Code of Conduct for Business Partners and Suppliers

Pareto Securities AS, including our branches and subsidiaries in Norway and abroad (“Pareto Securities”), is committed to conducting our business in a responsible, ethical and sustainable manner through strong governance, climate action and social impact.

We seek an open and transparent relationship with our suppliers, business partners and subcontractors (collectively the “Third Party”), and strive to ensure that our commitment within business integrity, human rights and climate action are reflected in our dealings with all stakeholders. The purpose of this Code of Conduct (“the Code”) is to set forth the basic standards that a Third Party wishing to do business with Pareto Securities is expected to follow. The Code is applicable to Third Party's employees at all levels, board members, hired personnel, consultants and others who act on behalf of or represent the Third Party.

Within the areas of Environmental (E), Social (S) and Governance (G), a Third party shall:

Conduct its services and business in line with the UN Guiding Principles on Business and Human Rights, the UN Global Compact, the UK Modern Slavery Act and when relevant the OECD Guidelines for Multinational Enterprises. As a result, a Third Party is expected to, in proportion to risk, fulfil the guiding principles below:

Environmental: 

• Support a precautionary approach to environmental challenges, undertake initiatives to promote greater environmental responsibilily, and encourage the development of environmentally friendly technologies.
• Endevour to reduce operational environmental impacts, including GHG emissions, responsible use of water, energy materials and waste management consumption.
• Comply with all obligations applicable to them in environmental matters and have appropriate procedures in place to ensure compliance.

 Social:

• Develop and carry out its business relationships in accordance with transparent principles of business ethics and management.
• Support and respect the protection of internationally proclaimed human rights and have relevant policies and processes to ensure that it neither is nor becomes complicit in any human rights abuses.
• In particular implement policies and procedures aimed at:
  • Elimination of trafficking, forced or compulsory labour and child labour
  • Freedom of association and right to collective bargaining
  • Elimination of discrimination in the workplace
  • Safe and healthy working conditions
  • Fair and competitive compensation and benefits
• Process personal data confidentially and responsibly, respects data privacy and ensures that personal data is effectively protected and used only for legitimate purposes.

Governance:

• Comply with, or exceed the requirements of all applicable laws, rules and regulations in the countries in which the Third Party operates.
• Avoid any conflict of interest with Pareto Securities, including interactions with a Pareto Securities representative that could result in a conflict of interest with the representative’s responsbilitiy to act in the best interest of Pareto Securities, and provide immediate notification to all affected parties if an actual conflict of interest arises.
• Ensure that no entity within the Third Party’s group of companies, its management or owners, being legal entities and/or person and subcontractors appear on any Watch and/or Sanctions lists issued by i.e. the UN, UK, EU and/or the US governmental bodies (collective Sanctions- and Watch lists).
• Have adequate policies and appropriate procedures to prevent corruption, bribery and extortion, as well as strict standards of ethical and moral conduct, and international conventions in place for this purpose.
• Not tolerate any form of and do not engage directly or indirectly in any form of corruption or bribery, and not grant, offer or promise any gifts, gratuities or other benefits to any Pareto Securities employee, government official or other counterparty in the private sector which may influence decisions, result in improper advantage or may be conceived as a bribe or facilitation payment, and not accept or receive any such gifts, gratuities or benefits.
• Not directly or indirectly facilitate money laundering or terrorism financing.

The Third Party shall notify Pareto Securities of any known or suspected breaches immediately, as well as provide any relevant information upon the request of Pareto Securities, including information on subcontractors and supply chain risk.

In cases of violation of this Code, the Third Party shall take the necessary corrective actions in a timely manner at no cost of Pareto Securities. This may include a requirement to change subcontractors that do not comply with the requirements of the Code, and/or a requirement to carry out necessary audits at own or subcontractors' premises.

The Third Party shall use its best efforts and influence towards ensuring that subcontractors comply with the requirements and standards herein, including having in place policies and contractual obligations in this regard as relevant.

Ensuring the principles of responsible and sustainable development in our supply chain and within our business partners is important to us. Third parties may be required to acknowledge their commitment to the standards set out in this Code or demonstrate their commitment and compliance to these same by providing copies of their own code of conduct or company policies that embrace these standards.

Lack of cooperation with this Code is viewed as a serious matter, which may lead to termination of the agreement(s) with the Third Party, claims for appropriate compensation, disqualification as a supplier, and reporting to relevant authorities.