Governance

Complying with ethical standards and laws is the starting point for all actions and decisions at Bromma. Behaving ethically is the responsibility of every employee at Bromma and a requirement to the company’s business partners. Our Code of Conduct is our main instrument in setting and implementing an ethical corporate culture. The Code of Conduct helps our people make informed decisions and find more information when in doubt.

Bromma has a robust risk-based Ethics & Compliance programme, which focuses on preventing, detecting and responding to potential misconduct, and ensures that related risks are managed effectively and consistently throughout the organisation.

Through mandatory Code of Conduct e-learning courses, Bromma trains its employees on ethics and compliance-related topics and provides exercises and examples that help employees with ethical dilemmas. The Code of Conduct training always includes content on anti-corruption and anti-bribery.

Bromma promotes a speak-up culture and the company encourages its employees to openly raise and discuss compliance concerns and questions, as well as to seek guidance. Bromma employees can report their concerns and potential misconduct through a variety of channels, which includes:

• Discussing directly with the line manager (primary channel for employees)
• Informing HR or the Ethics and Compliance functions
• Our SpeakUp line is an externally hosted channel that is available to anyone to report suspicions of misconduct in a safe and confidential way. It is an early warning system for Bromma to respond to potential problems, reduce risk and build trust within and outside of the organisation. Access the SpeakUp line to make a report at all suspected misconduct, including cases related to corruption and bribery, is subject to review and a potential investigation as assessed by the company’s Ethics & Compliance team. Our SpeakUp system enables and protects the confidentiality of reports and, where allowed by applicable law, the anonymity of reporters who wish to remain anonymous. Access the SpeakUp line to make a report.

In confirmed cases of misconduct, the Ethics & Compliance team agrees with relevant management team members on appropriate corrective actions, such as improved controls, training, disciplinary actions or termination of third-party relationships. The appropriate and adequate means of remedy are determined based on the details of the case, the needs of the affected person or people, and local legislation. The Kalmar Leadership Team discusses compliance topics and reviews the need for remedial and/or corrective measures during the bimonthly Code of Conduct panels led by the Head of Ethics & Compliance.