Code of Conduct  in Last Mile 

CEO's words.

Last Mile is a company that delivers products and services to critical and important infrastructure within society. Our customers and other stakeholders expect us to operate in a sustainable manner and to demonstrate their trust. We manage a great responsibility whether we help build infrastructure for large professional companies or are invited into the homes of our customers.  

Our Code of Conduct summarizes and clarifies the rules that apply to everything we do in our workplaces, with our customers and when representing Last Mile in every context. The Code of Conduct applies not only to all employees in Last Mile, but also to all contractors, subcontractors, manufacturers, and others we cooperate with.  

We shall be proud of our values, our ethical standards, and the way we run our business. We set high standards for ourselves. If we comply with our code of conduct, we will build the trust we depend on to succeed.  

Our mission and values  

Last Mile's mission is to "create increased competitiveness and profitability for our customers through streamlining and industry specialization". Together with the rest of our industry, we play a key role in the green shift and digitalization of society. While our deliveries contribute to a sustainable future, we are also expected to operate in a sustainable manner, which in turn means that our business must maintain a high ethical standard.  

Our values Efficient, Solution-oriented and Passionate, underpinned by high competence, reflect important aspects of Last Mile's culture that are also reinforced when we act in accordance with our code of conduct.  

Efficient means that we have a continuous focus on improving efficiency in processes, structure, and our work. 

By complying with our code of conduct, we ensure that everyone who works for and with us has an attitude that all challenges can be solved. Solution-oriented therefore means that we always aim for solutions, whether it is for a customer, for our colleagues or to contribute to our society. 

Being passionate means that we are passionate about what we do and do everything we can to deliver the best possible. At the same time, we are committed to creating safe and good workplaces, delivering what we promise to customers and owners and being good neighbors in the communities where we operate. 

High and correct competence is something we should have, and not least continuously develop so that we can live our values, every single day. 

Careful compliance with our Code of Conduct is the best guarantee that we will achieve our goals.  

Purpose  

This Code of Conduct has been established to clarify the requirements that apply to our business. By describing these requirements, we make it easier to understand how to act in given situations and when we are faced with ethical dilemmas.  

It will never be possible to fully describe guidelines for all situations that may arise. It is therefore important that in case of doubt as to what is the right decision or procedure, one consults with one's immediate superior or colleagues.  

Validity  

The ethical guidelines apply to all permanent and temporary employees in Last Mile, as well as contractors and contractors under our control, hired consultants, as well as board members and other employee representatives.  

Specifically, this means in practice that everyone who works in, or for Last Mile, must be familiar with and comply with our ethical guidelines.  

We expect all our business associates to maintain the same standards as us and therefore seek to avoid interacting with others who do not support our values and are willing to adhere to the same Code of Conduct as us.  

If there is no correspondence between our code of conduct and other internal governing documents, guidelines and requirements, our ethical guidelines will always take precedence, unless other requirements reflect a higher standard than what is stated in the ethical guidelines.  

Laws and regulations represent minimum requirements for Last Mile.  

Integrity, respect, and personal responsibility 

Compliance with this policy is a personal responsibility. Violations of the Code could have consequences for Last Mile's reputation, integrity, and legitimacy of the business, as well as major financial consequences.  

Last Mile will never accept unethical behavior. Violations of ethical guidelines, laws and regulations and other relevant requirements may therefore, depending on the severity, result in dismissal, reporting and other possible consequences.  

Sustainability and our Code of Conduct  

By complying with the Code of Conduct, we contribute to Last Mile conducting  its business in a sustainable manner. By actively using the Code as a guideline for the way we conduct our business, we will show care for the people affected, avoid negative effects on the environment and society and manage the company's resources in an efficient manner in line with long-term public interests. 

System Description  

Last Mile's system for ensuring compliance with our Code of Conduct consists of the following elements.  

• Description of the Code of Conduct, their validity and how to understand them – our Code of Conduct document.  

• Our values  

• Continuous competence measures for our employees 

• Management systems (ISO 9001), policies, guidelines, and other governing documentation with requirements for execution and conduct.  

• Internal control systems with the purpose of preventing, detecting nonconformities, treating nonconformities, and improving.  

Culture of openness and whistleblowing  

The basis for learning is a culture where challenges and problems can be addressed in an open and honest way, without fear of reprisals or other unpleasantness. We will therefore ensure that we maintain such a culture in the company, with openness and high ceilings.  

Everyone who works in or for Last Mile has both the duty and the right to report censurable conditions if they become aware of this. Censurable conditions mean violations of legal rules, written ethical guidelines or ethical norms.  

Last Mile emphasizes transparency and facilitates that it is safe to report incidents in all parts of the organization.  Last Mile will not tolerate any form of retaliation. 

