We at Tele2 are proud of our Business Partner Code of Conduct and the document has a very strong position in our company. Naturally as part of our sustainability and compliance efforts, we expect our Business Partners (suppliers, consultants, and other categories) to adopt equally, or higher, requirements as Tele2 by signing, implementing, and complying with our Business Partner Code of Conduct. 

Both Tele2's Code of Conduct and Business Partner Code of Conduct are based on the ten principles provided by the United Nations Global Compact and encompasses the United Nations Universal Declaration of Human Rights, the International Labour Organisation's (ILO) 8 core conventions, the United Nations Convention Against Corruption and the United Nations Convention on the Rights of the Child article 32. 

Our view on general requirements, for parties developing their own code as referred to above, we suggest and encourage Business Partners to look into the following, if/when designing own codes:

The United Nations Global Compact (UNGC)

The Universal declaration of Human Rights

The OECD Guidelines for Multinational Enterprises

The International Labour Organization Standards

The United Nation's Children's Rights and Business Principles

The first on the list above, the UNGC, consists of an overall corporate responsibility short list with 10 principles in the fields of Environment, Labor Rights, Human Rights and Anti-corruption. Applying the UNGC is likely to cover most companies’ basic needs, in relation to sustainability and compliance, and is an excellent starting point to help qualifying to be a Business Partner with Tele2. 

Compliance and follow up for Business Partners

To make sure that these requirements are followed, we conduct on-site audits at selected suppliers’ sites, based on our risk analysis. The risk analysis assesses suppliers based on e.g. EcoVadis performance, sector-, country-, commodity-specific risks, etc. For each audit we publish an audit report. You can find our most recent audit reports here and here.  

Tele2 would like to draw your attention to the fact that part of each audit will focus on how you, as Business Partner, ensure compliance with your suppliers. We therefore strongly recommend you to spread the requirements, separate or all together as a code, relevant to the Business Partner Code of Conduct areas and follow up on progress and compliance for your supply chain and other relevant parties. 

We are fully aware of that this is considered a difficult area, much depending on the spread and number of suppliers as well as their geographical position. Nonetheless we expect you to make all reasonable efforts and take reasonable actions to ensure compliance with our code and for being a trustworthy Business Partner to us and in society at large. For any questions regarding the Business Partner Code of Conduct please do not hesitate to contact Erik Wottrich, Head of Sustainability at erik.wottrich[a]tele2.com. 

Tele2 Business Partner Code of Conduct 

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Tele2 wins customers and builds long-term relationships by providing cost efficient and good quality services. This is done by demonstrating honesty and integrity in all interactions. Our marketing and advertising, expressed in communications or by employees, shall be accurate, truthful and comply with mandatory laws.  

Customer integrity

In the course of its operations, Tele2 has access to customer data for processing and storing. When handling data, Tele2 and its Business Partners shall take into account the Tele2 customers’ rights to maintain personal integrity and privacy. 

Tele2 should be trusted by customers and employees to handle their data, and can only achieve this in cooperation with its Business Partners. This includes compliance with applicable laws and regulations on the freedom of speech, the right to privacy and personal integrity as well as on personal data retention.  

Customer safety

Tele2 actively works to prevent fraud and abuse of its communications services. Therefore, Tele2 offers tools to prevent exposure to unwanted content. We are particularly careful in protecting the safety of children and young adults in this regard.  

Exposure to electromagnetic fields

When in use, electric equipment emits radiation and creates electromagnetic fields (EMF). In handling EMF related to Tele2’s networks, Tele2 and its Business Partners follow recommendations made by the relevant authorities.  

Tele2’s 

Tele2’s contractual relationships with suppliers and vendors and dealers are important elements of the company’s success. Supplier and vendor selection, and all other procurement decisions, must be made objectively and in Tele2’s best interests, striving for the best deal by evaluating costs, requirement fulfilment, expected delivery capability, quality and other relevant factors. 

Tele2 requires that business decisions are made without any unjustified influence from a third party. Suppliers and vendors which are proven to attempt to unduly influence Tele2’s procurement decisions will be excluded from any future transaction with Tele2. 

Anti-corruption

Tele2 employees and members of the Board of Directors may not offer, ask, give or accept, directly or indirectly, any undue advantage for personal gain to or from any third party, unless it can be constituted as being within the boundaries of accepted business practices such as representation and reasonable hospitality given in the ordinary course of business. Business Partners are expected to adhere to the same standards in relation to the work they do for Tele2. 

In most countries, gifts or benefits to government employees or public officials are considered a violation of law. Business Partners must not offer money or any gift, at their own initiative or on behalf of Tele2, to an official or employee of a governmental entity, except for symbolic gifts of insignificant monetary value, provided this is allowed by law. 

Fair competition

Tele2 is firmly committed to fair competition and open markets. One of the foundations for our success has been the break-up of monopoly power. We remain firm believers that free and fair competition works in our favor allowing Tele2 to provide expected quality and cost-efficient communication services to our customers. Accordingly, Tele2 and its Business Partners are expected to comply with competition laws and for example not engage in collusive practices or monopoly foreclosures. 

Conflict of interest

When business decisions are made by Tele2, conflict of interest should be avoided, so that decisions are always in the best interest of Tele2 and its Business Partners. Personal relations or considerations may never cause to influence Tele2’s decision making. This includes not only potential gains given to Tele2 employees, but also to relatives and friends of Tele2 employees. Business Partners are expected to identify any possible conflict of interest in their (prospective) relationship with Tele2, and inform Tele2 of such conflicts. 

Business Partners need to be aware that, to avoid risk of conflict of interest, the following applies to Tele2 employees: 

• Employees may not, without the company’s written consent, work outside Tele2 in any capacity (e.g. employment, consultancy, Board membership).
• If there is any risk, however small, for conflict of interest, employees are expected to immediately inform their manager.

