Code of Conduct

KVD Group is a group that encompasses subsidiaries (Kvdbil, Bilpriser and Forsbergs Fritidscenter), several business areas and many employees. It is therefore important that we have shared and fundamental values regarding how our businesses are conducted. Our ambition is that we not only live up to, but also exceed the expectations that our employees, customers, stakeholders and partners may have of us. Our commitment is to act with integrity in all situations, without compromise. KVD's core values — Considerate, Driven, Simple and Innovative — together with the Code of Conduct and other company policies, shall guide us in our everyday work. This Code of Conduct does not provide answers on how to behave in every situation, but shall help us make the right decisions in daily life — decisions that affect us all and that make both our workplace and the world around us a little better. That is how we take responsibility! KVD's Code of Conduct is based on the UN Global Compact's ten principles in the areas of human rights, labor rights, environment and anti-corruption. The principles in the Code of Conduct are also based on the UN Declaration of Human Rights, which in turn is based on the UN Declaration of Human Rights, the UN Sustainable Development Goals and the ILO's fundamental conventions on rights at work, the Rio Declaration and the UN Convention Against Corruption.

For whom does the Code of Conduct apply?

The Code of Conduct applies at all workplaces where we operate and to everyone working within the KVD Group — regardless of whether we are employees, interns, consultants, board members or part of group management.

Responsibilities and Roles

Board of Directors and CEO

The Board of Directors and CEO are responsible for ensuring that KVD has a current and fit-for-purpose Code of Conduct, and that there are working methods in place to communicate, implement and monitor compliance. They are also responsible for ensuring that the necessary resources and roles are in place to manage risks, deviations and reported suspicions of misconduct.

Executive management & managers

Executive management, managers and leaders carry the culture and have a significant influence on day-to-day operations across our businesses. As a manager, leader or employee with leadership responsibility, you therefore have an extra-large responsibility to adhere to our Code of Conduct and to act as a role model for your employees.

You are expected to lead by example and are responsible for ensuring that information reaches the organization and for monitoring that the Code is observed as a natural part of operations.

Management and managers shall support and provide guidance to employees who feel uncertain about applying the Code of Conduct in their daily work.

Employees

All employees are responsible for complying with this Code of Conduct, acting professionally and seeking support when in doubt. If you discover or suspect violations, misconduct or behavior contrary to our values, you must report this through the regular reporting channels and/or the whistleblowing function.

Confirmation at onboarding

Our Code of Conduct is included in our onboarding process. New employees shall review the contents and confirm that they have done so with a digital signature. An annual digital training on the Code of Conduct is conducted for all employees.

Our workplaces

At KVD, we take a holistic approach to health, equality and working conditions. We see it as our duty as an employer to give our employees the best possible conditions to perform to their full potential — both during the working day and through all stages of life.

We regard applicable legislation and collective agreements as the minimum baseline for our working conditions with regard to minimum age, working hours, lone working, rest, leave, compensation and benefits.

We shall also ensure that partners offering services such as subcontractors, hired staff, agency workers and interns comply with the Code of Conduct regarding terms of employment and working environment requirements.

We believe that clear and supportive leadership is just as important as engaged and responsible employee conduct. This will be achieved through well-defined roles and work processes, ensuring that you as an employee have the right competence and opportunity for skills development, and that your work performance is continuously monitored.

Good working conditions

KVD shall offer good working conditions and working arrangements for all employees, enabling them to feel secure in their employment, stay healthy and free from injury, achieve a healthy balance between work, family and leisure, and have good prospects of being able and willing to work all the way to retirement age.

All our legal entities with employed staff shall be covered by collective agreements.

Work environment & Health

KVD's workplaces shall be safe, injury-free and healthy. Employees and managers share a joint responsibility for one another and for our work environment.

We believe that systematic work environment management with a focus on health-promoting activities and new approaches to health helps us create a better workplace with healthy employees.

Our workplaces shall be drug-free and, through various activities and wellness initiatives, our employees shall be given the opportunity to maintain healthy lifestyle habits.

We are convinced that all work-related accidents and illnesses can be prevented. We always put safety first. We have a zero-vision for work-related accidents and are committed to providing a healthy and safe working environment for all our employees, including the necessary information and training.

If you as an employee observe a risk or risky behavior, you are expected to act by raising the alarm or directly stopping the hazardous work.

Equality & Diversity

KVD shall set an example from an equality and diversity perspective and, as a participant in the business community, we shall help address society's various challenges.

