Compliance i SOS International

To achieve our vision –

We want to be perceived as the most trusted assistance partner

– we must be committed to the highest ethical standards of business conduct.

Our Code of Conduct (the "Code") describes the compliance and ethical principles that guide our company, our employees and the interactions we have with our stakeholders. Our Code ensures that our values are reflected in our daily work and that we enhance the transparency of our activities for all stakeholder groups. Our Code reflects the business conduct that our customers will expect in the market that we operate in. It directs business practices as outlined by our corporate compliance programme and highlights potential areas of risk and conflict, prescribing guidelines of conduct for these areas.

In addition to this Code, SOS International will comply with all applicable laws, conventions and regulations.

All employees of SOS International are expected to adhere to and act according to the principles enclosed in this Code.

Non-compliance with this Code, company policies, laws, conventions and regulations and/or contractual obligations may not only have potential legal and regulatory consequences, but may also compromise SOS International's reputation. Unethical or illegal acts can never be justified. Violation of the Code may result in disciplinary actions and further employment law consequences, e.g. in the form of warning, employment termination or summary dismissal.

Compliance concerns and suspected violation of our Code can be reported to GroupGRC@sos.eu.

Conducting fair business practices and maintaining respectful customer relations is an essential part of the way we do business. We do not tolerate any dishonest behaviour and seek to always act with dignity and integrity.

CORRECT INFORMATION, ACCOUNTING AND REPORTING

We make decisions based on information recorded at every level of SOS International. We must record all information honestly and accurately. This includes, but is not limited to, expenses, revenues, case data and any other corporate information. All financial transactions and payments must be authorized and recorded.

SOS International business information will be communicated accurately and fully, both internally and externally. All accounting information must be correct, registered and reproduced in accordance with laws, conventions and regulations. Strict compliance with corporate accounting methods is required, as is cooperation with internal and external auditors.

Any intentional act that results in a material misstatement in financial statements will be treated as fraud.

FAIR COMPETITION

SOS International believes that customers and society as a whole benefit from fair, free and open markets. We do not make agreements with competitors to fix prices or otherwise restrain free trade.

CONFLICTS OF INTEREST

We have a responsibility to make decisions strictly on the basis of SOS International’s best interests. Business decisions and the provision of services may never be influenced by personal concerns and personal relations of our employees.

The key to addressing conflicts of interest is full disclosure. Employees have the responsibility to disclose any potential conflict of interest to SOS International.

USE OF SUBSTANCES

Use of illegal drugs, alcohol abuse and the misuse of legal drugs create serious health and safety risks in the workplace. The possession, sale or use of illegal drugs or being under the influence of such drugs, on company time or property, or at company-sponsored events, is prohibited. Similarly, impairment from alcohol when conducting company business is also prohibited. It is important that cases regarding drug and alcohol abuse be brought to management’s attention immediately.

COMMUNICATION

SOS International is committed to providing accurate and trustworthy information to the media and the public. To ensure consistent communication and compliance with SOS International’s policies, employees are prohibited from making statements to the media regarding or on behalf of SOS International unless in accordance with SOS International’s communication policy or approval has been granted by the manager of the communications department. If employees are contacted by the media they should kindly forward the request to the manager of the communications department.

CONFIDENTIALITY

Information is an important company asset which must be carefully protected. Handling sensitive information including company, customer and health information is part of our core business and all employees are obliged to keep sensitive information confidential.

• All employees are required to accept obligations of strict confidentiality during and after their employment with SOS International. This also includes substitutes, consultants, service personnel and visitors
• We take all reasonable precautions to ensure that we do not disclose confidential information, including confidential information belonging to our customers, to any third party without a valid business purpose and proper authorisation
• Employees shall protect SOS International’s intellectual property rights including trade secrets. Employees shall not unlawfully use or acquire trade secrets and other confidential and proprietary information of other companies

SOS International is committed to economic, environmental and socially sustainable development. This forms the basis of our approach to corporate social responsibility and our way of conducting our business with high integrity and ethical standards.

This Supplier Code of Conduct (this “Code”) is inspired by the ten general principles contained in the UN Global Compact. It includes respect for the environment, anti-corruption and universally recognised principles on human rights, including labour rights. SOS International wants to uphold this Code and the related instructions in a spirit of constructive dialogue and in partnership with our suppliers for the mutual benefit of both parties.

