About our Code of conduct

About our Code of Conduct

Soltech’s operation is run in a responsible way, and this is vital for the Group’s long-term success. Through our business of providing sustainable solar energy solutions, we at Soltech have a great responsibility both towards ourselves as a Group and to the society we operate in. We aim to generate added value for customers, colleagues, suppliers and shareholders, at the same time as we contribute to sustainable societal development. We care about sound commercial ethics and we aim to achieve long-term, trustful relationships. We set ethical standards for our business operations and act in a financially, environmentally and socially responsible way. Accordingly, we have a Code of Conduct, which clearly states that our actions are required to be both legal and ethical.

The Code of Conduct is based on the ten principles of the UN’s Global Compact, the OECD’s guidelines for multinational companies and the UN’s guiding principles for companies in human rights. The headings in the Code of Conduct are based on the four domains set out in the UN’s Global Compact (human rights, labour, the environment and anticorruption). As a member of Svensk solenergi, the trade association for solar energy in Sweden, we have also undertaken to comply with their Code of Conduct. Soltech’s Code of Conduct aligns with this, and specifies, in addition, how we act and operate as well as how we handle the reporting of suspected irregularities.

The Code of Conduct sets out the principles for interactions and the standards we set for staff and business partners. The Code of Conduct applies to all of Soltech’s employees, in all our companies and in every country in which Soltech operates and regulates how our employees act towards each other and towards our customers, suppliers, partners and others whom our employees meet in day-to-day business.

Our employees have an obligation to comply with our Code of Conduct, and with applicable laws, ordinances and other policies. Each individual employee also has a responsibility to report. The Group uses a whistleblower function to report behaviour which is not consistent with the Code of Conduct.

Relationships with others 

The Soltech Group requires that subcontractors, suppliers and partners comply with this Code of Conduct. In choosing subcontractors, suppliers and partners, a willingness to live up to the standards in the Code of Conduct is one of the selection criterias. In the event that the Code of Conduct is not in line with the laws and rules which apply to a particular partner, the relevant company in the Soltech Group must be informed of this.

Subcontractors, suppliers and partners must note any breach of this Code of Conduct and take appropriate action. The Soltech Group company involved will take appropriate action depending on the scope of the actual breach of the Code of Conduct.

Subcontractors, suppliers and partners who breach this Code of Conduct, risk having the collaboration cancelled or existing business contracts terminated.

The Soltech Group company involved has the right to carry out due diligence by regularly and systematically identifying and evaluating risks and consequences related to Human Rights, Employment Conditions, the Environment and Anticorruption in their supply chain with the aim of ensuring that their purchases are made in a responsible manner. This includes the right, with their own staff, or through hired third parties, to carry out audits and evaluations of that part of the supplier’s work which is relevant, including its facilities. In these cases, the Parties involved shall enter into Confidentiality Agreements regarding the circumstances described in the audit and evaluation.

Subcontractors, suppliers and partners are expected to report any suspected irregularities detected within the Soltech Group’s operations to the Business Manager or via Soltech’s whistleblower function for employees.

To comply with the Code of Conduct, subcontractors, suppliers and partners are expected to treat all information, work documents and systems provided through the collaboration with the Soltech Group as strictly confidential.

How we treat each other

A good relationship is based on trust. We treat each other in accordance with the following basic principles:

• Everyone must be able to listen

• No matter who is in the vicinity of a conversation, that person must be able to listen with ease.

• We speak to each other with respect and talk about situations and people in a respectful manner.

• Everyone must be heard

• We respect each other and give space to listen to each other’s opinions, ideas and views. This enables us to ensure that we constantly challenge and develop ourselves and our operation.

• We take responsibility

• We practice what we say, and take responsibility for each other and for our operation. We are reliable and do what we say we will do.

Human Rights

Internationally declared human rights are respected and there is no involvement in any violation of human rights.

Human Rights

No modern forms of slavery, such as forced labour, debt bondage and human trafficking, are accepted. Children’s rights to personal development and education are respected and supported. Child labour is not accepted.

In addition, we disassociate ourselves from any purchase of sexual services and other activities which may involve supporting human trafficking, no matter whether these take place during or outside working hours in connection with work-related travel. This refers to all involvement in trading and sexual services such as payment for sexual services or visits to porn clubs or strip clubs, no matter in which countries these occur or whether they are permitted or prohibited in that country.

The equal value of all people

The equal value of all people is self-evident. Initiatives to increase diversity, gender equality and equal opportunities in all parts of the operation are essential in all workplaces.

Everyone must have the same rights and opportunities, independent of gender, transgender identity or expression, ethnic background, religion or other belief, disability, sexual orientation or age.

