Kojamo plc’s Code of Conduct for Suppliers

Responsible operations and legal compliance

Kojamo Group (hereinafter referred to as “Kojamo”) is committed to operating responsibly and transparently and in full compliance with laws and regulations. We demand that our cooperation partners throughout the supply chain observe the same standards of responsibility as well as the laws, regulations and national and international agreements that govern their operations.

This Supplier Code of Conduct is a set of guidelines drafted for Kojamo’s cooperation partners, and all of the participants of our supply chain are required to observe the principles described herein. The Supplier Code of Conduct applies to all of Kojamo’s purchasing activities. Our partners are responsible for their subcontractors’ ethical operating practices, the control thereto, and the responsibility and legality of their operations in accordance with this Supplier Code of Conduct.

Conflicts of interest

Kojamo and its cooperation partners shall steer away from any activities where the interests of the parties conflict. The business activities of a cooperation partner and Kojamo must not be significantly dependent on each other based on an overall assessment.

The cooperation partner, its person in charge or its beneficial owner should not be closely associated to a person working in Kojamo through a close business, family or friendship relationship. If an employee, who is in a relationship of the aforementioned nature, does not participate in negotiations or decision-making processes pertaining to the purchase or competitive tendering, purchasing from such companies may be
possible in case it is the most economically advantageous to Kojamo’s.

Anti-grey economy efforts

Kojamo’s anti-grey economy models exceed the legislative requirements in many respects. Partners who are in a business relationship with Kojamo and participate in the supply chain shall observe the provisions of the Act on the Contractor’s Obligations and Liability when Work is Contracted Out (Contractor’s Liability Act) and other applicable legislation. Kojamo’s cooperation partners shall comply with all laws and regulations pertaining to taxation and money laundering as well as all applicable economic
and trade sanctions.

Our partners are required to join the Reliable Partner service maintained by Vastuu Group Oy and the related reporting shall be kept up-to-date throughout the duration of the agreement. We monitor the information required by the Contractor’s Liability Act for all of the companies in our purchasing network.

Responsibility for the personnel

Our cooperation partners shall comply with the current employment legislation and collective bargaining agreements in all of their operations as well as regulations governing occupational health and safety, and commit to promoting these. Our cooperation partners shall also respect the human rights defined in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.

Our cooperation partners shall respect employee rights. Our cooperation partners shall commit to the equal treatment of employees regardless of their gender, age, origin, language, political and religious beliefs and any other factors. We do not condone any form of discrimination, harassment, bullying or threats in our cooperation partners’ operations. We do not condone the use of illegal labour, forced labour or child labour in our supply chain. If the countries of operation in our cooperation partner’s own supply chain does not have national legislation that prohibits the use of child labour, our partner shall implement regular procedures to ensure that no-one under the age of 15 is employed in the supply chain.

Our cooperation partners shall ensure safe and healthy working conditions for their employees in accordance with all applicable laws and regulations.

Our partners shall ensure that their employees act irreproachably and provide their employees with the freedom to unionise.

Bribery and corruption

Our cooperation partners shall not offer, give or accept bribes. All forms of bribery and corruption are prohibited in Kojamo Group’s supply chain.

Our cooperation partners shall not offer any inappropriate financial benefits to representatives of Kojamo or public officials with the purpose of promoting business operations or gaining any other advantage, here such benefits can be considered to be aimed at influencing decisions or gaining preferential treatment or where such benefits may otherwise seem inappropriate. Our current or potential cooperation partners shall not offer any bribes or benefits to Kojamo’s representatives in connection with contract negotiations.

Environmental responsibility

Our cooperation partners shall observe the principles of sustainable development in everything they do.

Our cooperation partners shall have an effective environmental management system, environmental programme or similar system that defines the general operating principles for promoting environmental responsibility and reducing environmental impacts. Our cooperation partners shall comply with the provisions of environmental legislation, decrees and permits. Our partners shall strive to reduce their environmental emissions, use eco-friendly products and improve their energy and resource efficiency. Our cooperation partners shall only hand over waste to parties that have the required permit to receive waste.

Protection of property and information

When handling confidential information and personal data, our cooperation partners shall always observe an especially high standard of responsibility and reliability as well as the applicable laws and regulations, data security practices, data protection practices and any detailed policies and guidelines potentially issued by Kojamo.

Kojamo’s property – including intangible assets, resources, premises, buildings and equipment – is intended to be used only for Kojamo’s business purposes. Kojamo’s property and resources shall not be used for illegal or unethical purposes. The same applies to all property of our cooperation partners that is in Kojamo’s possession.

All communication pertaining to Kojamo or related to cooperation with Kojamo shall only be undertaken with Kojamo’s consent and in cooperation with Kojamo.

Monitoring and reporting

We monitor the quality and performance of our partners in an appropriate manner. Our cooperation partners shall have appropriate and reliable operating methods and they shall be capable of offering a high level of delivery reliability. We ensure that our suppliers deliver high quality reliably by undertaking regular monitoring and collaboration and by using performance indicators set for our partners.

Where necessary, our partners must report to Kojamo on their operations in accordance with this Code of Conduct and their key sustainability indicators. The said information may be relevant to Kojamo for example regarding sustainability reporting.

Compliance with the Supplier Code of Conduct and other topical matters related to sustainability will be discussed in regular intervals as part of the annual cooperation meetings between Kojamo and the partner.

Kojamo also reserves the right to conduct also sustainability audits as part of its annual audit plan. The cooperation partner must participate free of charge at least to the first audit of a calendar year.

Violations of the Supplier Code of Conduct

All of our cooperation partners shall comply with this Supplier Code of Conduct. In the event that a partner is found to be operating in violation of this Supplier Code of Conduct, we shall terminate our cooperation with the partner with immediate effect. Violations may also lead to consequences under civil or criminal law.

Any observations of conduct in violation of the Supplier Code of Conduct must always be reported to Kojamo’s contact person without delay. Kojamo uses a whistleblowing system to facilitate the anonymous reporting of violations of the Supplier Code of Conduct. Any party who sincerely reports any potential violations shall not suffer any negative consequences. Reported incidents are processed as quickly as possible, in strict confidence and impartially.

This Supplier Code of Conduct was approved by Kojamo’s Board of Directors on 15 February 2024 and it will replace the Supplier Code of Conduct approved on 4 November 2020.

Page updated 21 February 2024