Code of Conduct including Sustainability Policy

This Code of Conduct (including Sustainability Policy) was drawn up by the Board of Directors at a Board meeting held June 18, 2010 and is effective until further notice.

Fouriertransform’s Code of Conduct (including Sustainability Policy) clarifies how the company shall act as a business partner, employer and as a part of society. The Code and the Policy cover both the individual responsibilities of employees and the company’s responsibilities in its own business and in Fouriertransform’s portfolio companies, as well as in respect of employees and society.

An ethical approach and a sustainable enterprise

Starting point

Fouriertransform is a company characterized by ethics and good business morals. This applies both to how Fouriertransform acts as a company and to how Fouriertransform acts as co-owner of its portfolio companies.

An ethical approach includes environmental, social and business aspects of the company’s operations and is crucial to the company’s credibility among its stakeholders. Good ethics also covers the management of all the resources in the business: economic resources, natural resources and human resources.

Fouriertransform’s basic view is that sustainability, growth and profitability are entirely compatible with each other. In Fouriertransform’s field of operations – the Swedish automotive cluster – these three factors are in fact inter-dependent.
 
Fouriertransform also considers transparency, integrity and honesty in the dialog with its stakeholders to be part of an ethical approach. A high degree of professionalism in its daily work is also part of good business morals.

Investment aspects

Since Fouriertransform is a venture capital company with no production of its own, its own direct impact on the environment and the outside world is limited. However, Fouriertransform’s mission and investment principles mean that the company will contribute to sustainable development by investing in projects that have a sustainability dimension. Climate issues in particular are driving the automotive industry in this direction. In view of this, it is only natural for sustainability aspects to form an important part of the analysis carried out ahead of any investment decision. Opportunities and risks are always thoroughly analyzed, with the project’s sustainability potential being weighed up in relation to its growth potential and prospects of profitability.

Good ethics shall guide the company not only in its assessment of investments, but also during the period in which Fouriertransform holds an interest in a portfolio company. As co-owner, Fouriertransform plays an active role via the boards of the portfolio companies and encourages the business to be run ethically and responsibly. The portfolio companies are encouraged to establish policies and objectives for the issues judged to be most relevant to the company concerned.

Business ethics

Fouriertransform’s employees abide by the laws, agreements and provisions applicable to business relations and always act in an ethically correct way. Fouriertransform also requires its portfolio companies, suppliers and other business partners to act accordingly.

Restrictions on competition

Effective and fair competition on equal terms is crucial to a functioning market economy. The products and solutions that Fouriertransform helps to develop must provide added value on market terms. The company will not participate in unfair, incorrect or misleading comparisons, or in agreements or arrangements that distort competition.

Fraud

Legal action will be taken in respect of any kind of law-breaking that concerns Fouriertransform’s business.

Bribery and corruption

Fouriertransform adopts a zero tolerance approach to any kind of corrupt practices. No employee shall give or receive benefits that may be regarded as inappropriate and thus illegal. This includes any benefits that could influence decisions or result in other impermissible advantage in the performance of Fouriertransform's business. Examples of such prohibited benefits might include gifts, leisure travel, entertainment or various kinds of services. 

Fouriertransform’s employees are encouraged to show great restraint in the matter of accepting gifts or other offers. They shall also be judicious in their own entertainment of others. If there is the slightest doubt, the employee shall raise the matter and obtain approval in advance from his or her line manager.

Conflicts of interest

Conflict of interest refers to cases in which employees may have loyalties outside the company that could have a negative impact on business operations.  These include, for example, their own investments or business commitments outside the company, the use of insider information or confidential information for personal gain, or favoring related parties.

Fouriertransform’s employees are expected to be vigilant and transparent regarding such potential conflicts of interest, so that these can be avoided.

Social responsibility

Fouriertransform shall be familiar with the relevant applicable laws and agreements in the labor market, with legislation on discrimination, environmental legislation, legislation on public enterprises and legislation concerning business relations, and – in accordance with state guidelines – shall comply with these in all situations. Naturally this applies both to its own business and to the portfolio companies.

Fouriertransform supports the universal guidelines that exist on human rights, labor practices, consideration for the environment and fighting corruption. Where the portfolio companies have international business relations, for example with subcontractors, Fouriertransform expects these to be conducted in accordance with the OECD Guidelines for Multinational Enterprises and the ten principles of the UN Global Compact.

The company shall be a good citizen and employer, and shall endeavor to maintain a continuous dialog with the rest of society – particularly in the places and with the people that are close to Fouriertransform and the portfolio companies. 

The company does not support any political parties or other political organizations, either directly or indirectly.

Employees

The company’s responsibilities

Fouriertransform’s relations with its employees shall be based on mutual respect. In order to attract competent employees Fouriertransform must offer good working conditions, fair pay and relevant professional development.

No kind of discrimination will be tolerated within Fouriertransform – refer also to the company’s Equality and Diversity Policy.

Fouriertransform complies with laws and agreements regarding employment contracts and working hours.

Information on employees shall be treated with respect for the privacy of individuals and in accordance with applicable legislation on personal data protection.

Responsibilities of employees

All employees shall ensure that confidential information – whether it concerns Fouriertransform, potential investments, portfolio companies or other external parties – remains confidential.

It is each employee’s responsibility to seek the advice required in order to be aware of applicable laws, current practice and agreements that are relevant to his or her duties and position. Since the work involves contact with highly competent players, the company’s employees are required to monitor economic and social debate as well as international developments.

All employees shall protect Fouriertransform’s assets and intellectual property.

Alcohol and drug abuse have no place within Fouriertransform.

The environment

Indirect environmental impact

Fouriertransform invests capital in projects associated with the automotive industry. During its period of ownership Fouriertransform will be an active owner and will contribute relevant expertise to these projects. This primarily takes place through representation on the board of directors – either one of our own employees or by engaging someone from the company’s networks. This also provides opportunity to contribute to sustainability becoming a living, strategic issue in the work of that board. Similarly, Fouriertransform's work on these boards will focus on achieving profitability. Good profitability in a company is often the most effective way of actively investing in R&D and environmental innovations. 

Fouriertransform’s board representatives will encourage the portfolio companies to actively pursue sustainability work throughout the value chain, from purchasing to end product.

Fouriertransform requires each company to establish policies and goals for its sustainability work where applicable, and to report facts concerning the company’s environmental impact and the measures taken to reduce this.

Direct environmental impact

Fouriertransform’s own environmental impact is primarily due to office premises, energy consumption, purchasing, office equipment and consumables, and also business travel.

All Fouriertransform’s employees are responsible for respecting environmental aspects in their daily work. This applies, for example, in respect of energy consumption and recycling.

When travelling on business, employees should consider travelling by train as an alternative to air or car travel.

When choosing a company car employees shall select vehicles classified as ‘green cars’.