For us, this means that all employees shall receive equal treatment and equal opportunity for career development and advancement at work, regardless of gender, ethnic background, religion, sexual orientation, disability, functional variation or age.

Decisions relating to hiring, promotion, pay-setting, working conditions, disciplinary measures or termination of employment shall be based on an employee's ability or performance, not on irrelevant personal factors.

At KVD, every employee shall:

  • be given the opportunity to feel joy and security in their work.

  • feel accepted as individuals in the workplace and be treated with respect by all colleagues, customers and other partners.

  • have their salary determined based on factors that depend solely on market pay, the difficulty of the position and their own performance and competence.

  • experience that development opportunities within the company are equal for everyone.

  • be given the opportunity to exercise the right and responsibility to care for and raise their children.

  • have the opportunity to combine working life, career and family.

Zero tolerance of harassment & discrimination

At KVD, we do not accept any form of abusive treatment, harassment or sexual harassment in our workplaces.

For any such incidents, we have a preparedness and established action plan to counteract, prevent and resolve issues relating to all forms of abusive treatment.

As an employee, you are expected to treat all fellow human beings with respect and to act or raise the alarm in the event of any incidents, in order to counteract all forms of bullying, exclusion, hazing and differential treatment.

Freedom of Association

We respect our employees' freedom of association and applicable collective agreements. KVD's employees have the right to form or join trade unions and we respect our employees' and their trade unions' right to negotiate collective agreements and co-determination in working life.

Protection of Personal Data

At KVD, we handle personal data responsibly and comply with all applicable legislation regarding personal data when collecting and sharing such data. This applies to personal data relating to employees, job applicants, consultants, interns and others, as well as our customers' personal data.

Information & Communication

At KVD, we share information and believe in transparent and open communication, but keep confidential information private at all times.

As an employee at KVD, you may not disseminate or misuse confidential information. Examples of confidential information include non-public information about KVD's operations, results, strategies, business transactions, business plans, business processes, etc.

The commitment to maintaining confidential information also applies after an employment or consultancy assignment has ended.

Licenses & IT Systems

Only approved systems and software may be used on company IT equipment. Only computers, phones and tablets approved and configured by the IT department are approved for use at work and/or on KVD's network. Within the Group, AI tools may be used as a support in work. AI may only be used in accordance with KVD's AI policy and with approved tools/configurations.

If users require additional software or equipment, this must be approved by the IT department. The purpose is to ensure that applicable licensing models are followed and that equipment meets the company's security requirements with regard to virus protection.

Respect and care of KVD's property

KVD has both physical assets (facilities, equipment, work tools, etc.) and intellectual property (computer systems and programs, concepts, trade secrets, trademarks, etc.) that our employees or other contractors have access to during employment. KVD's assets may only be used for legitimate business purposes and not for personal or others' gain.

As an employee at KVD, you have a duty during the period of use to protect KVD's property and assets against damage, theft and misuse. Upon termination of employment, all physical property and assets belonging to KVD must be returned.

Respect and care of our clients' property

KVD also handles property owned by our clients. This places significant demands on the respectful and careful handling of our clients' property.

We take responsibility

KVD works actively for a sustainable society and therefore needs employees who take responsibility. Through large and small efforts and wise choices, we shall do what we can to drive the transition to a sustainable society and minimize the negative environmental and carbon impact of our operations. By systematically identifying, assessing and managing risks and material impacts linked to the environment as well as social responsibility and corporate governance (ESG), KVD integrates sustainability and compliance issues into decisions, processes and follow-up. We assess and prioritize risks based on the impact, likelihood and consequence for the business and value chain.

Sustainable offices & workplaces

In our workplaces, we take responsibility for a safe and secure working environment. This means that we work proactively on work environment risks, encourage a good safety culture and expect employees to report incidents, risk observations and work environment deviations in accordance with our procedures.

There shall be opportunities for source separation and we shall make it easy to recycle by placing waste stations for recyclable waste throughout our premises. We strive for reduced consumption of paper and other office supplies.

We use energy responsibly by, where possible, installing motion sensors for lighting and using LED lights. Our employees receive instructions that all electronics must be switched off when not in use.

Business travel

In our business travel policy, we advocate the most environmentally friendly travel option in order to reduce the burden on the environment.

In the first instance, the possibility of holding a meeting remotely (via web or telephone) shall be considered before a decision is made about a business trip. In the second instance, we shall choose the mode of transport that causes the least possible environmental impact.

When choosing a company car, vehicle models that meet the current requirements for climate bonus incentives shall be permitted where possible.

