Code of Conduct

Leave A Mark Consulting Group

 

Introduction

At Leave a Mark Consulting Group (LAM), we advise and help companies implement information security, production optimization and automation via ISO standards. Our products, services and advice give our customers competitive and operational advantages in their daily work. It is a commitment that we take seriously. We want to be a responsible, reliable and environmentally friendly company – for our customers, shareholders, employees, suppliers, partners and the society in which we operate. We want to build trust with all our stakeholders and we conduct our business in a responsible, ethical and legal way to fulfill our obligations.

To support this, we have drawn up this code of conduct (hereafter CoC), which contains several principles to reflect the behavior we want to promote in LAM together with our employees. These are principles for how we treat each other, how we serve our customers and how we interact with other stakeholders such as suppliers, business partners, tax and regulatory authorities. These are also principles that reflect the way we want to carry out corporate governance. LAM also follows the UN's Global Compact principles and has signed up to the UN's Global Compact.

The CoC is approved annually by the Executive Board

Purpose and scope

The purpose of this code of conduct is to define LAM's overall level of responsibility and targets for key areas. The aim is not to regulate the individual areas in detail – this is done using internal policies and guidelines. The code of conduct applies to all employees, suppliers, freelancers and everyone who acts on behalf of LAM, including the board.

It is the responsibility of the employee, supplier, freelancer and anyone acting on behalf of LAM to read, understand and comply with the principles of the code of conduct. Violation of the principles can expose LAM's to reputational risks as well as legal and regulatory sanctions. In the event of a violation of the principles of the code of conduct, the behavior must be stopped immediately. Inappropriate business practices or direct violations of the principles must be reported to the company's management. We expect all our business partners to adhere to the same principles.

Business principles

LAM has established a number of business principles that will ensure compliance with our code of conduct. Compliance with legislation and regulations. It is LAM's objective to comply with locally applicable legislation and regulations from the authorities as well as EU regulations in all our activities, products and services. This means that we provide products and services that are responsible, understandable, sustainable and developed to meet the customer's needs.

Pricing

We have guidelines and procedures, including control procedures, for calculating prices, which ensure that only relevant criteria are used. We do not use the individual customer's marital status, religion, race or ethnic background as criteria for our pricing. Our prices are transparent and it is always clear to our customers what they have to pay.

Communication

Communication to customers focuses on ensuring that the customer receives transparent, balanced and easy-to-understand information. No information is hidden or written in fine print and we strive to have marketing and product information that is professional, comprehensive, accurate, balanced and not misleading. We ensure transparency and a fair case handling procedure with a focus on the customer

ESG

ESG is integrated in investments It is LAM's position that environmental, social and cooperative governance factors affect long-term results, risk and value for all companies. Therefore, ESG factors are integrated into our investment activities both in relation to investment analyses, the decision-making process, reporting and in active ownership.

Data and Privacy Protection

At LAM we collect general information and personal data. We only collect data for specific and legitimate purposes. Data is not sold and the customer can always access the information collected. Data is only kept and stored for as long as necessary. We comply with the General Data Protection Regulation (GDPR). We ensure that data is stored and processed in a way that does not compromise the customer's right to privacy.

Data Ethical Governance

Data ethics includes the moral obligations of the collection, protection and use of personally identifiable information and how it affects individuals. Data ethical governance is part of LAM's general governance, and we strive to ensure that ethics is incorporated into all decisions and a part of daily life.

Working with Data

When we work with data, we follow the "5 PRINCIPLES OF DATA ETHICS FOR BUSINESS PROFESSIONALS".

1. Ownership

The first principle of data ethics is that an individual owns their personal information. Just as taking an item that doesn't belong to you is considered theft, collecting someone's personal data without their consent is illegal and unethical.

2. Transparency

In addition to owning their personal information, data subjects have the right to know how you plan to collect, store and use it. When collecting data, practice transparency.

3. Privacy

Another ethical responsibility that comes with handling data is to ensure the privacy of data subjects. Even if a customer gives your company permission to collect, store and analyze their personally identifiable information (PII), that doesn't mean they want it publicly available.

4. Intention

When discussing any branch of ethics, intentions matter. Before collecting data, ask yourself why you need it, what you want to achieve with it, and what changes you will be able to make after the analysis. If your intent is to harm others, take advantage of your subjects' weaknesses, or any other nefarious goal, it is unethical to collect their data.

5. Results

Even when the intentions are good, the result of data analysis can cause unintended harm to individuals or groups of people. This is called disparate impact, which is described in the Civil Rights Act as illegal.

We use artificial intelligence responsibly

In LAM, we use artificial intelligence to support our daily work, e.g. to assess risks or manage work processes. This helps to provide our customers with a good and efficient experience. To ensure responsible use of artificial intelligence, we follow five ethical principles.

1. Consideration. Artificial intelligence must be developed and used with caution and respect.
2. Professional security. Artificial intelligence must be used within a defined framework and be built on the latest technological knowledge and thorough tests.
3. Reliability. Artificial intelligence must be reliable, based on facts and free from bias.
4. Transparency. We need to understand how artificial intelligence works so that the models work safely and only for the purposes they were created for.
5. Data security. Artificial intelligence must meet the requirements of data protection legislation and be protected against cybercrime.