This Code governs the business relationship between SOS International and our suppliers regarding the themes corporate social responsibility and business ethics.

As a condition for doing business with SOS International, we require our suppliers to comply with the Code and related instructions. In addition, suppliers shall ensure that their sub-contractors also comply with the provisions of the Code and the related instructions.

The provisions in this Code are minimum requirements to suppliers. In addition to meeting the minimum requirements in this Code, suppliers must comply with all applicable local laws and regulations. If there are differences between the provisions of the Code and applicable laws or regulations, suppliers shall adhere to the higher requirements.

The supplier shall at SOS International’s request provide sufficient information for SOS International to ensure that the supplier is compliant with the Code and the related instructions. Such information may be disclosed to SOS International’s customers if relevant.

If this Code or the related instructions is not complied with, the supplier shall inform SOS International immediately and prepare an action plan to remedy the non-compliance.

SOS International reserves the right to consider any non-compliance by suppliers or sub-suppliers a material breach of the agreement between SOS International and the supplier.

Suppliers are expected to support the protection of internationally recognised human rights, including labour rights, as stated in the UN International Bill of Human Rights and the UN International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

As a minimum, SOS International expects our suppliers to:

• Condemn the use of forced labour and exploitative child labour
• Comply with applicable laws, agreements and industry standards on compensation and working hours
• Respect employees’ lawful freedom of association and the right to collective bargaining
• Provide equal opportunity for all employees and not discriminate at any level of the organisation on the basis of ethnicity, gender, age, religious beliefs, social origin, disability, sexual orientation, gender identity or any other legally protected characteristic
• Provide a safe and healthy work environment

Suppliers must manage all significant potential and actual impacts on the environment and climate.

As a minimum, SOS International expects our suppliers to:

• Identify aspects of the supplier’s activities, products and services that have or may have significant impact on the environment
• Ensure legal compliance with applicable law or regulation relevant to the environmental impacts of the supplier’s activities, products and services
• Establish environmental objectives and targets relevant to the law and significant environmental affairs, and develop action plans to achieve the stated objectives and targets
• Ensure that activities related to the environment are conducted under specified conditions and continually monitored
• Ensure that any person  performing tasks which have the potential to cause significant environmental impact is competent and has the proper education, training and experience to overcome the potential risk

SOS International will not tolerate any form of, and will not engage in any form of, corruption or bribery. Suppliers are required to work systematically and continually against corruption or other improper business practices.

As a minimum, SOS International requires our suppliers to:  

• Comply with applicable laws and regulations relating to financial crimes, anti-corruption and refrain from engaging in any form of bribery, corruption or extortion
• Abstain from deliberate or inadvertent involvement in money laundering
• Establish and have in place adequate policies and processes to counter corrupt practices
• Refrain from offering disproportionate donations, funding, excessive gifts and extravagant entertainment and similar improper advantages to government officials, SOS International employees, agents, representatives of other business partners etc. Courtesies must be properly reflected as such in the supplier’s books or records
• Generally refrain from offering, promising or making facilitation payments
• Refrain from using the name or assets of SOS International to promote the interests of political parties or candidates
• Avoid conflict of interests and always make decisions without regard to personal concerns that could impair, or be perceived to impair, the supplier’s business judgment. Disclose conflict of interests if they occur

Suppliers are expected to adopt fair and respectful business practices towards all of its business relations. 

As a minimum, SOS International expects our suppliers to:

• Provide and record all information honestly and accurately, including but not limited to expenses, revenues, data and any other corporate information. Compliance with applicable accounting methods is required, as is cooperation with internal and external auditors
• Safeguard any confidential information and personal data. Respect and protect the individual’s right to privacy by adhering to the agreement with SOS International and the Supplier Instructions for the processing of Personal Data (for instructions, please see appendix 1)
• Abstain from fixing prices or otherwise restraining trade
• Refrain from using illegal drugs, abuse alcohol or misuse legal drugs when conducting business with or on behalf of SOS International
• Make no public statements on behalf of SOS International. Always forward any requests from the media regarding SOS International to our communications department

Questions and observations including required reporting relating to this Code shall be directed to SOS International at:

Compliance@sos.eu
SOS International
Nitivej 6
2000 Frederiksberg
Denmark

On behalf of SOS International, I hereby certify that this document is valid and has been approved by SOS International Group Management

Niels Krag Printz, CEO
September 2015.