Notification may be made to the immediate manager, the manager's manager, employee representative, safety representative, CEO, or other employee representative internally.  

The notification rules do not apply to matters that are only related to the employee's own working conditions, such as personnel conflicts or disagreements related to the employment contract.  

Caring for each other  

Health and Personal Safety 

Our goal is that no one should be harmed or have impaired health because of our activities. All activities involve risk, but we believe that by systematic work, all undesirable incidents can be prevented. This means that we place high demands on how we run our business, follow best practices, and ensure that everyone has the necessary expertise and the right tools to perform their duties.  

A key prerequisite for success is that each employee shows care for others and takes personal responsibility for their own and others' safety. Injuries and permanently impaired health not only have major personal consequences, but also greatly affect other people such as family, friends and colleagues. Therefore, we intervene if we observe dangerous conditions, unacceptable behavior, and violations of safety regulations.  

Our requirements must also, as a minimum, be complied with by our co-suppliers and partners. Our position is that if we do not believe that we can carry out an assignment or project in accordance with our HSE requirements, we do not.  

Bullying, harassment and threats  

Last Mile distances itself from any form of discrimination, whether based on gender, age, race, religion or other circumstances.  Last Mile  works actively for an inclusive and health-promoting working life where none of our employees - or others who perform work for Last Mile, will experience harassment, bullying or negative attention.  

We never accept any form of harassing behaviour or other behaviour that may be considered offensive, threatening or degrading, including any form of unwanted attention of a sexual nature.  

Diversity and Equality  

Last Mile aims to reflect the diversity of the community.  Last Mile wants an inclusive work environment characterized by diversity and equality. To achieve this goal, we must treat colleagues, customers, business partners and others with respect and be sensitive to and respect cultural differences. Last Mile is a group with a multi-ethnic workforce, and a number of nationalities are represented among our employees. We are proud of this community.  

Last Mile operates in male-dominated industries and has a skewed gender balance among our employees. We believe that increasing the proportion of women will contribute positively to the working environment, the quality of our deliveries, and the results we achieve. A better gender balance will contribute to a strengthened reputation and increased attractiveness as an employer for both genders. 

We will never accept discrimination or discrimination based on age, gender identity or expression, disability, sexual orientation, ethnicity, political or religious beliefs or other characteristics.  

Human rights, child and forced labor.  

Last Mile is affiliated with No17, which is a national network for companies that want to work with corporate social responsibility and contribute to responsible and sustainable business practices in accordance with the UN's 17 sustainability goals.  Last Mile recognizes and complies with the core conventions on human rights and the prohibition of child and forced labor.  

Wages and working conditions and freedom of association.  

Freedom of association is a matter of course in Last Mile   and all Last Mile employees are free to be members of trade unions.   

Drugs and alcohol 

Last Mile shall be a drug-free workplace, and no one shall be under the influence of alcohol or other drugs while performing work for the Last Mile. In social settings, and during events where appropriate and acceptable, alcohol may be served in moderation.  

Purchase of sexual services  

The purchase of sexual services supports human trafficking, violates human rights, and poses a security risk. Last Mile  prohibits the purchase of sexual services in connection with work or business travel for Last Mile. We must never accept sexual favors paid for by others.  

Protect personnel information.  

We respect the privacy of all people and ensure that personal data is treated with honesty, integrity and in accordance with applicable laws and guidelines.  

Caring for society and the environment  

Good neighborliness  

Good neighborliness means that through our operations we create good local jobs while at the same time seeking to minimize possible negative consequences of our business on our neighbors. We achieve this through good dialogue with local authorities and those who operate or live close to our offices.  

We are committed to using local labour and local co-suppliers when carrying out our projects and delivering our products and services, where possible.  

Sponsorship and donations  

There can be many legitimate reasons for sponsoring and making donations for various purposes. Some examples are profiling our brand, supporting NGOs in communities where we operate and donations for various purposes that contribute to sustainable development and fulfillment of the SDGs.  

All sponsorship must be rooted in the company's objectives. Decisions regarding sponsorship and donations must be made at the right level in the organization and must not involve personal gain for the decision-maker or close associates.  

Sponsorship or donations shall not have the purpose of or could be perceived as undue influence by government officials, customers, or other business associates.  

We will not sponsor or donate to political or religious groups.  

Protecting the environment  

Last Mile's goal is for all our activities to be carried out in such a way that the negative impact on the external environment is as small as possible. We find that there are increasing demands on how we run our business. Increased focus on external environmental impact and responsible operations will require a willingness to adapt and a critical look at existing delivery models. Our sustainability work shall be based on international standards and our performance shall be verifiable and binding. 

