Introduction

At Leave a Mark Consulting Group (LAM), we advise and assist companies with implementing information security, production optimization, and automation through ISO standards. Our products, services, and consultancy provide our clients with competitive and operational advantages in their daily work. This is a commitment we take seriously. We aim to be a responsible, reliable, and environmentally conscious company—for our clients, shareholders, employees, suppliers, partners, and the society in which we operate. We strive to build trust with all our stakeholders and conduct our business in a responsible, ethical, and lawful manner to meet our obligations.

To support this, we have developed this Code of Conduct (hereafter “CoC”), which outlines several principles that reflect the behavior we wish to promote at LAM and among 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. They also reflect the way we aim to exercise corporate governance. LAM also adheres to the UN Global Compact principles and is a registered participant of the UN 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 overarching level of responsibility and objectives in key areas. The aim is not to regulate specific areas in detail—this is managed through internal policies and guidelines. The Code of Conduct applies to all employees, suppliers, freelancers, and anyone acting on behalf of LAM, including the Board of Directors.

It is the responsibility of employees, suppliers, freelancers, and all others acting on behalf of LAM to read, understand, and comply with the principles of the Code. Violations of the principles may expose LAM to reputational risk as well as legal and regulatory sanctions. In the event of a breach of the principles outlined in this Code of Conduct, the behavior must be stopped immediately. Improper business practices or direct violations must be reported to company management. We expect all our business partners to comply with the same principles.

Business Principles

LAM is committed to complying with applicable local laws and governmental regulations, as well as EU regulations, in all our activities, products, and services. This means delivering responsible, understandable, and sustainable products and services developed to meet customer needs.

Pricing

We have established guidelines and procedures, including control processes, for pricing to ensure that only relevant criteria are used. We do not use an individual customer’s marital status, religion, race, or ethnic background as a pricing factor. Our pricing is transparent, and it is always clear to our customers what they will pay.

Communication

Customer communication focuses on ensuring transparent, balanced, and easily understandable information. No information is hidden or written in fine print, and we strive to ensure that all marketing and product materials are professional, comprehensive, accurate, balanced, and not misleading. We ensure transparency and a fair case-handling procedure with customer-centric focus.

ESG

ESG is Integrated into Investments. LAM believes that Environmental, Social, and Corporate Governance (ESG) factors impact long-term outcomes, risk, and value for all companies. Therefore, ESG factors are integrated into our investment activities, including investment analyses, decision-making, reporting, and 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 customers always have access to the information collected. Data is retained and stored only 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 refers to the moral obligations surrounding the collection, protection, and use of personally identifiable information and how it affects individuals. Data ethical governance is an integral part of LAM’s overall governance structure, and we strive to ensure that ethical considerations are embedded in every decision and part of daily operations.

Working with Data

When working 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, it is both illegal and unethical to collect someone’s personal data without their consent.

  1. Transparency

In addition to owning their data, individuals have the right to know how it will be collected, stored, and used. When gathering data, you must act transparently.

  1. Privacy

Another ethical responsibility when handling data is safeguarding the privacy of data subjects. Even if a customer grants permission to collect, store, and analyze their personally identifiable information (PII), it does not mean they want it to be publicly accessible.

  1. Intent

Intentions matter when discussing any branch of ethics. Before collecting data, one should ask: Why is it needed? What is the intended outcome? What changes will be made based on the analysis? If the intent is to cause harm, exploit vulnerabilities, or pursue any malicious objective, then collecting that data is unethical.

  1. Outcomes

Even with good intentions, data analysis can unintentionally harm individuals or groups. This is referred to as disparate impact and is recognized as unlawful under the Civil Rights Act.

We Use Artificial Intelligence Responsibly

At LAM, we use artificial intelligence (AI) to support daily operations—for example, to assess risks or streamline workflows. This contributes to providing our clients with a smooth and efficient experience. To ensure the responsible use of AI, we adhere to five ethical principles:

  1. Care: AI must be developed and used with caution and respect.
  2. Professional Security: AI should be used within a defined framework, grounded in the latest technological knowledge and subject to rigorous testing.
  3. Reliability: AI must be trustworthy, fact-based, and free from bias.
  4. Transparency: AI must be understandable, and models should only be used for their intended purposes.
  5. Data Security: AI must comply with data protection laws and be safeguarded against cybercrime.

Cyber and Data Security Requirements

At LAM, we take data and cybersecurity seriously. We have implemented procedures, control systems, and technologies to ensure the confidentiality, integrity, and availability of information. Both data and cybersecurity are critical to protecting LAM as an organization. We emphasize the importance of proper data handling and security and require that all employees and external partners comply with our data and cybersecurity standards. We regularly conduct risk assessments and contingency planning. Additionally, we maintain internal procedures that uphold a high level of security across applications, systems, and infrastructure. We recognize the risks associated with data and cyber threats and provide employees with sufficient training to address them. All current and new employees are required to complete e-learning courses to ensure knowledge and awareness of data and cyber security. To affirm our commitment to data protection, LAM ensures at minimum the following certifications and declarations: ISO/IEC 27001 and ISO/IEC 27701.

