy must be followed. 

Airam may support events and activities organised for customers or other stakeholders. Such support must be aligned with Airam’s values, general operating principles, and the principles of this Policy, and must be directed towards events and activities that support Airam’s business operations. 

Decisions regarding donations and sponsorships shall be made in accordance with the approval limits defined in the Code of Governance. Each decision must be recorded in the Gifts and Hospitality Register. 

3.5.   Third Parties

Due diligence must be applied when conducting business through third parties (”intermediaries”), as the use of third parties carries an increased risk of corruption and bribery. Airam may be held liable if a third party acting on Airam’s behalf engages in corruption or bribery.  

Where third parties are used, only reputable and qualified agents, consultants, or other representatives shall be selected. Their selection must comply with Airam’s guidelines for the engagement of external service providers. The services provided by third parties must be transparent and reasonably priced and must not include bribes or payments intended to facilitate services other than those for which they have been engaged. 

A written agreement must be concluded with the third party before the cooperation begins. The agreement shall specify the services to be provided by the third party, the pricing of those services, and the documentation and detailed reporting to be provided to Airam regarding the performance of the services. The agreement shall also include a commitment to Airam’s ethical principles, and Airam’s Supplier Code of Conduct shall be attached as an appendix to the agreement. 

3.6. Dealing with Authorities 

Public authorities and other public-sector entities are often subject to stricter rules and restrictions than private-sector organisations. Due diligence must be applied when dealing with public authorities or public officials. The definition of a public official is very broad and includes officials of central and local government, employees of public agencies, and may also extend to employees of state-owned enterprises. The definition of a public official may vary from country to country.  

Facilitation payments must never be offered or paid to public authorities or public officials under any circumstances. Such payments are unambiguously prohibited. 

4. Breaches and Sanctions 

Each employee is responsible for familiarising themselves with this Policy, understanding its contents, and complying with its requirements. In situations of uncertainty, employees should discuss the matter with their supervisor or contact Airam’s Sustainability Specialist.  

Violations of this Policy will be addressed in accordance with Airam’s standard employee management and disciplinary practices. Consequences for breaches of this Policy follow the general framework of employment-related disciplinary measures. Depending on the nature and severity of the violation, it will generally be considered either a neglect of duties during employment or a serious misconduct. 

5. Disclosure requirement 

Every Airam employee has a duty to report any suspected or actual violations of this Policy or applicable laws that they become aware of, either to their direct supervisor or to Airam’s Sustainability Specialist: sustainability@airam.fi. Observed or suspected violations may also be reported anonymously through Airam’s whistleblowing channel, which is available on Airam’s website. The reporting obligation also applies in situations where an employee has declined a gift, hospitality, or other benefit oekijä on kieltäytynyt tarjotusta lahjasta, kestityksestä tai muusta edusta tämän politiikan perusteella.