Code of Conduct

Instabee Group

1. INTRODUCTION

As a responsible and sustainable growing player in the ever-evolving world of logistics, we recognise that a big part of our success lies in not only delivering goods and services efficiently with great consumer experience and advanced tech, but also upholding the highest standards of integrity, ethics, and professionalism to protect and respect our employees, business partners, customers, investors, competition, society and the planet, as well as Instabee with its material and intellectual property, business and values. To guide our actions and foster a culture of trust and collaboration, we have established this Instabee Code of Conduct (“Code of Conduct”) applicable to the entire Instabee Group (“Instabee”, “we” or “us”).

This Code of Conduct does not replace laws or regulations, applicable standards or any agreement or existing policy with or within Instabee, but sets forth a common set of principles that transcend geographical boundaries, ensuring that our actions align with our values, regardless of the market in which we operate. It serves as an overarching framework for our internal collective behaviour, guiding our interactions with authorities, customers, suppliers, communities, colleagues and others, and is supplemented by more specific referred and/or underlying policies and procedures elaborating on the principles included herein in more detail. By internalising and applying this code and supplementing policies and procedures, we will collectively uphold the reputation and integrity of our company, setting us apart as a trusted and responsible partner in the market.

This Code of Conduct is mandatory to comply with and applies to all employees, consultants, interns, agency workers, staffing personnel, directors and persons employed or engaged by or acting on behalf of Instabee regardless of their position or location (“Employees”, “you”).

NOTE: The principles outlined in Sections 3-5 below are supplemented with practical examples to illustrate their implementation. These examples are not exhaustive and are included solely for clarification purposes. When acting on behalf of Instabee, the main rule is: always consult with Legal & Compliance or People & Culture when in doubt whether a behaviour, act or omission is in line with our values and this Code of Conduct.

2. STATEMENT ON RESPONSIBLE BUSINESS CONDUCT

 

Instabee supports internationally agreed conventions and standards on human rights, labour rights and responsible business conduct, including the UN Universal Declaration of Human Rights, the ten principles of the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the International Labor Organisation Declaration on Fundamental Principles and Rights at Work as well as the eight core conventions of ILO regarding forced labour, child labour, discrimination, freedom of association, and the right to collective bargaining (no. 29, 87, 98, 100, 105, 111, 138, and 182). Instabee and its Employees shall always adhere to the principles set out in these conventions and standards.

3. BUSINESS ETHICS

 

Ensuring a high standard of business ethics is a core principle of Instabee. We always consider the ethical implications of our decisions and actions, assessing the potential impact on stakeholders, including Employees, business partners, customers, investors, communities and the environment. We promote open dialogue and encourage Employees to seek guidance whenever faced with ethical dilemmas.

3.1 Legal and Contractual Compliance 

We must always comply with laws and regulations applicable to our business, the practices of our industry and, to the extent legally permissible, our contractual obligations (“legal obligations”). This includes but is not limited to legal obligations related to labour, health and safety, environmental protection, privacy, anti-discrimination, trade, and taxation. Nevertheless, compliance goes beyond just adhering to our legal obligations; it stands as an integral aspect of our dedication to ethical business conduct.

Where any applicable legal obligations impose higher standards than those set out in this Code of Conduct, such legal obligations shall apply.

For you, this could mean: Understanding and complying with Instabee‘s policies and procedures available on our Intranet and consulting with Legal & Compliance or relevant department when needed; understanding our contractual rights and undertakings and implementing procedures to ensure compliance with our contractual obligations, and performing and/or joining trainings arranged for you.

3.2 Anti-Corruption

Instabee maintains a strict zero-tolerance policy towards all forms of corruption, including bribery. We refuse any attempts from current or potential business partners, customers, or other stakeholders to improperly influence us with undue benefits or advantages that could be perceived as corrupt. Similarly, we do not engage in offering such undue benefits to influence stakeholders in our relationships and negotiations.

The zero-tolerance policy, as further outlined in our Anti-Corruption Policy, also applies for other forms of influence such as fraud, extortion, embezzlement or similar acts.

For you, this could mean: Understanding and following our Anti-Corruption Policy; remaining vigilant against any attempts to influence your decisions with gifts or favours (including non-monetary ones); never offering gifts or favours to influence others; promptly reporting any activity that raises suspicions of corruption; and understanding that your integrity directly impacts the reputation of Instabee.

3.3 Conflict of Interest

The relationship between Instabee and its Employees, as well as Instabee and any of our business partners and other stakeholders, shall always be based on mutual trust. We, therefore, have an obligation to watch for situations where personal interests conflict with Instabee’s or Instabee’s stakeholders’ legitimate interests, e.g. where someone is given the chance to take personal advantage of business opportunities that belong to Instabee, or use Instabee information, property or positions for personal gain. We must always make all decisions in the best interest of our business, hence, such conflicts should be avoided, if possible, or disclosed and managed properly.

For you, this could mean: Refraining from misusing Instabee’s resources or information for personal gain; ensuring that all decisions prioritise Instabee’s success over personal benefit (e.g. financially); and disclosing any (potential) conflicts of interest (e.g. you are recruiting a family member) to the relevant department head.

