Code of Conduct

1. Introduction

This Code of Conduct applies to the Swedish private limited company Pedaly AB with company registration number 559243-7999 ("Company"), as well as to all of the Company’s employees, suppliers, resellers, consultants, and other business partners, including their employees ("Partners"). The term "employees" also includes contracted staff, interns, volunteers, and others performing work on behalf of the Company or its Partners.

The Code of Conduct is a governing document that ensures that operations and business relationships are conducted responsibly, lawfully, and ethically. Everyone covered by the Code of Conduct must safeguard human rights, fair working conditions, a safe and inclusive work environment, reduced environmental impact, and sound business ethics.

The Code of Conduct is based on the ten (10) principles of the UN Global Compact, which are universally recognized and founded in the UN Declaration of Human Rights, the ILO Core Conventions, the Rio Declaration, and the UN Convention against Corruption. Compliance is mandatory, and failure to comply may lead to measures, including termination of contracts and business relationships.

2. Human Rights

All parties covered by the Code of Conduct must support and respect internationally recognized human rights and always comply with applicable national and international standards (Principle 1). The Company and its Partners must also ensure that they are not complicit in human rights abuses, whether directly or indirectly (Principle 2).

Respect for individual privacy is a central part of human rights. All processing of personal data must therefore comply with the GDPR and national legislation. Required agreements and documents, such as data processing agreements, internal procedures for handling data breaches, privacy notices, and records of processing activities, must be in place and kept up to date. Technical and organizational security measures must ensure an adequate level of protection, and particular care must be taken when processing sensitive data and when transferring data to countries outside the EU/EEA (Principles 1 and 2).

3. Labour

All parties covered by the Code of Conduct must comply with national and international labour law and ensure that fundamental rights at work are respected. Freedom of association and the right to collective bargaining must be upheld (Principle 3). All forms of forced labour are prohibited (Principle 4), and child labour must be effectively abolished (Principle 5).

Discrimination in employment must not occur (Principle 6), and terms of employment must be fair, inclusive, and lawful, with wages at least in line with statutory minimum wages and working hours within legal limits. The work environment must be safe, healthy, and inclusive, with zero tolerance for discrimination, harassment, and degrading treatment (Principle 6).

Conflicts of interest must be avoided and, if they arise, reported.

4. Environment

Everyone covered by the Code of Conduct must protect the environment and climate and support a precautionary approach to environmental challenges, to prevent risks in time and minimize negative impacts (Principle 7).

The Company and its Partners must take initiatives to promote greater environmental responsibility, including reducing emissions, improving resource efficiency, and supporting recycling (Principle 8).

Furthermore, operations must take into account the protection of biodiversity and the preservation of ecosystems, and encourage the development and diffusion of environmentally friendly technologies and innovations (Principle 9). Products, services, and procurement must always be developed and selected with regard to environmental, social, and ethical aspects, and applicable environmental legislation must be followed.

5. Anti-Corruption

All parties covered by the Code of Conduct must work against corruption in all its forms, including bribery and extortion (Principle 10). This means not only refraining from engaging in corruption, but also actively working to prevent it, both within the organization and throughout the supply chain.

Corruption can take many forms, from undue influence and systematic bribery to more subtle abuses of power, but in all cases it undermines trust, transparency, and fair competition. The Company and its Partners must therefore have routines, controls, and programs in place to prevent corruption and ensure that no business relationship contributes to the abuse of entrusted power for personal gain.

Compliance with applicable laws, international conventions, and guidelines is self-evident. In cases of suspected corruption, immediate action must be taken. Preventing and combating corruption is a prerequisite for maintaining sustainable and responsible operations, and it is a shared responsibility of the Company, its employees, and its Partners (Principle 10).

6. Business Ethics

The Company and Partners must always conduct business with high integrity and in compliance with applicable laws and regulations. This includes compliance with competition law, sanctions, and export controls. The Company does not make political contributions, and the same principle applies to Partners.

Products and services must meet requirements for quality, health, and safety, and all information provided must be accurate, clear, and not misleading. Accounting, reporting, and other documentation must be truthful, complete, and in accordance with applicable laws and good accounting practice.

Confidential information must be protected against unauthorized access, loss, or damage through appropriate technical and organizational measures. The Company’s and Partners’ material and intellectual property may only be used for legitimate business purposes, and third-party intellectual property rights must be respected.

Business ethics also means building long-term relationships characterized by trust, transparency, and openness. Everyone covered by the Code of Conduct must contribute to a corporate culture where responsibility, respect, and professionalism permeate every business decision and interaction.

7. Implemenation, Compliance and Follow-up

Management and the Board of Directors are responsible for ensuring compliance with the Code of Conduct and must provide training and information to employees and partners. Partners must ensure that their employees and business partners comply with the Code, with these requirements incorporated into agreements throughout the supply chain.

The Company may, directly or through an appointed third party, conduct audits and request information and documentation that demonstrate compliance. Partners must provide necessary information and cooperate in such audits. If deficiencies are identified, immediate corrective measures must be taken, and business partners that do not comply must be replaced.

Both the Company and its Partners must conduct reasonable due diligence in the supply chain to identify, prevent, and address risks related to human rights, labour rights, the environment, and business ethics. Non-compliance may result in written warnings, requirements for corrective action, suspension of assignments, termination of agreements, or reporting to authorities. Partners are not entitled to compensation if an agreement is terminated due to a breach of the Code of Conduct.

8. Reporting Violations

To ensure compliance with the Code of Conduct, suspected or actual violations must be reported. Whistleblowers must be protected from retaliation or other negative consequences. Where practically possible, anonymous reporting should be offered. Reports can be made to the Company using the contact details provided in section 10 below.

9. Amendments

The Company may amend the Code of Conduct at any time to ensure it remains consistent with applicable legislation and relevant international frameworks. Amendments will normally be communicated by email at least thirty (30) calendar days before taking effect. The current version is always available at https://www.pedaly.se/code-of-conduct.

In cases of legislative changes, requirements from international frameworks (e.g., the UN Global Compact, ILO Core Conventions, OECD Guidelines), or urgent risks to human rights, the environment, or safety, amendments may take effect immediately, with information provided as soon as possible.

10. Company Contact Details

Email: contact@pedaly.se
Telephone number: +46 010-300 11 61
Postal address: Fabriksgatan 8, 702 11 Örebro