No forms of victimisation, sexual harassment, bullying or discrimination are accepted. A zero-tolerance policy is applied.

Working conditions

Dignified and fair working conditions apply to all employees, as well as to subcontractors, suppliers and other contract parties in every country in which the operation is carried on. Safety in the workplace is an essential factor in dignified and fair working conditions. Legislation, conventions and guidelines on sustainability and ethics at the production and delivery stages are complied with. All forms of forced labour, child labour and discrimination in relation to employment and work are eliminated and prevented. “Child” refers to a person under 15 years old unless legislation specifies a higher minimum age. Employees under 18 years old must be specially protected against hazardous tasks which involve a risk to health and safety, such as night work.

Working conditions

Good working conditions are safeguarded, and applicable legislation, regulations and collective agreements are complied with. Every employee will receive a clear job description setting out his/her tasks, responsibilities and authorisations. The right of freedom of association for employees is protected, and no restrictions on this are accepted.

Work environment

Every effort is made to generate a feeling of well-being and belonging among all employees. A democratic approach is taken on issues involving employees’ ability to exert influence, and respect is guaranteed for differing opinions.

The work environment meets statutory requirements and complies with agreements, and is safe and healthy from physical, psychological and social perspectives. Systematic and preventive efforts are made to ensure the constant improvement of the work environment and health. All employees shall have access to, and shall use, appropriate protective equipment. Alcohol and drugs must not be used during work. Smoking is permitted only in designated locations and in accordance with workplace guidelines.

The environment and quality

Respect for the environment

We are committed to the environment and sustainable development. The relevant environmental legislation is complied with, and we take a proactive approach to reducing a negative environmental impact on an ongoing basis.

We promote sustainability in the industry. Our vision is that solar energy technology will be manufactured, installed, used and recycled with as little impact on the environment and surroundings as possible, and that the industry will make an effective contribution to achieving national and international environmental and climate goals.


High quality standards are enforced. Products and systems which are manufactured, sold or used shall be inspected and labelled in accordance with current legislation and other regulations. Quality is a clear objective, and deliveries of services and work will reflect a high level of safety, know-how and professionalism.


Compliance with legislation and respect for custom and practice

All relevant laws and regulations are respected in every country in which our operation is carried on. Ethical guidelines are observed, and the operation is run in a financially, environmentally and socially responsible way. Local culture, social structures, customs and practices are respected in the countries in which we operate, provided that this does not involve any breach of legislation or of this Code of Conduct.

Measures against corruption and bribery

There is zero tolerance of bribery and corruption. Bribery means offering, giving, receiving or requesting something of value in return for influencing a public sector or private company in the exercise of its operation. Corruption means the misuse of power for personal gain. This includes conflicts of interest, embezzlement, kickbacks, extortion and nepotism.

• The business is run with a high level of integrity in which bribery or corruption are not permitted.
• Bribes are not paid out and payment of bribes is not offered, either directly or through a third party.
• Gifts which improperly influence our own partners’ business decisions are not offered, nor are they accepted.
• Legislation on money laundering, including reporting obligations, are fully complied with.

Payments, accounting and records

Outgoing payments are made only against a specified invoice which is attested by an authorised manager or employee. Payments are made only for services actually carried out or goods delivered, and only to parties with which there is a current and correct business relationship.

Customers receive specified invoices and documentation. All invoices are based on services actually carried out or goods delivered.

Detailed accounting and records of all income and expenditure is kept, and generally accepted accounting standards in accordance with relevant legislation are observed.

Healthy competition

Applicable competition laws are complied with. We compete fairly in all markets in which the operation is carried out since competition is an essential driving force for innovation and efficiency. Information on trade secrets shall not be acquired or sought after in an unjustified way, nor shall such information be used in an unjustified way.

General complaint cases and court judgements

All assignments are carried out in a professional manner. Any rulings from ARN (Allmänna Reklamationsnämnden – The Swedish National Board for Consumer Disputes) or a court are complied with.

Whistleblower Policy


Whistleblowing involves bringing attention to misconduct, and the concept has come to be used both for sounding an alarm to the media and for highlighting misconduct internally.

Soltech Energy Sweden AB (Soltech) has a whistleblower system in place, in which employees can notify the organisation anonymously of misconduct within the Group. The whistleblowing system is located with an external party to make it impossible to search for the identity of the informant and to have an objective perspective. There is information on the Group intranet and the external webpages. It is not possible to identify the person behind a notification and, accordingly, it is not possible to verify whether the person is employed at Soltech in the reporting process. All reported cases will be examined and handled.

