Code of Conduct
1 Introduction
The AACG Code of Conduct represents our commitment to ethical practices and professional conduct.
It supports you in making the right choices, ensuring fairness, transparency, and respect. All employees,
contractors, and partners must uphold these standards to build a trustworthy and sustainable business.
1.1. AACG Principles of Conduct
Absolent Air Care Group (AACG) is committed to responsible conduct in all the societies where we
operate, extending our responsibilities to employees, business partners, and the broader community.
Our guiding principles are:
Integrity: We conduct our business with the highest moral standards.
Legal Compliance: We adhere to the laws and regulations of every country we operate in and take
responsibility for our actions in these jurisdictions.
Human Rights: We respect the United Nations Guiding Principles on Business and Human Rights,
ensuring our actions uphold the rights of our employees and the communities we engage with.
Policy Integration: We incorporate these principles into all our business processes.
As an AACG employee, you are obligated to maintain high standards of integrity and fairness toward
all stakeholders, including customers, end-users, shareholders, investors, employees, business
partners, suppliers, governments, authorities, and local communities.
1.2. Managers’ Responsibilities and Implementation
The President and CEO of AACG is ultimately responsible for the Code of Conduct, while managers
are responsible for implementing it effectively and integrating it into the company culture.
Responsibilities Include:
Leading by Example: Demonstrate ethical behavior and compliance with the Code.
Communicating: Ensure all employees are informed about the Code and its importance.
Addressing Concerns: Handle any issues or complaints related to the Code.
Onboarding New Employees: Introduce and explain the Code to all new hires.
Implementation:
• The Code will be integrated into the onboarding process for new employees.
• The Code shall be accessible to all employees, and annual training shall be conducted
• Employees must ensure their activities align with the Code and each employee is individually
responsible for understanding and adhering to this Code of Conduct
• In the absence of specific laws, employees should adhere to the Code’s principles.
Managers must also stay informed about any local legislative requirements applicable to their site or
legal entity.
2 Our purpose and our Values
We are on a mission to help businesses to clean their air with our products and solutions to benefit both
people and businesses. Our values, Caring-Ethical-Dedicated-Driven is our guiding star and should
guide every aspect of our actions:
Caring
• We care about people. We care about their health and quality of life.
• We care about our customers and the challenges they face.
Care encompasses everything we do. We believe that by enabling healthier work environments, we
give people and businesses an opportunity to grow.
Ethical
• We keep our promises,
• We are honest and transparent,
• We treat our stakeholders with respect and consideration.
For us it is not enough to meet rules and regulations. It is about doing the right thing and provide
solutions that are of real and lasting benefit to our customers and their employees.
Dedicated: We are dedicated to enabling health growth through advanced air cleaning solutions. We
are always innovating and improving our offer, building on a strong engineering heritage. And we are
willing to help our customers – no matter what it takes.
Driven: We are driven to be the best in our industry. Not for its own sake, but because we can see
there is a growing need all over the world for the benefits our solutions provide. Clean air is slowly being
recognized as key to improved employee health and work performance. It is our responsibility to
accelerate this shift in perception – by leading the way to real and sustainable change.
3 Responsibilities towards shareholders
3.1. Public information and confidential information
Any information that is not public property or public knowledge shall be considered confidential
information, e.g. trade and business secrets and personnel information. Confidential information shall
be protected and not disclosed unless required by law or authorized by management. Necessary
steps shall be taken to avoid unintentional disclosure of confidential information, which include storing
and transmission of such information in a safe manner.
Confidential information received from third parties shall be handled with similar respect.
3.2. Insider information/trading
Insider information is private details about AACG that have not been shared with the public but could
impact the company’s share price if they were made known. This includes things like our financial
results, upcoming acquisitions, or major company changes.
AACG is dedicated to keeping this information confidential and strictly forbids insider trading—using
this information to buy or sell shares for personal gain. This Code is in place to ensure we all follow
high ethical standards and legal requirements, helping us maintain a strong reputation in the public
and financial markets.
For identified PDMR – each person is responsibility to report any changes in their ownership of AACG
shares or other financial interests and to follow the relevant laws and regulations. Breaking insider
trading laws is a serious offense and can lead to legal consequences. For more details, please check
AACG’s Information and insider Policy.
3.3. Records and reports
AACG is dedicated to upholding high standards of integrity in record keeping and reporting. As an
employee, you must ensure that all records—whether for internal or external use—are accurate and
complete. This includes careful preparation, thorough review, and adherence to accounting rules and
internal controls.
You are also required to follow AACG’s procedures for retaining and disposing of records, ensuring
you comply with all relevant guidelines and regulations.
4 Responsibility towards Human rights and fair labor conditions
At AACG, we are dedicated to upholding and respecting human rights in all aspects of our operations.
We believe that every individual deserves to be treated with dignity and respect. Our commitment to
human rights is reflected in the following principles:
Non-Discrimination: We are committed to ensuring a workplace free from discrimination,
harassment, and bias. All employees are entitled to equal opportunities and fair treatment, regardless
of race, gender, age, sexual orientation, disability, religion, or other characteristics. Recruitment and
promotions are based on matching job requirements with candidates’ qualifications and experience.
