Code of conduct

1. Preamble

The purpose of this Code of Conduct is to ensure that Harvia Plc and all of its subsidiaries (“Harvia Group” or the “Group”) abide by shared ethical principles in their operations. Harvia Group’s Code of Conduct (the “Code”) describes generally accepted practices and our commitment to comply with laws and regulations.

This Code applies to all of Harvia Group’s employees regardless of their geographical location, and the employees are expected to abide by the Code without fail.

2. Compliance with the Law

We abide by all applicable laws, regulations and undertakings that bind Harvia Group in our business operations. We do not allow any conduct that is contrary to law, and we expect our employees to comply with the applicable laws in both Finland and in other countries when conducting their work duties.

All of our employees are obliged to review the laws affecting their work duties and act accordingly.

3. Environment, Health and Safety

We seek to protect the environment, health and safety in addition to improving the quality of our business operations. We strive to prevent and reduce the detrimental effects of our operations on the environment, people and property as well as to promote the efficient use of natural resources.

4. Product Safety

We abide by the applicable safety regulations and provide users with information on the safe use of our products. We take the safety of people, processes and our products into consideration when making business decisions. We must ensure that Harvia Group’s products are safe to use and that their purpose of use is appropriately described and determined. We determine and strive to find ways to reduce the risks and the environmental impact of our products both during production and over their entire lifespan. We provide our customers and other key parties with all necessary information on our products.

5. Competition Law

We act in accordance with the applicable competition law provisions. We only use legal and ethical methods to gain a competitive advantage when seeking to promote our business.

Harvia Group cannot engage in conduct that restricts free competition either by itself or together with other operators in the industry. Each employee must treat our customers, service providers, suppliers and competitors as well as any third parties fairly, and no one should be taken advantage of e.g. through manipulation, by withholding or misusing information, by twisting facts or by engaging in any other unfair conduct.

The Harvia Group may face significant sanctions or fines and be liable for damages if it is found to be in breach of competition law provisions. Any individual employee found guilty of a competition law breach may also face criminal liability and/or be liable for damages.

6. Anti-bribery and Anti-corruption

All forms of corruption and bribery are prohibited. Neither Harvia Group nor its employees may promise, offer or give bribes or make any other unlawful payments or provide any other unlawful benefits directly or indirectly to any public authority or to any other party in order to initiate or maintain business operations or for any other reason.

The restrictions on giving gifts and entertaining guests or other business partners do not apply to small-scale conventional entertaining of guests or business partners in connection with Harvia Group’s business operations. Guests or business partners should not, however, be entertained so often or in such an unreasonable or extensive manner that it could be considered inappropriate.
If you are uncertain as to whether you could be considered to be acting inappropriately by entertaining specific guests or business partners, you must consult with the Chief Financial Officer of Harvia Group or the local managing director before entertaining the said guests or business partners. In addition, entertaining a public authority in any capacity always requires special advance consideration and is subject to Harvia Group’s Chief Financial Officer’s or the local managing director’s consent.

Harvia Group’s employees may not accept more than minor personal gifts or other business-related benefits from Harvia Group’s customers, subcontractors or other business partners. Gifts and other business-related benefits can only be accepted when they are given in connection with regular business operations and always on the precondition that they are low-value.

No gifts, favours, entertainment, money or unjustified benefit or anything else of value can be promised, offered or provided to a public authority in any way, directly or indirectly, in order to influence their actions as a public authority. The said unjustified benefit may also be of low monetary value.

No gifts, favours, entertainment, money or unjustified benefit or anything else of value can be promised, offered or provided to any person employed by a rival company or to a person acting on behalf of such a company in any way, directly or indirectly, in order to influence the said person to favour the Group or another person when conducting their duties. The said unjustified benefit may also be of low monetary value or have no monetary value.

7. Political Activity

Unless otherwise decided by Harvia Group’s Board of Directors, the Group will not engage in politics and the Group’s funds must not be used to make any political contributions.

Each employee personally decides whether to engage in politics. Any political activity must occur in the employee’s free time while acting as a private person and not in the name of the Group. The funds, name or assets of the Group must not be used for political purposes or to support a specific political view either directly or indirectly.

8. Business Partners

We conduct business solely with reliable business partners that take the environment and people into consideration. The Group expects all of its business partners and subcontractors to abide by the applicable laws and to undertake to conduct their business in an ethical and sustainable way.

