Human Rights policy

This human rights policy (the “Policy”) applies to all employees and officers of Pareto Securities AS, including our branches and subsidiaries in Norway and abroad (“Pareto Securities”).

To maintain trust and meet the expectations of our stakeholders and to contribute to society and the well-being of employees, we aim to carry out all our business activities in such a manner that does not negatively affect fundamental human rights and decent working conditions as referred to in the Norwegian Transparency Act  (hereinafter collectively referred to as “Human Rights”). We acknowledge and wish to promote these Human Rights, which include but are not limited to: 

• the International Bill of Human Rights, which covers;
  • the Universal Declaration of Human rights 
  • the UN International Covenant on economical, social and culture rights from 1966, and
  • the UN Covenant on Civil and Political Rights
• ILO’s Declaration of Fundamental Principles and Right at Work

The Policy describes Pareto Securities’ approach to managing Human Rights risks in our business operations and compliments our Ethical Principles, Anti-corruption policy, as well as our Diversity and Inclusion policy. 

The objective of this Policy (without reducing the importance of the other policies mentioned in the above) is to;

• Describe our Human Rights commitment and how we work to avoid infringements of Human Rights to employees, suppliers, customers, business partners and stakeholders 
• Clarify our expectations on the importance of conducting business consistent with the principles described in this Policy, and 
• Improve our awareness of our continuous efforts to reduce risks for Human Rights infringements

We are committed to respecting internationally recognised Human Rights, and to this effect support the guiding document “UN Guiding Principles on Business and Human Rights”. In particular, we emphasise the following core principles:

• Everyone who works for and with Pareto Securities shall be treated with respect, fairness, and dignity
• Pareto Securities shall provide a safe, healthy, and secure working environment, free of any form of discrimination based on gender, ethnicity, nationality, sexual orientation, age or political beliefs or any other class
• Any employee or officer of Pareto Securities shall respect the freedom of association and right to collective bargaining
• Pareto Securities shall oppose all forms of child labour, human trafficking, modern slavery, compulsory or forced labour
• We shall respect employees’ rights to freedom of opinion and expression, freedom of thought and religion
• We shall provide fair working conditions to our and their employees in accordance with applicable legislation
• We will pay special attention to the rights, requirements, values and integrity of individuals and groups which may be particularly vulnerable to adverse impacts
• We will respect individual privacy rights and are committed to protecting personal information in compliance with applicable laws
• We should be committed to continuously improve our efforts to eliminate Human Rights violations

We expect anyone doing business with Pareto Securities, including our business partners, suppliers, and subcontractors, to share our commitment to respect Human Rights and the abovementioned core principles.

We expect all our employees and officers to adhere to this Policy.

We expect our employees and officers, suppliers, and business partners to never infringe on Human Rights and report to relevant authorities any situation in which Human Rights infringement is suspected.

In line with the expectations that follow from the Norwegian Transparency Act and the anticipated EU Directive on Corporate Sustainability Due Diligence, we will continuously assess whether our business activities may lead to a negative impact on Human Rights by conducting relevant due diligence and propose necessary preventive risk mitigating actions if needed. Furthermore, in order to identify the need for mitigating actions towards third parties, we will continuously conduct risk assessments of our suppliers and business partners to assess whether there is any risk of Human Rights being negatively affected by our contracts with such suppliers or business partners. This will in turn enhance our ability to uncover future human rights risks in our different business areas and be able to mitigate this. The internal procedures in further described in the Instruction in relation to the Norwegian Transparency Act, adopted by the board of Pareto Securities AS. 

Sourcing and procurement processes in Pareto Securities are based on the principles set out in our Guidelines for procurement. Among other things, the principles reflect that good sustainability standards and Human Rights shall be emphasised when choosing suppliers.  
Our Ethical Principles are a part of Pareto Securities’ governing documents and set the framework for what we consider responsible business conduct and describe how we aspire to work. All employees shall sign the Ethical Principles, and employees must know our internal rules, guidelines, and routines, as well as the laws and regulations that set limits for our business.

Pareto Securities is firmly opposed to corruption in all forms, including bribery and trading in influence. We do not allow anyone involved in our business to offer, give, ask for, accept or receive any form of bribe, including facilitation payments. Our zero tolerance for corruption is reflected in our Anti-corruption Policy.

Pareto Securities is subject to applicable anti-money laundering and terrorism financing legislation in the respective jurisdiction and is committed to combating economic crime, including money laundering, terrorist financing, fraud, work-related crime and corruption. We have established an extensive framework of guidelines intended to prevent us from being exploited for money laundering, tax evasion or terrorist financing. 

Privacy is a human right, as described in the European Convention on Human Rights. The European privacy legislation is unified in the General Data Protection Regulation (GDPR) and ensures that the handling of personal data is similar across borders in all countries in the EU. The law aims to protect and defend every person’s right to privacy. Pareto Securities has established a quality management system for information security and privacy. Our Global Privacy Policy provides details of our approach to data privacy. 

Our compliance framework forms the basis for all our decisions and is key to the integrity of our business. For our investment banking activities, the quality of deal selection and execution work is ensured through teamwork under experienced Deal Captains and established capital raising project procedures, including a thorough assessment of potential new assignments in the internal “Deal Committee”. The Deal Committee evaluates several aspects of potential investment banking assignment, for instance, risks connected with the sector and jurisdiction in which the potential client operates and other more company-specific matters. Another example of topics addressed by the Deal Committee is conflicts of interest. In accordance with regulatory expectations, the organisation and manner in which activities of Pareto Securities are conducted shall at all times be organised in such a way that the risk of negative consequences of conflicts of interest between Pareto Securities and our clients, as well as between the clients of Pareto Securities, are to be minimised and/or otherwise handled in accordance with our Conflict of Interest Policy. 

As part of the Investment Banking department’s efforts to strengthen corporate responsibility, we ask our clients to confirm that they respect and comply with Human Rights through our standard terms. Where assignments involve capital raisings, our issuing clients are furthermore closer to the launch of such transactions, typically asked to provide certain confirmations to us in a separate document which also includes confirmations on the respect for fundamental human rights and decent working conditions. 

Our Diversity & Inclusion Policy reflects our commitment to the principles of non-discrimination and equality in opportunity. We have zero tolerance for discrimination and harassment. The remuneration policies are approved and overseen by the boards of the Pareto Securities entities and receive direct input from control departments, such as Compliance and Risk Management. We have established Working Environment Committees. Considerations of equality and non-discrimination are otherwise included in the personnel policies.

The employees and officers of Pareto Securities may raise concerns regarding impacts on Human Rights through our whistleblowing procedures. We also welcome our business partners to notify us should they discover any circumstance that may potentially lead to negative effects on Human Rights. More information on our whistleblowing system can be found in our annual Sustainability report on our website.