Tax Obligations

LAM always strives to comply with all current tax laws, regulations, and provisions in every jurisdiction in which we operate. The company pays taxes in the country where its actual business activities are conducted. All taxes are paid on time. We do not engage in tax planning or structuring that is intentionally designed to artificially reduce the group’s taxable income. In tax matters, we operate our group companies within the framework of the law and established legal practices when planning the taxable income of the group. The financial results of the group companies always comply with local laws and recognized accounting standards.

Business Ethics

We avoid conflicts of interest. LAM’s employees, suppliers, and other business partners are expected to act in the best interests of LAM. No employee may use their position to further personal interests. In situations where personal interests conflict with those of LAM, the employee is obligated to hand over the decision to someone who is not subject to such a conflict.

Prevention of Money Laundering and Terrorist Financing

LAM fully complies with laws and regulations regarding the prevention of money laundering and terrorist financing, including UN and EU regulations concerning elevated risk and financial sanctions. Our goal is to actively contribute to the prevention of money laundering and terrorist financing, to avoid being misused for such purposes, and to maintain a strong reputation in this regard. We do not accept corruption or bribery.

LAM aims to be part of a professional, respectable, and trustworthy business environment. Therefore, we do not tolerate any behavior that may give the impression of undue influence or suggest that business decisions are driven by personal or non-business-related motives or interests. We expect the same from all employees, customers, suppliers, and other partners. Employees must ensure that payments to third parties are appropriate, have a legitimate business purpose, and are correctly documented.

Fair Competition

It is our policy to compete in full compliance with all applicable antitrust and competition laws wherever LAM operates. We treat competitors with respect and behave appropriately in competitive situations. We do not engage in price-fixing or market allocation agreements with our competitors.

Human Rights and Labor Practices

Respect for Human Rights

 At LAM, we are committed to complying with all applicable legislation regarding human rights, labor rights, and employment conditions. We respect internationally recognized human rights and the UN Global Compact principles on human rights. Our goal is to ensure that we do not violate these principles or conventions. This applies across our business operations, supply chain, products, and investments.

We Do Not Tolerate Discrimination

At LAM, we respect individual human rights and do not tolerate any form of discrimination, bullying, or harassment, including sexual harassment. All employees are treated fairly and equally regardless of age, ethnicity, sexual orientation, disability, health status, political views, or race. LAM strives to be a diverse workplace—one where diversity is embraced and leveraged as a strength. As a company, we work actively to foster openness to counter all forms of discrimination and ensure equal opportunities for everyone. Discriminatory practices in recruitment, job assignments, promotions, compensation, benefits, and general workplace behavior are not tolerated.

High Standards for Health and Safety

At LAM, we maintain high standards for safety as well as physical and mental well-being. Our goal is to minimize work-related accidents, illnesses, and absenteeism. Employees are also required to take all reasonable precautions to maintain a healthy and safe work environment to prevent injury or risk to others. We strive to promote employee engagement, health, well-being, and professional development. This includes strong leadership practices, support for skills development, and providing a safe and healthy workplace.

Right to Freedom of Assembly and Association

At LAM, employees have the right to freedom of assembly and association in the workplace and are free to join organizations in accordance with Danish law. Recognized labor unions are entitled to participate in collective bargaining. Employees serving as representatives must not be treated less favorably than other employees.

We Do Not Accept Child Labor

At LAM, we have zero tolerance for any form of forced labor or child labor, which we strongly condemn. We are committed to due diligence and have procedures in place to avoid direct or indirect involvement in forced or child labor—for example, via our supply chain or investments. If we are found to be involved in such practices, we are also committed to contributing to their elimination.

Environment and Climate Change

At LAM, we are committed to complying with current legislation and regulations concerning environmental protection and climate change prevention.

Furthermore, we strive to:

  • Improve our climate and environmental performance and integrate climate and environmental considerations into our business operations and activities.
  • Reduce resource consumption (e.g., energy, water) and promote the efficient use of these resources.
  • Reduce pollution, CO₂ emissions, and waste resulting from business activities.
  • Promote and implement initiatives to foster greater environmental responsibility and a sustainable future—for example, by focusing on recycling and repair.

We aim to raise awareness of climate and environmental issues, educate our employees, and encourage participation in any events organized by LAM. We encourage our customers, suppliers, and other business partners to adopt similar climate and environmental responsibilities.

Whistleblowing

LAM uses the national whistleblower reporting system at https://whistleblower.dk/ , allowing anyone to report unlawful behavior. All whistleblower reports are investigated promptly and confidentially, and whistleblowers are protected. If you observe inappropriate business or personal conduct by one of our employees that may represent a potential or actual violation of this Code of Conduct and its principles, you are encouraged.

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