Management of property, equipment, information, and other resources 

At Last Mile, we manage significant assets through the equipment we use and the information we develop and obtain through our operations. This means that we must take good care of the values, secure them against unauthorized persons, theft, and criminal damage, ensure necessary maintenance, and do everything we can to avoid loss and damage.  

In many cases, we are also responsible for our customers' assets and facilities through, among other things, operating agreements.  

Careless use resulting in loss and damage not only has financial consequences, but can destroy relations with business partners, and also represents an unnecessary consumption of resources. 

Our assets, including IT systems and information, may only be used for legitimate business purposes and by authorized employees.  

We shall never disclose confidential information to anyone outside the Company unless such disclosure is required by law. Confidential information is information that is not, or should not be, known to the public. For example, such information may include business plans, budgets, marketing and sales programs, recipes, design specifications, and customer records. 

Exercise good business practice  

Customers and quality  

We shall meet and treat our customers in a good and predictable manner, and our deliveries shall comply with agreed requirements and the customer's expectations. This is important for building and preserving trust and reputation. Customer feedback and complaints are an opportunity for learning and improvement and are always handled in a constructive and respectful manner.  

Transparency in financial reporting  

Last Mile is committed to keeping correct and accurate accounting and reporting in accordance with applicable legislation. All transactions must be fully and correctly documented and recorded in accordance with applicable laws and generally accepted accounting principles. Untrue or misleading behaviors may be treated as fraud and will never be accepted.  

Our financial reporting shall provide sound and objective information on the status and our assessment of future opportunities and threats to all stakeholders so that they can make decisions that are based on as appropriate a basis as possible. Therefore, no assessments shall be made or transactions that are likely to mislead about the financial status of the company.  

Competition law  

Last Mile wants to contribute to fair and open competition. Therefore, we combat illegal practices such as price fixing and illegal tendering. We shall not engage in illegal collection of nonpublic information that may unlawfully affect competition. Last Mile will facilitate fair and open competition when we compete for assignments and in our procurement processes.  

We will of course comply with competition law and all relevant regulations.  

Anti-corruption  

Last Mile has zero tolerance for all forms of corruption. Corruption undermines legitimate business activities, distorts competition, destroys the reputation of corporations and individuals, leads to prison sentences and other civil and criminal liability, and prevents compliance with human rights. Therefore, we must always comply with anti-corruption laws and never offer or accept anything that may cast doubt on our professionalism and our ethical way of doing business.  

Sanctions  

International and economic sanctions impose restrictions and prohibitions on trade with certain parties determined by the authorities. Last Mile shall comply with all sanctions laws and regulations. This requires special care in case of trade with specific countries. Sanctions provisions may include the sale and purchase of goods, services, and technology as well as the exchange of information.  

Partners and co-suppliers  

Last Mile relies on good co-suppliers and partners to achieve success. Our business partners are expected to maintain the same high ethical standards as ourselves. Suppliers with contractual relationships  with Last Mile must comply with laws and regulations, our health, safety and environment requirements, the core conventions on child and forced labour, and our requirements for good business practice. Failure to comply with the requirements may result in termination of the business relationship.  

Due care must be taken when selecting suppliers and other partners, and we shall ensure that our relevant requirements for ethical business operations are contractually established and followed up. We will comply with the Transparency Act and ensure good information about our work with fundamental human rights and working conditions in our supply chain.  

Money laundering  

Money laundering hides the illicit origin of proceeds from criminal activity such as drug trafficking, terrorism, corruption and tax evasion. Criminal exploits include not only money, but all forms of assets, real estate, and intellectual property derived from criminal activity. 

Last Mile is committed to complying with all anti-money laundering laws. We conduct business exclusively with reputable customers and business partners involved in legitimate business activities.  

Gifts and hospitality  

Last Mile does not allow gifts or hospitality where giving or accepting them may influence business decisions, violate local laws or the policies of the receiving company, or cause others to perceive that such influence or violation has occurred.  Last Mile does not expect gifts or hospitality from any of our business partners.  

Hospitality can only be accepted or offered if it is in combination with a business meeting or there is another clear business reason for attending.  

Special care shall be taken when receiving from or offering to public officials.  

Conflict of interest  

A conflict of interest arises when personal interests, participation in external activities, or business interests may influence decisions made on behalf of Last Mile. Examples of such relationships may be related to financial interests, customer/supplier relationships or positions of trust or similar roles or ownership interests.  

All business transactions must be entered into exclusively in the best interests of the Last Mile . Any actual or perceived conflict of interest that cannot be avoided should be reported and made transparent.  

All decisions that may involve a change in, or assignment of, advantages or disadvantages for an employee, such as reorganizations, job changes, promotions, salary adjustments, bonus awards, dismissals, or reassignments, etc. must be approved by the manager's manager (grandfather principle).