Harassment-Free Environment: AACG maintains a zero-tolerance policy for any form of harassment
or abuse. We strive to create a safe and supportive environment where everyone can work without
fear of intimidation or offensive behavior.
Fair Labor Practices Fair and No Forced Labor: We uphold fair labor practices, ensuring that our
working conditions comply with all legal and industry standards. This includes fair wages, safe
conditions, reasonable hours, and voluntary work. Forced, bonded, or involuntary labor is strictly
prohibited in our operations and supply chain.
Freedom of Association: We support the right of employees to freely associate, join unions, or
engage in collective bargaining without fear of retaliation or discrimination.
Respect for Local Laws: We respect and comply with human rights laws and regulations in every
country where we operate. We ensure that our business practices align with local and international
human rights standards.
Prohibition of Child Labor: AACG strictly bans child labor in all areas of our supply chain. We are
committed to safeguarding children from exploitation and ensuring they are not exposed to work that
could harm their health, development, or education. A child is defined as anyone under 15 years old,
or 14 in developing countries as per ILO Convention No. 138. If local laws set a higher age, those
laws apply.
Responsibility and Reporting: We encourage all employees to report any concerns or violations
related to human rights. AACG is committed to investigating such reports promptly and thoroughly
and protecting those who come forward in good faith.
We expect all employees, suppliers, partners, and stakeholders to uphold these principles and
contribute to a respectful and equitable work environment.
4.1. Work environment and Health and safety
Safety is the utmost priority at AACG, always guiding our decisions and actions. At AACG, the health
and safety of our employees are our top priorities. Our focus includes:
Preventive Measures: We adhere to all relevant laws and focus on preventing workplace risks.
Regular risk assessments will ensure we take necessary precautions to avoid accidents.
Training and Equipment: As an employee you will receive the required safety training and protective
equipment to perform your tasks safely. In case of process disruptions, safety takes precedence over
production.
Role of you as employee: You must act safely, follow all safety instructions, and report any risks or
incidents. Being under the influence of alcohol or drugs while at work is prohibited. At AACG, we
expect you to maintain clear judgment and avoid alcohol, drug abuse, or gambling that could impact
your performance.
By following these guidelines, you contribute to a safe and healthy work environment for yourself and
your colleagues.
4.2. Pay and other terms of employment
AACG shall comply with local laws and regulations regarding workers’ contracts and working hours.
Salaries shall be paid regularly, be adequate and comply with the applicable local legislation and the
local market situation.
Employees are entitled to a minimum of one day off out of seven and to take time off for official
national and local holidays, all in accordance with domestic law. Employees shall be granted the
stipulated annual leave, sick leave, and maternity/ paternity leave without any negative repercussions
from local management.
Employee Privacy: AACG is committed to safeguarding employee privacy and managing personal
data with the utmost confidentiality. We adhere to legal requirements, including the EU’s General
Data Protection Regulation (GDPR) and local laws, to ensure personal information is handled
securely.
4.3. Company assets and IT security
AACG’s assets, including physical items (such as buildings and resources) and financial resources,
are critical to the company. They must be used exclusively for AACG’s business purposes and
safeguarded against damage, loss, theft, and misuse. Employees must not use these assets for
personal gain or competitive activities. Proper and responsible use of company property, including
equipment provided by AACG, is mandatory and essential for the benefit of AACG and its
shareholders.
Various IT systems and equipment are vital parts of the work environment, and every employee shall
act in accordance with the AACG IT Policy and Information Security Policy (see separate policies).
5 Responsibility towards business partners
5.1. Fair business dealing
All employees shall behave in accordance with high business ethics and act in compliance with laws
of antitrust, competition and fair dealing.
AACG shall respect the laws and regulations in the countries in which the Group operates and
requires that its suppliers and partners do the same. All employees shall follow relevant laws and
regulations and adhere to internal AACG policies and rules, including this Code that may go beyond
what is required by law.
Should any requirement in this Code violate applicable law, the law takes precedence.
5.2. Fair competition and antitrust legislation
AACG is committed to competition that is based on the added value of its products and services. We
do not engage in unfair, misleading, or inaccurate comparisons, anti-competitive agreements or
arrangements and do not tolerate bribes or extortion, neither as a payer, initiator nor receiver.
5.3. Relations with business partners, suppliers and other stakeholders
All employees are expected to ensure that our business complies with the Code and to make sure
that our business partners, suppliers, consultants and other stakeholders are duly informed of its
contents.
We prefer to cooperate with suppliers, distributors, agents and consultants and other business
partners that share the same view on the principles expressed in this Code. Should a supplier fail to
comply with AACG’s Code of Conduct, we shall cooperate with the supplier to try to resolve the
situation. If not possible, the relationship shall be terminated.
6 Responsibility towards Environment and Society
At AACG, we are committed to sustainability and minimizing our environmental impact. Our commitment
includes:
Environmental Responsibility: We strive to minimize our environmental impact by adhering to all
relevant laws and regulations, implementing sustainable practices, and reducing waste and resource
consumption.