9. Conflicts of Interest

Harvia Group’s employees may not engage in business operations or other activities that may cause a conflict of interest to arise between the interests of the Group and those of the employee or their close associates. Each employee is obliged to openly disclose the potential for such a conflict of interest.

A conflict of interest may also be at hand if someone takes action that affects your ability to appropriately and efficiently conduct your duties for our Group. The employer must always be notified in advance of any secondary or additional employment.

10. Communication Principles

Harvia Group applies high quality standards to the publication of financial and other information. All transactions conducted on behalf of Harvia Group must be clearly and truthfully disclosed in its bookkeeping.

11. Confidentiality

Employees must ensure that all confidential information is kept secret regardless of whether the employee has received the information from Harvia Group or from a party that engages in business with the Group. Disclosing such information is allowed only if the employee has specific permission to do so or when the information must be disclosed pursuant to law. Confidential information encompasses all non-public information that may benefit Harvia Group’s competitors or disadvantage the Group or its business partners if it is disclosed. Confidential information conveyed to the employee during their employment is Harvia Group’s property, and the disclosure of such information to third parties is prohibited.

12. Data Protection and Access to Data

Harvia Group abides by the principles of the applicable Personal Data Act that specifies the obligations concerning collecting, handling, processing, transferring and storing personal data.

There must always be a justified reason referred to in the Personal Data Act for processing personal data.

13. Prohibition of Money Laundering and International Sanctions

Each employee of Harvia Group must abide by the provisions governing the prevention of terrorist financing and money laundering. Furthermore, business cannot be conducted with a party subject to criminal proceedings or international sanctions. The other party’s identity and background must be ascertained when engaging in business with the said party.

14. Human Rights

We respect and promote human rights as they are defined in the United Nations’ Universal Declaration of Human Rights. These rights comprise e.g. freedom of opinion, freedom of expression, freedom of religion and freedom of assembly as well as freedom from discrimination based on race, age, nationality, sex or sexual orientation.

Furthermore, we disapprove of using child labour or forced labour and of working conditions that do not correspond to international treaties, practices and the Group’s own ethical standards.

15. Non-harassment and Non-discrimination

We treasure diversity and promote fair and equal treatment in all aspects of the employment relationship. We promote equality in our operations and will not stand for any kind of harassment or discrimination.

16. Sanctions

All fraudulent conduct is prohibited. Fraudulent conduct, including theft, fraud and other such inappropriate behaviour, undertaken with the intention of benefiting from such conduct is subject to official investigation.

Neglecting to abide by applicable laws, guidelines or other undertakings that bind Harvia Group may have serious consequences, including the termination of the employee’s employment, potential criminal and civil liability and liability for damages.

17. The Implementation and Supervision of the Code

The implementation of this Code is based on the uncompromising example of the top management of and all supervisors employed by Harvia Plc.
Acting in breach of this Code has a detrimental effect on Harvia Group’s brands and trust in Harvia Group in addition to potentially causing significant business-related and personal liabilities. Each employee must ask for help when necessary and to immediately inform of any suspected or observed breaches. Harvia Plc’s confidential whistleblowing channel,, must be used to inform Harvia Plc of any concerns or breaches, and employees are obliged to assist in any investigation into suspected inappropriate conduct if necessary. Harvia Group’s operating principle is to prevent unethical and unlawful conduct and to intervene in such conduct as quickly as is reasonably possible after Harvia Group has become aware of such conduct.

All whistleblowing reports are treated confidentially to the extent allowed by applicable law and when taking into consideration the Group’s obligation to investigate the conduct disclosed in the said reports. The identity of the employee who submitted the report will similarly be kept confidential. Employees are obliged to keep confidential any investigations they become aware of as well as the details of such investigations.

18. Decision-making, Amendments and Responsible Parties

Harvia Plc’s (Harvia Holding Oy) Board of Directors approved this Code of Conduct in January 2018 and its formulations have been updated to suit international distribution within the Group in November 2020.

The Code of Conduct will be reviewed at regular intervals and updated if necessary. The owner of the Code of Conduct is Harvia Plc’s Chief Financial Officer, and the Chief Financial Officer and the Managing Director will be jointly responsible for updating and amending the Code of Conduct.

English language translation from the Finnish original. In case of discrepancies, the Finnish language version shall prevail.

Finnish language version