Own transportation

Transportation accounts for a very large share of the Group's total climate impact. We work actively to package services for customers in a way that provides greater control. This progressively improves our ability to influence the choice of vehicles, load capacity, working conditions and route optimization together with our transport partners.

Car washing & reconditioning

When selecting partners for car washing and reconditioning at our facilities, we shall consider environmentally friendly alternatives and ensure water conservation and more environmentally friendly chemicals or correct handling of hazardous waste. We shall also take into account the work environment and safety in these activities, both in our own operations and at partner sites, for example in the handling of chemicals and the use of safety equipment.

Requirements for Suppliers & Partners

Employees who are responsible for purchasing and selecting suppliers shall place demands on suppliers' products and work in the areas of sustainability and business ethics. This includes, among other things, environmental and climate impact (e.g. transport, emissions, waste and chemicals), but also social aspects such as working conditions, work environment, human rights and zero tolerance of corruption.

We work on a risk-based basis and follow up on requirements as needed, for example in connection with procurement, contract renewal or identified deviations.

Employees who take responsibility

KVD works actively at every level of our operations to minimize environmental impact. We therefore continuously work on information and training, for both staff and customers. We view positively employees putting forward environment-related improvement suggestions in daily operations.

As an employee at KVD, you are expected to act if you discover behavior, a risk or a deviation that could affect the environment, work environment, safety or trust in our operations, for example in the event of an oil spill, deficiencies in safety routines, harassment or misconduct. You are expected to report deviations in accordance with our procedures and — where relevant — via the whistleblowing function.

We conduct business with good business ethics

All employees and representatives of the KVD Group are expected to act with good business ethics when conducting business with customers, suppliers and other business partners. We comply with the Code of Conduct and applicable legislation when conducting our business.

Each of us is expected to have a basic knowledge of the laws and regulations that apply to the operations we conduct and the tasks we perform. Below is an overview of some of the ethical requirements that apply to us when conducting business in our operations.

Selection of External Partners

When selecting external partners — such as suppliers, distributors, consultants and other types of business partners — we shall assess their ability to live up to the principles of our Code of Conduct.

Everyone we work with shall be able to meet the same standards to which we ourselves are committed with regard to human rights, working conditions, business ethics and the environment. Suppliers who are part of our value chain shall also sign our Supplier Code of Conduct and, where necessary, we can carry out audits together with them to ensure that our requirements are being met.

If our partners deviate from our standards, we shall use our influence to change their behavior or discontinue the cooperation. In this way, we can minimize the risk of doing business with companies or individuals that are subject to sanctions, of facilitating corruption or money laundering, of financing terrorism or financial crime, or of being associated with serious negative impacts on human rights, working conditions or the environment.

Conflict of Interest

A conflict of interest arises when an employee's private interests in any way collide or appear to collide with KVD's interests. The existence of a real or potential conflict of interest does not necessarily constitute a violation of the Code of Conduct, but all employees have a responsibility to inform and consult their immediate manager or HR in the event of potential conflicts of interest and bias situations.

It is not possible to list every situation in which conflicts of interest may arise, but the list below provides guidance on how to avoid potential situations.

Conflicts of interest include:

  • Employment, other side activities or secondary occupations that compete with the KVD Group's business, that affect work, that could damage KVD's reputation or that place you in a situation where your independence is compromised.

  • Use of insider information or other confidential information for personal gain.

  • Where you, a close friend or family member has a financial interest in a company or business that does business with or could otherwise affect KVD's operations.

  • Handling of business matters, cases or issues involving relatives, close relationships or where you could be perceived as acting in your own or a related party's interest.

  • Hiring close relatives and others with whom you have a close personal relationship, direct line management over or direct reporting of a related party, unless the situation has been reviewed and approved in advance by the HR department.

  • Exploiting information or business opportunities discovered during working hours, or using KVD's property, information or position for personal gain.

  • KVD does not take political positions and therefore we do not use Group funds to support political campaigns or other political causes.

Accounting & financial reporting

KVD shall maintain accurate accounting that complies with applicable laws, regulations, accounting standards and norms.

Financial information and other price-sensitive information shall be communicated in accordance with applicable law, stock exchange rules (including listing agreements) and other regulations.

Fraud

KVD does not accept fraud in any form. Fraud includes employees or other persons misleading (deceiving) or attempting to mislead the company, or abusing the company's trust through actions that result in personal financial gain.

Corruption

KVD has zero tolerance for all forms of corruption and shall work actively to ensure that it does not occur within the Group.