Cyber and Data Security Requirements

At LAM, we take data security and cyber security seriously. We have established procedures, control systems and technologies to ensure the confidentiality, integrity and availability of the information. Both data security and cyber security are important factors in the protection of companies LAM. We emphasize the protection and processing of information, and we set requirements for data and cyber security, which must be observed by both employees and external business partners. We conduct risk assessment analyzes and contingency planning regularly. In addition, we have internal procedures that result in a high level of security in applications, systems and infrastructure. We recognize the risk associated with data security and cyber security. Therefore, we ensure that employees receive sufficient training. Thus, all existing and new employees are obliged to complete e-learning to gain knowledge and focus on data security and cyber security. To confirm our data security, the company will at least secure the following certification/declarations: ISO27001, IS027701

Tax Obligations

LAM always strives to comply with all current tax laws, rules and regulations in all areas where we do business. The company pays taxes in the country where its actual business is conducted. All taxes are paid on time. We do not practice tax planning or tax structuring that deliberately aims to artificially reduce the group's taxable income. In tax matters, we operate the group companies within the framework of legislation and legal practice for planning the group companies' taxable income. The financial results of the group companies always comply with local laws and recognized accounting principles

Business ethics

We avoid conflicts of interest. LAM's employees, suppliers and other business partners are expected to act in LAM's best interest. No employee may use their position to promote their own interests. In situations where personal interests are in conflict with LAM's interests, the employee is obliged to entrust the decision to a person who is not in conflict with LAM's interests.

Prevention of Money Laundering and Terrorism Financing

LAM always complies with the legislation on the prevention of money laundering and the financing of terrorism, including UN and EU regulations on increased risk and financial sanctions. It is our aim to actively contribute to the prevention of money laundering and terrorist financing, to avoid being misused for money laundering and terrorist financing, and to maintain a good reputation in relation to preventing and combating money laundering and terrorist financing. We do not accept corruption and bribery.

LAM wants to be part of a professional, decent and trustworthy business environment. Therefore, we do not accept any type of behavior that may give the impression of undue influence or that business decisions are influenced by individual and/or non-business motives and interests. We expect all employees, customers, suppliers and other business partners to act in the same way. Employees must ensure that payments to third parties are appropriate, with a legitimate business reason and properly recorded.

Fair competition

It is our policy to compete in accordance with all applicable antitrust and competition laws wherever LAM does business. We treat competitors with respect and appropriate behavior in competitive situations. We do not enter into agreements on pricing or agreements on the market with our competitors.

Human Rights and Labor Practices

Respect for Human Rights

 At LAM, we always want to follow applicable legislation on human rights, labor rights and employment conditions. We respect internationally recognized human rights and the UN's Global Compact principles on human rights. It is our aim not to violate these principles and conventions. This applies to our business operations, the entire supply chain, our products and investments.

We do not tolerate discrimination

At LAM, we respect the individual's human rights, and we do not tolerate any form of discrimination, bullying or harassment, including sexual harassment. All employees are treated fairly and on equal terms, regardless of age, ethnic background, sexual orientation, disability, health, political position or race. LAM wants to be a diverse workplace – a workplace where diversity is accepted and used as a strength. That is why we work as a company to maintain and develop openness to counter any form of discrimination and to ensure that everyone has equal opportunities. We do not tolerate discriminatory practices in recruitment, job assignments, promotions, compensation or other benefits and general workplace conduct.

High Standards for Health and Safety

At LAM we have high standards for safety as well as physical and mental health. Our goal is to limit work-related accidents and illness as well as sick leave as much as possible. In addition, employees are required to take all reasonable precautions to maintain a healthy and safe working environment to avoid possible personal injury or risk to the safety of others. We want to promote employee commitment, health, well-being and professional development. This includes developing management practices, supporting skills development and providing a healthy and safe workplace.

The Right to Freedom of Assembly and Association

At LAM, employees have the right to freedom of assembly and association at the workplace, and they are free to choose to be members of organizations in accordance with Danish legislation. Trade unions that are recognized as negotiating partners and enter into general agreements in the area can participate in collective negotiations. Employees who act as representatives are not treated worse than other employees.

We do not accept child labor.

At LAM, we have zero tolerance towards all forms of forced labor and child labour, which we strongly condemn. We are obliged to exercise care and diligence and have procedures in place so that we avoid directly and indirectly participating in forced labor or child labour, e.g. through the supply chain or via investments. We are also committed to contributing to the elimination of such practices if we become involved in them.

Environment and Climate Change

At LAM, we always want to follow current legislation and regulations on protecting the environment and preventing climate change.

In addition, we want to:

• Improve our climate and environmental performance; to integrate environmental and climate considerations into our own company and business activities
• Reduce the consumption of resources (e.g. energy, water) and improve the efficient use of these resources
• Reduce pollution, CO2 emissions and waste from business activities
• Promote and implement initiatives to motivate greater environmental responsibility and a sustainable future, for example through a focus on recycling and repair.

We want to raise awareness about climate and environmental issues, educate employees and encourage participation in any event organized by LAM. We encourage customers, suppliers and other business partners to comply with similar climate and environmental responsibilities.

Whistleblowing

LAM uses the national whistleblower reporting system at https://whistleblower.dk/ so that everyone has the opportunity to report illegalities. All whistleblower reports are immediately investigated in a confidential manner, while the whistleblower is protected. If you find inappropriate business or personal behavior by one of our employees that is a potential or actual violation of this Code of Conduct and its principles, you are encouraged to report this to a manager.