3.4 Fair Competition

We believe that fair competition is in the best interest of Instabee, our Employees, customers, our other stakeholders and society at large. We should never engage in anti-competitive activities, such as illegal price fixing, market division, abuse of dominant position, or other situations where fair competition is unlawfully prevented, restricted or weakened. Our Competition Law Policy further outlines the principles and standards that govern our activities to ensure that we maintain a competitive and fair market environment.

For you, this could mean: Being extra careful when you participate in activities that involve contact with competitors or when discussing or drafting contractual terms, including exclusivities or non-compete undertakings (never do this without involvement of Legal), and understanding and complying with Instabee‘s policies and procedures on how to discuss, meet and share information with competitors.

3.5 Trade Compliance - Exports, Imports and Sanctions

As a global provider of logistic services, Instabee must comply with and shall not violate any applicable economic, financial or trade sanctions, import or export bans, trade embargoes or similar restrictive measures in force from time to time, including those administered by the European Union, the United States, the United Nations, the United Kingdom and other jurisdictions.

For you, this could mean: Being aware of applicable trade restrictions and export requirements in place; and supporting and applying our due diligence and audit procedures for business partners.

3.6 Financial reporting & Accurate Record Keeping

Instabee is committed to accurate and transparent financial reporting. All Employees are expected to adhere to the highest ethical standards in their financial dealings, ensuring that all transactions are recorded accurately and in compliance with applicable laws and regulations. We do not tolerate any form of tax evasion or fraudulent activity.

For you, this could mean: Accurately recording all sales and expenses; properly documenting business transactions; and promptly reporting any financial discrepancies you encounter.

4. PROTECTION OF ASSETS, INFORMATION SECURITY AND PRIVACY

 

Our assets, e.g. our information, softwares, equipment and people (“Assets”), are crucial to our work and our business - we need it to operate and to maintain our competitive advantage. Since we strongly believe in what we do, we must all protect and maintain our Assets appropriately, and we do this with integrity.

4.1 Protection of Assets, Information Security and Confidentiality

Assets of Instabee can be particularly valuable and such value can be lost or compromised if misused or inappropriately disclosed. Physical Assets, including laptops, mobile devices, premises, and office equipment, often contain sensitive and/or important company or client information. We must, therefore, at all times ensure that all our Assets are protected from unauthorised disclosure or manipulation, as well as ensuring that our Assets are available to authorised users at defined times, to the extent the Assets are needed. This applies to, inter alia, any non-public information about e.g. our processes, innovation and financial or strategic plans/position (“confidential information”), trademarks, copyrights, patents, design protections and other intellectual property (“intellectual property”), contract content, software and hardware.

Furthermore, maintaining the confidentiality of information trusted with us is crucial to the trust placed in us by our stakeholders and to our compliance with legal obligations.

For you, this could mean: Understanding and following our information security policies available on the Intranet; using our company assets with sound judgement to ensure they are not stolen, lost, wasted or misused; never posting non-public company information on social media; using NDAs when sharing company information externally; preventing unauthorised access to company software; and promptly reporting any (potential) incidents in relevant channels.

4.2 Privacy

Instabee is committed to respecting individuals' right to privacy. Processing personal data with respect and in a secure and lawful manner is part of building and maintaining trust with our customers, Employees, investors, business partners and other stakeholders. Instabee is thus handling personal data with due care, in compliance with applicable data protection laws and regulations as well as our internal policies and tools designed to protect and secure the data.

For you, this could mean: Understanding and following our privacy policies and procedures, including our Group Privacy Policy; respecting individuals' privacy by always safeguarding personal data in your possession; refraining from unnecessary processing of personal data; and deleting personal data when it is no longer needed for the identified purpose.

4.3 Artificial Intelligence and Machine Learning (AI/ML)

Within Instabee, we use AI/ML legally, responsibly and ethically. In addition to what is set out in this section 4 above, we prioritise fairness in AI decision-making and transparency about how AI/ML is used. We hold ourselves accountable for the responsible development and deployment of AI/ML systems.

For you, this could mean: Pay attention to potential biases or discriminatory outcomes resulting from AI/ML models; and carefully handle and protect sensitive data used by AI/ML systems in accordance with our AI strategy and policy.

5. RESPECT FOR PEOPLE AND THE PLANET

Respect for others and professional conduct is primal to a healthy working environment and considering the impact of our actions on others. In alignment with our commitment to fostering a culture of integrity and responsibility, this section addresses key aspects of our dedication to respecting both people and the planet.

5.1 Mutual Respect

We foster a work environment that promotes respect, dignity, and inclusivity for all Employees. We have a zero-tolerance policy for acts or threats of violence, including physical, verbal, or psychological violence, or any other type of unwelcome conduct that creates an intimidating, offensive or hostile work environment at Instabee, e.g. sexual harassment.

We believe that every individual deserves to be treated with fairness, courtesy, professionalism and respect, hence we encourage open, respectful and professional conduct in all interactions.

For you, this could mean: Understanding and following our Non-Discrimination & Anti-Harassment Policy available on the Intranet; modelling respectful behaviour; never bullying, intimidating or threatening another person; speaking up and addressing conflicts constructively (e.g. reporting your concern); and supporting colleagues in upholding these standards.