Soltech’s Whistleblower Policy was approved by Soltech Energy Sweden AB’s management. The Whistleblowing Policy applies to the Parent and all Group companies. The CEO of the respective subsidiaries are responsible for communicating the policy and making it available to all employees within their subsidiary.


The system makes it clear that it is the responsibility of everyone jointly to bring attention to problems and areas in which we as an organisation, our employees, are not complying with current laws, or are not fully following our guidelines. The system will also act as a reminder of the organisation’s responsibility to clarify the rules which apply and what is expected of all employees. Overall, the whistleblower system will strengthen a culture in which problems are addressed and discussed even before a misconduct appears.

Our sincere hope is that every employee will feel that there is sufficient space to hold dialogues about problems openly. But the ability to leave tipoffs anonymously is one way of showing that no one need to be afraid of the consequences of pointing out misconduct.

The whistleblower function is, accordingly, a complement, and should not be seen as a substitute for a climate of open discussion. We want employees to approach their immediate manager or another person in the management structure whom they trust if a misconduct is noted or if you want to discuss something out of the ordinary.

Soltech applies a total prohibition of reprisals. This means that we have zero tolerance of actions intended to punish someone who has pointed out misconduct – actual or perceived – as long as their action was taken in good faith. Deliberate mudslinging or spreading of rumours, however, are not tolerated.
The channel is intended for serious violations, such as a breach of Swedish or EU legislation, as well as matters which could be regarded as in the public interest that they are brought to light. It is these matters which will be dealt with using the process defined in the whistleblower system. Other matters will be referred on to the Soltech “trust group” (described below)

Internal communication

Soltech is committed to open communication and recommends communication with the employee’s immediate manager. If an employee does not feel comfortable communicating with his/her manager, he/she can report to individuals in Soltech’s overall ”trust group” which consists of the Head of HR (coordinator), the CEO, the COO and the Head of Communications of Soltech Energy Sweden AB. The trust group has its own email address. Contact information and the email address of the trust group are posted on the intranet.

Soltech’s overall trust group is responsible for monitoring compliance with the Code of Conduct and following up cases via external parties. It handles matters which do not meet the criteria for whistleblower cases and constitutes the communication group for whistleblower cases which are referred for legal investigation.

About the system

For the system to be trustworthy, transparency and clarity on how we protect the user’s privacy are essential. It is also essential to assist the informant in providing the best possible information. Aspects to which Soltech attaches particular importance include

• Independent handling of cases. Cases which are judged to meet the criteria for whistleblower cases are investigated by an independent external lawyer
•Information for users. Informants must know how they are protected technically, and what they must themselves bear in mind to avoid providing too much information. This may involve user data in annexes, risks in reporting from the workplace network or the risk of revealing their own identity through the way in which they express themselves
• Data storage. We have selected a supplier with its own dedicated servers, located in Sweden. Once cases are dealt with, they are erased from the system so that information is not stored for longer than necessary
• Information management. No sensitive information is to be sent by email at any time, and there is a requirement for personal login to access and work on any case information
• Report quality. Clear questionnaires help the informant provide full information to make it possible to investigate the matter in an effective way. In addition, there is the opportunity to correspond anonymously with the informant
• Accessibility. Adapting the report page for mobile communication is a natural move, since communication is increasingly taking place on mobile units. An additional point here is that mobile units are often outside the workplace network and, accordingly, provide an excellent alternative to work computers from a privacy perspective. The option of submitting information by phone is also offered.

About the process

Cases are handled by a specially appointed independent lawyer. Investigation and any recommendation for action or further processing will be presented to Soltech’s trust group as well as to the Group Management Team by the coordinator in the trust group.

Cases which fall outside the purpose of the system are written off as whistleblower cases, but are referred on to the Soltech Group’s internal trust group for possible further consideration.

Individuals who are named in a case are informed of the ongoing investigation as soon as possible with respect to the investigation work. The name of the person who submitted the report is not communicated, even should this be known by the investigator.

After the process is completed, the matter is erased from the database. If the matter requires further investigation, the necessary information is saved outside the database. The information is destroyed or anonymised as soon as the investigation permits.

If an informant chooses to be open about his/her identity, that identity will still be made available exclusively to the group appointed to investigate the whistleblower case. The exception is if the case results in a criminal investigation, when the informant may be called as a witness.

Evaluations and improvements

To ensure that the whistleblower system remains fit for purpose, regular evaluations are carried out on how the channel is being used, whether the individuals involved are aware of the channel, whether the type of case is in line with the purpose of the system and whether the procedures surrounding the investigation function as intended.

Responsibility for the function
If you have any questions on the whistleblower function or the system, you are always welcome to contact the Head of HR at Soltech Energy Sweden AB