Sustainable Practices: We integrate sustainability into our business operations by promoting energy
efficiency, reducing emissions, and supporting eco-friendly initiatives.
Continuous Improvement: We regularly review and improve our environmental practices to ensure
we meet and exceed industry standards and contribute positively to the communities where we operate.
Employee Involvement: All employees are expected to support and participate in our sustainability
efforts by following environmental policies, identifying areas for improvement, and adopting practices
that reduce environmental impact.
By upholding these principles, we aim to protect the environment and contribute to a sustainable future
for all.
6.1. Environmental protection
AACG shall work with sustainability at heart by providing clean air for people, planet, and life. We have
a responsibility for the environmental compatibility and sustainability of our products and services and
it is crucial that everyone in our organization shows responsibility in every aspect of our work.
As an employee you must:
Follow Instructions: Adhere to AACG’s environmental guidelines and laws.
Use Resources Wisely: Conserve water, energy, and materials.
Get Permits: Ensure environmental permits are obtained before starting activities.
Report Issues: Immediately report any environmental concerns or questions about our processes. Do
not rely on others to report them.
For more information turn to the CSR policy
6.2. Anti-corruption
AACG has a zero-tolerance for any types of bribes, fraud, facilitation payments or other improper
benefits contrary to this policy, local laws and regulations, industry standards or ethical codes in the
countries in which the Group operates.
For more details, employees should consult AACG’s Anti-Bribery and Anti-Corruption Policy. If there is
a conflict between local law and this Code, local law takes precedence, and any deviation must be
reported to AACG as outlined in paragraph 8 of this Code.
6.3. Political contributions
AACG shall be politically neutral and shall not pay any political contributions to obtain business
advantages. Individuals’ participation in politics must not involve the use of AACG’s funds, time,
equipment, supplies, facilities, brand or name.
6.4. Trade sanctions and export controls
AACG is committed to adhering to trade sanctions and export control regulations, which we view as
vital for advancing human rights. We do not tolerate any violations of these laws by our employees.
This means that AACG will not engage, directly or indirectly, in any business, or transaction prohibited
by applicable trade sanctions or export control regulations. Furthermore, AACG and its employees shall
not carry out any direct or indirect business activities with any person, entity or government targeted by
trade sanctions, nor export goods or services subject to export control laws without required licenses
and/or approvals from the relevant authorities.
7 Conflict of interests
At AACG, a conflict of interest arises when personal interests interfere with the company’s interests.
We are committed to avoiding conflicts of interest entirely and making decisions based solely on what
is best for the company, not on personal preferences or relationships.
Definition: A conflict of interest occurs when personal interests conflict with AACG’s interests,
potentially influencing job performance or decision-making.
Avoidance and Transparency: To avoid conflicts, as an employee you must disclose any personal
interests that might conflict with AACG’s interests. We conduct business based on the company’s
interests and strive to make objective decisions.
Disclosure: you must report any actual or potential conflicts of interest immediately to your manager
or the manager’s supervisor. This includes any relationships or financial interests that could influence,
or appear to influence, your professional responsibilities.
Recusal: As an Employee you should recuse yourselves from participating in decisions or activities
where you have a personal stake. This helps ensure that business decisions are made impartially.
Family and Personal Relationships: Personal relationships with colleagues, clients, or vendors
must be managed carefully to avoid any appearance of favoritism. Such relationships should be
disclosed to maintain transparency.
Gifts and Entertainment: As an employee, you should not accept gifts, favors, or entertainment from
clients, vendors, or partners that could affect, or appear to affect, business decisions. All such offers
must be reported for review.
Review and Compliance: AACG will review reported conflicts and take appropriate actions to
manage or resolve them. As an Employee you are expected to fully cooperate in these reviews.
By following these guidelines, we maintain the integrity of our decisions and uphold the trust placed in
us by AACG.
8 Report
If you notice anything that seems wrong or violates the Code, please speak up. You can:
Report concerns to your line manager, local management, or the person responsible. For more details
and forms, check the intranet. If it is difficult to address the issue locally, you may contact Head Office’s
Code of Conduct whistleblowing function.
Contact information Head office Code of Conduct whistleblowing function
President and CEO or CHRO
Absolent Air Care Group AB
Att: CEO or CHRO
Karl Gustavsgatan 1A
411 25 Gothenburg, Sweden
Phone: +46 (0)510- 48 40 00
Email: whistleblowing@absolentgrop.com
All reports are confidential. AACG has zero tolerance for retaliation. Your reports will be handled
properly, and you will be informed of the results if possible.
If you are unsure how to act in a certain situation, a guiding principle is to ask yourself the following:
• Is this against the law?
• Would this be considered unethical?
• Could this potentially jeopardize and/or damage AACG’s reputation?
• Would it be embarrassing to read about this in the media?
8.1. Compliance
Failure to follow this Code can lead to disciplinary actions, including dismissal. If you suspect that
laws, legal requirements, or this Code are being violated, please report it to local management. You
can do so with confidence, knowing that your confidentiality and anonymity will be protected.