The term corruption refers to the abuse of a position of trust for personal or corporate gain, for example through the use of bribes. It is prohibited both to offer, promise or give, and to request, accept a promise of or receive a bribe. A bribe is a gift or other benefit that can influence another person to improperly favor the giver within the scope of their employment or assignment.

We comply with applicable bribery legislation and the Swedish code on gifts, rewards and other benefits in business. No form of extortion, bribery or payments that could influence decisions is accepted.

As an employee at KVD, you may not, for example, offer, give, receive or request gifts, services, entertainment or other benefits that:

  • are contrary to general business practice or applicable legislation.

  • are of unreasonable value and consist of money, securities, monetary loans, other forms of personal payments in the form of discounts, commissions, bonuses or fees.

  • consist of purely recreational or holiday trips or excessive business entertainment.

  • are offered to partners in connection with an imminent or ongoing procurement or business decision.

  • due to their value or other relevant circumstances, risk unduly influencing the recipient in the exercise of their professional duties, or that otherwise risk causing embarrassment to the company or the employee if made public.

This does not, however, prevent employees of the KVD Group from receiving or offering benefits with the aim of maintaining and promoting good business relationships with customers and other partners. The prerequisite is that such benefits are modest, accepted and offered openly, and are otherwise in accordance with this Code of Conduct and the Swedish code on gifts, rewards and other benefits in business.

Money laundering and financial crime

KVD has zero tolerance for money laundering. We work on a risk-based basis with procedures and controls to prevent and detect money laundering, and we expect employees to follow the procedures and report suspected deviations.

We never accept cash payments. If a need arises for KVD to make a refund to a buyer, such refund is always made to the account from which the original payment was made. KVD can therefore never serve as a channel through which cash changes hands without a sale of an item having taken place.

Information, PR & Advertising

KVD's information activities and contacts with the media and journalists shall increase knowledge of and trust in our operations. We provide factual and clear information and adapt our communication to the target audience and the situation. We are always professional, prepared and well-versed in the subject.

We support and strive for fair competition

Employees of the KVD Group shall comply with all relevant competition rules and refrain from entering into unlawful competition-restricting agreements and from exchanging unlawful price and/or market information with competitors.

We comply with applicable export control regulations

KVD shall comply with all applicable export control regulations, including not trading in violation of, or with persons designated under, economic sanctions. KVD shall furthermore not trade in or export sensitive goods without the required export licenses.

We respect Human Rights

KVD is committed to respecting and promoting international human rights. Our commitment extends across the entire value chain.

If we cause, contribute to or are otherwise associated with serious violations of human rights, we shall take action. Forced labor, involuntary labor or child labor in any part of KVD's value chain is never accepted.

Active stance against purchasing sexual services and child pornography

Purchasing sexual services, sexual exploitation of children and child pornography are illegal under the legislation of most countries, including Sweden, and can support human trafficking, which is a violation of human rights.

Employees of the KVD Group on assignments and business trips are expected to respect KVD's position on this matter. This applies regardless of country and both during and after working hours.

We speak up

At KVD, it is important that everyone who represents the company acts in accordance with our values and follows the Code of Conduct, as well as applicable laws, guidelines and policies. If you as an employee notice something that does not seem right or that violates the Code of Conduct, we want you to speak up!

Employees and managers are expected to act when there is a suspicion of something that violates the Code of Conduct, company policies or other legislation. KVD provides several ways to report suspicions of violations.

In many cases, early reporting can help quickly resolve a problem and prevent or minimize harm.

How do you raise a concern?

As an employee, you have several ways to report misconduct:

  • Notify your manager, your manager's manager, the HR department or the trade union representatives of the organization.

  • Submit information anonymously through employee surveys conducted three times a year.

  • Use our whistleblowing tool, which is accessible both internally and externally, where employees and others can anonymously and in encrypted form report suspected misconduct. Our whistleblowing tool is hosted by an external party and is independent of our IT systems.

Reports can be made anonymously

Your report can be made anonymously. However, we recommend that you identify yourself if you are reporting a misconduct or a problem, as this would make it easier for KVD to gather all the facts, investigate your report and conduct a confidential dialogue with you.

What happens with my report?

Once you have made a report, KVD will investigate the situation and take appropriate action. All reports shall be taken seriously and will be investigated.

An honest report will never have negative consequences for the person making it. No form of retaliation against an employee who in good faith has reported a violation or suspected violation of the Code of Conduct shall occur. This applies regardless of the outcome of the investigation.

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