5.2 Equality, Diversity and Inclusion

We value and promote equality in our workforce and prohibit discrimination in any form. We believe in providing equal opportunities and fair treatment to all Employees, regardless of background, characteristics, or circumstances, and recognise the big value of different perspectives, experiences, and backgrounds.

For you, this could mean: Understanding and following our Non-Discrimination & Anti-Harassment Policy; treating all colleagues with fairness and respect; appreciating the diverse perspectives and experiences that each individual brings to our company; evaluating candidates based on talent, skill and experience; and speaking up if noticing discriminatory behaviour.

5.3 Health and Safety

We prioritise the health, safety, and well-being of our Employees, business partners and other stakeholders to prevent accidents, incidents, injuries, near misses, work-related illnesses and unsafe conditions. We identify and mitigate potential hazards, and promote best practices. We comply with all applicable health and safety laws, regulations, standards, and internal policies and procedures.

To ensure a safe and productive work environment, we strictly prohibit the use, possession, distribution, or sale of drugs and the use of alcohol during work hours.

We are committed to promoting road safety to protect our Employees, business partners, and the community. We encourage responsible driving practices, adherence to traffic laws, and regular vehicle maintenance to prevent accidents and ensure the safety of all road users.

For you, this could mean: Understanding and following our health and safety policies, e.g. Work Environment Policy, Alcohol and Drug Policy, and Road Safety Policy; addressing potential hazards; never taking shortcuts and/or ignoring required safety practices; refraining from the use of drugs and alcohol during work hours; adhering to traffic laws; practising responsible driving; and ensuring regular vehicle maintenance. All policies and documents are found on the Intranet.

5.4 Human and Labor Rights

Instabee is committed to respecting internationally recognised human rights and condemns all forms of slavery, torture, cruel, inhuman or degrading treatment, working conditions that are a threat to life or health, and child labour.

We respect Employees’ right to freedom of association and collective bargaining as well as the Employee's choice to refrain from joining a union. Further, all forms of forced and bonded labour are prohibited including compulsory overtime. All work must be voluntary, including the right for Employees to be able to end their employment without any restrictions such as excessive notice periods or fines.

For you, this could mean: Having the right not to be subject to, or refuse to participate in, any form of slavery, forced labour, or abusive working conditions; favouring fair treatment and voluntary work practices; and reporting any violations or concerns to the appropriate channels within Instabee.

5.5 Environmental Responsibility

We are committed to being responsible stewards of the environment and to minimise the ecological impact of our operations. We recognise the importance of sustainability and strive to integrate environmental considerations into our decision-making processes throughout our operations. This includes implementing measures to conserve resources, reduce waste, and minimise our carbon footprint. We strive to continuously improve our environmental performance by setting measurable targets and monitoring progress to preserve the environment for future generations.

For you, this could mean: Integrating our Sustainability Strategy into your daily work; demonstrating responsible care for the environment; supporting sustainability initiatives; and suggesting ways to improve our environmental performance (e.g. how to minimise resource use, emissions and waste).

6. REPORTING AND WHISTLEBLOWING

In alignment with our commitment to upholding ethical standards, integrity and great business conduct, we actively encourage the reporting of any potential violation of the principles defined in this Code of Conduct, including any supplementing policies or procedures, and raising concerns regarding misconduct. The earlier a problem is discovered, the better chance we have to approach, prevent and repair the situation.

We provide appropriate channels, e.g. in our whistleblowing system, for such reporting, underscoring our dedication to maintaining integrity throughout such operations. Reports made in good faith will never imply any negative consequences for the person reporting.

We have established a Whistleblowing System where Employees can report serious misconduct anonymously in accordance with the Instabee Whistleblowing Policy, available on the Intranet. The Whistleblowing System ensures that Employees feel safe and supported when reporting. We are legally committed to protecting whistleblowers from retaliation or adverse consequences for making good faith reports.

7. VIOLATIONS OF THE CODE OF CONDUCT

We take violations of this Code of Conduct seriously, as they undermine our values, culture, and the trust placed in us by our stakeholders. When violations occur, we are committed to taking appropriate and fair disciplinary actions in accordance with the at the time applicable and shared procedure on disciplinary actions. The consequences for violations may vary depending on the nature and severity of the infraction, the Employee's disciplinary history, mitigating circumstances, any applicable laws or regulations, and more. Such consequences can include demotion, reprimands, suspension or termination of employment or engagement. We may also take legal action in cases of corruption, theft, fraud, or any other unlawful behaviour.

8. VALIDITY

 

This Code of Conduct has been adopted by the Board of Directors of Instabee Holding AB and in all subsidiaries in the Instabee Group, and shall remain valid, binding, and effective until further notice.
All Employees are required to sign or otherwise acknowledge their understanding and agreement to abide by this Code of Conduct.

We will keep this Code of Conduct under regular review and continuously update it when deemed necessary. The latest version of this Code of Conduct will always be available on the Intranet.

This Code of Conduct was approved by Instabee's Board of Directors and CEO on 2024-08-30