VR Group Code of Conduct

1. Why do we have a code of conduct?

The VR Group (VR) seeks to achieve its long-term profitability goals ethically and responsibly. Responsibility is at the core of VR’s business and an integral part of VR’s strategy. The vision of VR is “Getting there together for a better world”. This code of conduct benefits VR as well as its employees and other interest groups.

By acting honestly, we maintain our good reputation. In addition, we ensure that we are an interesting employer to both current and potential employees.

At the same time, we live up to the expectations of our various interest groups, such as the owner, customers, suppliers and service providers as well as authorities. For employees, the code of conduct is important, because it fosters a shared culture that values honesty and responsibility and helps us make the right decisions in the situations we encounter in our work.

2. Who has to comply with the code of conduct?

This code is based on VR's values, which are customer-oriented operations, safety and responsibility, successful together, renewal and being goal-oriented. The code of conduct applies equally to all of VR's personnel and management, in other words, the board of directors, the management team and other management and employees.

Everyone at VR is expected to comply with this code of conduct as well as the company's other valid instructions in their work. Employees in supervisory positions should be particularly active and determined in promoting VR's values and the corporate culture expressed in this code.

The board of directors of VR Group Oy has approved this code of conduct and monitors compliance with it. The code of conduct is reviewed regularly and updated as necessary.

3. What should I do in case of a problem?

We encourage employees to report all suspected misconduct or violations of the code of conduct. Violations of the code of conduct are taken seriously. Every employee is obligated to report violations of law or other serious violations of the code.

You can report such matters in person, by phone, by mail or by e-mail to your closest supervisor, to VR's Legal Affairs, to the company's internal audit unit or to the HR Business Partner of your own unit or division. You can also report via whistleblowing service at https://report.whistleb.com/vrgroup (for more detailed instructions see: Whistleblowing Guidelines). It is possible to submit the report anonymously.

All bona fide reports will be investigated, and the necessary actions will be taken. You will suffer no negative consequences for filing a report. The rights and privacy of the person who filed the report will be protected in connection with the processing of the matter. Violating the code of conduct can lead to disciplinary actions. VR does not accept inappropriate reports.

4. Business Ethics

We are committed to doing business honestly and ethically. We obey laws and official regulations in all our activities. If the rules of the home country of one of VR's subsidiaries are stricter than in Finland, we comply with the stricter rules in the country in question.

Every employee must know the legislation and the instructions and regulations that affect his or her work. Every supervisor must ensure that their own team members know the rules and comply with them. It is important to understand that failing to comply with laws and regulations could have serious consequences both legally and in terms of our reputation.

Our business must be based on objectivity. We must avoid situations in which our personal interests are in conflict with those of VR (for more detailed instructions see: Guidelines for transactions involving related parties.) No employee should seek to exploit or help others exploit opportunities relating to VR's confidential information. In the course of our business, we may receive inside information relating to listed companies. In such situations, the prohibition of exploitation and disclosure concerning inside information must be complied with.

We do not offer, give, demand or accept gifts, payments, services or hospitality that could reasonably be considered to affect a business relationship and that exceed the limits of customary hospitality. The other party in such situations could be a business partner, potential business partner or official (for more detailed instructions, see: Anti-bribery Guidelines).

We do not support political parties, candidates or organisations.

We do not accept unfair competition or the prevention of competition, and we comply with competition law in all of our activities (for more detailed instructions see: Guidelines on compliance with competition laws).

5. Respecting Human Rights and the Rights of Employees

We respect human rights, and we are committed to comply with the United Nations’ Guiding Principles on Business and Human Rights. Human rights, such as equality and non-discrimination are included in our basic values.

We respect the rights of our employees. We are committed to comply with the International Labour Organization’s (ILO) ILO Declaration on Fundamental Principles and Rights at Work, ILO conventions on abolition of forced labour, abolition of child labour, prohibition of discrimination at work and on the freedom to join a union, in addition to ILO conventions on working time, occupational safety and occupational health.

We do not hire people who are younger than the minimum age as stipulated by ILO conventions on abolition of child labour or by the local law, whichever age is higher. We do not allow the use of any kind of forced labour.

We provide everyone with equal rights and opportunities regardless of origin, gender, nationality, religion or other corresponding characteristics. We do not accept any kind of discrimination, harassment or bullying of our employees.

Every employee has the obligation to act in such a way or ensure that no customer, colleague or other person suffers discrimination or other inappropriate behaviour.

We respect the rights of employees to form and join unions and to bargain collectively. We always pay at least the minimum wage in accordance with law or collective agreements.

6. Safety and health

Safety is always a priority at VR, and safety must never be endangered. In all our activities, we seek to promote safety and prevent accidents. Every employee is obligated to comply with the provided safety instructions in their activities.

We offer safe and healthy working conditions for our employees. We pay attention to the well-being and coping at work of our employees.

7. Environment

We are committed to acting responsibly and to taking environmental perspectives into account in our business decisions. We are an environmentally conscious company right down to our corporate image. We take the entire life cycle of a product and its effects on the environment into account in our activities, particularly in our procurement activities. In line with VR's environmental commitments, we seek to steer our procurement towards products and services that burden the environment as little as possible.

8. Personal Data and Communications

We are committed to maintaining the secrecy of VR's, our customers' and our business partners' business secrets and other confidential information as well as confidential information concerning our employees.

Business secrets and other confidential information related to VR's business, customers or employees may not be disclosed to third parties during one's employment relationship or thereafter.

Business secrets and other confidential information must be kept in such a way that only those employees who need it for their work have access to it. Every employee must comply with the provided data security instructions.

Our communications are responsible, open, customer oriented and dynamic. Public statements on behalf of VR are only given by the employees whose job it is to do so. We ensure the effective flow of information inside the company. Our internal communications are open, honest and respectful of colleagues. When engaging in discussions in social medial, the provided instructions must be complied with.

9. Business Partners

We require that our business partners act ethically. We do not work with companies that do not obey the law in their activities and that to not act ethically.

We require that our suppliers and service providers, subcontractors, representatives, partners in consortiums and other business partners comply with the ethical conditions of VR's procurement procedures or ethical guidelines, which correspond to the contents of this code of conduct.

10. More Information

You can get more information on complying with this code of conduct from your supervisor, the HR Business Partner of your unit or department or VR's Legal Affairs.

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