Environmental, Social and Governance Policy - Badrap Oy

This Environmental, Social and Governance Policy has been approved on 2024-12-31 by the board of directors to be used at Badrap Oy.

Corporate Responsibility Statement

Safety, security and privacy of our customers, society, people, our employees and our partners are the highest priorities for us. We follow laws, regulations and good corporate governance practices. We respect human rights, labour rights, consider the environment and have anti-corruption measures. Our Code of Conduct has short policy statements on Environmental Protection, Health and Safety, Open Source and Community Work, Security Research, Child and Forced Labour, Anti-Bribery, Competition, Anti-Discrimination, Anti-Harassment, Taxes and Export Control.

Code of Conduct

Our environmental, social and corporate governance (ESG) policies are the basis for our Code of Conduct. Our ESG policies are approved by our board. We periodically review and communicate our Code of Conduct to our staff, suppliers and partners. Our Code of Conduct is public and it is shared openly.

Supplier Code of Conduct

Our Code of Conduct and its major updates are communicated to the suppliers and partners and we expect them to uphold the same standards and to obey the legal obligations and local regulations.

Anti-Bribery Policy

We have zero tolerance towards acts of bribery and corruption, by any employee or anyone acting on our behalf. We, our partners and suppliers should "not engage in any act of corruption, including the offering, promising or giving of any undue pecuniary or other advantage to public officials or employees of persons or entities with which an enterprise has a business relationship or to their relatives or associates. ... Enterprises should not use third parties or other intermediaries, including, inter alia, agents, consultants, representatives, distributors, consortia, contractors and suppliers and joint venture partners for channelling undue pecuniary or other advantages to public officials, or to employees of persons or entities with which an enterprise has a business relationship or to their relatives or associates.". See also further guidelines in chapter "Combating Bribery and Other Forms of Corruption" in OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.

Competition Policy

We foster fair competition, ethical practices and transparency throughout our business dealings. We will carry out our activities in a manner consistent with all applicable competition laws and regulations, taking into account the competition laws of all jurisdictions in which the activities may have anti-competitive effects. We will refrain from entering into or carrying out anti-competitive agreements, including agreements to: a) fix prices; b) make rigged bids (collusive tenders); c) establish output restrictions or quotas; or d) share or divide markets by allocating customers, suppliers, territories or lines of commerce. See also further guidelines in chapter "Competition" in OECD Guidelines for Multinational Enterprises on Responsible Business Conduct.

Anti-Discrimination Policy

We have zero tolerance for discrimination, see https://yhdenvertaisuusvaltuutettu.fi/syrjinta (Finnish) and https://yhdenvertaisuusvaltuutettu.fi/en/discrimination (English). We follow the Finnish law on non-discrimination.

Anti-Harassment Policy

We prohibit harassment of any kind. Incidents should be reported to the management and will always be investigated. Retaliation is strictly prohibited.

Child & Forced Labour Policy

We forbid use of child and forced labour as defined by the Finnish laws, see Laki nuorista työntekijöistä and Valtioneuvoston asetus nuorille työntekijöille erityisen haitallisista ja vaarallisista töistä.

Environmental Policy

As a bare minimum we, our suppliers and partners are to follow environmental laws, in Finland see Luonnonsuojelulaki. However, we strongly encourage going beyond that. We will be periodically reviewing United Nations' Sustainable Development goals for goal setting and adoption in our operations.

Health and Safety Policy

We follow Finnish laws for health and safety in employment and workplace, see Työterveyshuoltolaki and Työturvallisuuslaki. Local laws should be respected abroad.

Open Source and Community Work

Our employees and suppliers are encouraged to participate in community efforts such as developing and contributing to free open source software (FOSS). Contributing to the common good is a shared interest.

Security Research

Our employees and suppliers who participate in security and vulnerability research are encouraged to work responsibly and disclose any findings with care.

Tax Policy

We have a zero tolerance to tax evasion and the facilitation of tax evasion. We are not engaged in aggressive tax planning. Our headquarters is in Finland and we follow local tax laws in regions where we operate.

Export Control & Sanctions

We comply with applicable export control laws, and international trade sanctions.

Standard Clause for Suppliers and Partners

All Suppliers and Partners can include the following standard clause (or equivalent content in their own language) into their contract terms to demonstrate their willingness to uphold our ESG standards.

"The Supplier/Contractor/Partner has received a copy of the Company's Code of Conduct at https:/docs.badrap.io/esg.html and agrees to uphold or to exceed the same standards and to obey legal obligations and local regulations."