Financial reporting

Tele2 is required to follow strict accounting principles and standards (IFRS), to report financial information accurately and completely, and to have appropriate internal controls and processes to ensure that accounting and financial reporting complies with legislation. Business Partners must act in a way that supports Tele2’s efforts in this area. 

The integrity of Tele2’s financial records is critical to the operation of Tele2’s business and is a key factor in maintaining the confidence and trust of our shareholders. Tele2 must ensure that all transactions are properly recorded, classified and summarized in accordance with Tele2 accounting policies. Business Partners may not cause Tele2 employees to enter or remove information in the company's books or records that intentionally hides, misleads or disguises the true nature of any financial or non-financial transaction or result. 

Corporate Governance

Tele2 strongly believes in transparent and consistent corporate governance practices and abides with the applicable regulations and standards in each of its geographical markets. This protects the legitimate interests of all Tele2’s shareholders and stakeholders, and Tele2 expects its Business Partners to act in support of these efforts. 

Fair working conditions

All employees of Tele2 and its Business Partners are entitled to fundamental human rights which shall be known, understood and respected and be applied equally. No one shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. Forced, exploited or bonded labor is strictly forbidden. Employees shall not be required to lodge deposits or original identity papers as a condition for employment. 

Employees shall not be forced to work more than the limits on regular and overtime hours allowed by the laws of the country in which they are employed. Overtime shall be compensated at no less than the legally required rate. All employees shall have contracts specifying the terms of employment. Children under the minimum working age established by local law or fifteen (15) years, whichever is greater, shall not be used as part of the labor force. Employees under eighteen (18) years shall not be engaged in hazardous or heavy work, or on night shifts. 

The rights of employees to freely associate and to bargain collectively, in accordance with the laws of the countries in which they are employed, shall be recognized and respected

Child Protection

To support the protection of children’s rights, Tele2 gives guidance to its employees regarding child protection. Tele2 employees are under no circumstance allowed to contact or to meet children for any kind of sexual purpose. They do not visit bars, restaurants or hotels where children are sexually exploited in any way, and report suspected cases of sexual exploitation of minors to the police immediately. Tele2 applies the same standard online as it does offline, and does not allow employees possessing, or searching for, materials documenting sexual abuse of children. 

Business Partners are expected to adhere to the same standards in relation to the work they do for Tele2. 

Diversity and Inclusion

All employees of Tele2 and its Business Partners are protected by the fundamental right not to be discriminated against. They shall not be subject to discrimination, whether active or by means of passive support, whether based on ethnicity, national origin, religion, disability, gender, sexual orientation, marital or parental status, union membership, political affiliation, or age. 

Compensation and benefits

No employee of Tele2 or its Business Partners will be paid less than the minimum total wage required by applicable national law, including all mandated wages, allowances and benefits. All employees shall have the right to equal pay for equal work, as well as periodic holiday with pay. 

Occupational health and safety

Safety at work is a prioritized concern of Tele2’s and therefore it takes adequate steps to prevent accidents and injury to health, by minimizing the causes of hazards inherent in the working environment and by providing appropriate safety equipment. The same is expected from Business Partners. 

The Business Partner shall apply a precautionary approach towards environmental and climate matters, and to protect biodiversity and ecosystems. Business Partners running operations with high environmental impact, e.g., production facilities and construction of network infrastructure, shall undertake initiatives to promote greater environmental responsibility and encourage the development of environmentally friendly technologies. 

Environmental management

Efforts to reduce and optimize the consumption of energy, water and materials shall be promoted. If available in the country, renewable energy sources shall be prioritized. In order to minimize waste generation, the Business Partner shall strive to reduce, reuse and recycle materials and products, in that priority order. Hazardous waste and effluents shall be handled appropriately. Emissions of greenhouse gases should be measured, monitored and a plan to minimize such should be developed. 

Responsible and safe products

The Business Partner should apply the substitution principle for chemicals that can be replaced by those that are less hazardous, and have a process in place to identify Substances of Very High Concern (SVHC) present in products delivered to Tele2, in accordance with the REACH (EC1907/2006) regulation. Electric and electronic products delivered to Tele2 must not contain any of the following substances: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, DEHP, BBP, DBP or DIBP, in accordance with the Restriction of the use of certain Hazardous Substances in electrical and electronic equipment (RoHS) directive. The Business Partner shall work proactively to ensure that minerals (such as but not limited to tungsten, tantalum, tin, and gold) in its products and its supply chain are responsibly sourced. When applicable, the Business Partner shall have a policy and due diligence process in place, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

It is the responsibility of business partners to make sure that both the content and the spirit of this Business Partner Code of Conduct are communicated, understood and acted upon within their organizations and to encourage employees to reveal behavior that may be non-compliant with the Business Partner Code of Conduct . Explicit or implicit approval of questionable actions will not be tolerated. 

As soon as any person is informed of, or suspects, any activities, taking place at Tele2 or at a business partner, that may be in violation of this Business Partner Code of Conduct, it is this person’s responsibility to report it. 

In order to report via the Whistle Blower channel, please use one of the following alternatives: 

• E-mail to report.violation@tele2.com  

• Send a letter to the address “Tele2 Whistleblower, Att. EVP Corporate Affairs, Box 62, SE-164 94 Kista, Sweden

• Use the direct telephone contact at +46 701 620 062.  

Reports are received by Tele2’s Director Group Security, who work under supervision of, and with the support from the EVP Corporate Affairs and the Audit Committee of the Board. All whistleblowing channels are designed, set up and operated in a way that ensures the confidentiality of the whistleblower. Reporting can be done either anonymously, confidentially, or openly.