NIR Code of Conduct

Adopted by the Board of Directors on 19 March 2025

Table of Contents
The purpose of this Code

NIR improves the conditions for conducting economically, socially and environmentally sustainable business in complex markets. As a membership-based non-profit organisation, NIR represents some of Sweden’s largest exporting companies and the financial sector. As a nexus between aid and trade, NIR often partners with other Swedish stakeholders such as the Swedish International Development Cooperation Agency (Sida) and the Swedish Ministry for Foreign Affairs. Through these partnerships, NIR manages public funds which requires a heightened duty of care.

As NIR is uniquely positioned to represent its members and Swedish business values and principles in complex markets, we must always uphold the highest ethical and professional standards and act responsibly and sustainably. When representing NIR in partner countries, we contribute to building Sweden’s legacy. Therefore, the highest ethical and professional standards must be our hallmark.

The purpose of this Code of Conduct (hereinafter referred to as this ‘Code’) is to define those standards, clarify responsibilities and guide us in ensuring that we always conduct ourselves ethically and responsibly in carrying out our mission.

Who does this Code apply to?

This Code applies to all persons working on behalf of or representing NIR, including all employees, the Board of Directors when representing NIR *, consultants and other implementing partners. Our in-country partners (beneficiaries) should be made aware of this Code and understand how to respond if this Code is violated by persons working on behalf of or representing NIR.

The CEO of NIR is responsible for ensuring that this Code is fully communicated and properly implemented. All persons employed by NIR are individually responsible for understanding and complying with this Code. A lack of understanding of this Code is not an excusable reason for non-compliance.

Any violations of this Code, NIR’s policies or the law by a person working for or on behalf of NIR may result in NIR facing criminal and/or financial sanctions. It could also result in the individual facing criminal prosecution and/or disciplinary action, including termination if warranted, in accordance with the applicable regulations and laws. Further, violations of this Code, NIR’s policies or the law could result in reputational damage. Upholding this Code therefore protects the reputation of NIR and its members. NIR reserves the right to review and terminate its relationship(s) with any partners who violate this Code and to take legal action, if deemed necessary.

Each person who this Code applies to has a duty to speak up and respond to a suspected or known incident which violates this Code, NIR’s policies and guidelines and/or the law. See the section below, ‘Speaking Up and Responding,’ for how to do so.

As NIR is uniquely positioned to represent its members and Swedish business values and principles in complex markets, we must always uphold the highest ethical and professional standards and act responsibly and sustainably. When representing NIR in partner countries, we contribute to building Sweden’s legacy. Therefore, the highest ethical and professional standards must be our hallmark.

The purpose of this Code of Conduct (hereinafter referred to as this ‘Code’) is to define those standards, clarify responsibilities and guide us in ensuring that we always conduct ourselves ethically and responsibly in carrying out our mission.

* NIR acknowledges that members of the Board of Directors are required to adhere to their respective organisational Code of Conduct. In cases of an inconsistency between this Code and a member’s organisational Code, NIR acknowledges that the highest standard applies.

Acting ethically and professionally

We have a duty to engage with others adhering to the highest ethical and professional standards. As NIR’s activities are largely based on interacting with partners, stakeholders and other third parties, it is imperative that we manage all professional relationships ethically and responsibly. This includes communicating honestly, openly and clearly, respecting the confidentiality of our members and projects and managing budgets and spending funds with the utmost integrity. This also means creating equal opportunities in our business relations and partnerships and protecting human rights.

Communicating and engaging with others to the highest ethical and professional standards means:

Definitions

Zero tolerance for bribery and corruption

NIR has zero tolerance for any form of bribery and corruption.

Corruption undermines NIR’s mission as it hinders economic and sustainable development, increases inequality, poverty and social division, weakens democracy, worsens the environmental crisis and erodes trust.
As a representative of Sweden and our members, we hold ourselves to the highest standards of transparency and fighting corruption and we have a duty and responsibility to support our in-country partners (beneficiaries) in combating corruption. This also includes avoiding any conflicts of interest and identifying and resolving any possible conflicts, which is vital to maintain trust.

A zero tolerance for bribery and corruption means:

Definitions

Corruption

Corruption is an abuse/misuse of trust, power or position for improper gain for a person, organization, private company or other. Corruption can take many forms and includes among others, bribery, kickbacks, illegal gratitudes, extortion, sextortion, facilitation payments, embezzlement, fraud, theft, favouritism and nepotism and conflicts of interest.

Bribery

A bribe or bribery is an indirect or direct offer to pay, a payment, a promise to pay or the authorisation of any form of payment for an improper purpose. An improper purpose includes the influencing of an act or decision of another or securing any improper advantage over another.

Nepotism

Nepotism is a form of favouritism based on acquaintances and familialrelationships whereby someone in an official position exploits his or her powerand authority to provide a job or favour to a family member or friend.

Conflict of Interest

A conflict of interest is any situation where the functions of a person acting onbehalf of the organisation is or could be compromised for personal reasons,involving family, personal life, political affiliation, economic interest or any other shared interest with another person.

GIFT

A gift of minimal value is anything under the value of 500 Swedish Krona. Gifts of minimal value may include, but are not limited to, small souvenirs or memorabilia, corporate merchandise such as pens and notepads and coffee or meals at meetings and conferences. This does not include other benefits, even if they are of low or no monetary value.

For further guidance, see The Swedish Anti-Corruption Institute’s Code to Prevent Corruption in Business (August 2020).

Staying safe and being secure

We have a duty to properly assess and mitigate security risks to stay safe and be secure, safeguarding ourselves, NIR as an organisation and our partners. An international presence is at the core of NIR’s mission, but this also brings significant security risks as we work and travel in complex environments and with partners from diverse backgrounds. Risks cannot always be avoided but should always be minimised to the greatest extent possible. Staying safe and being secure requires that we understand and mitigate personal safety risks, protect sensitive and confidential information and follow all IT security protocols.

Staying safe and being secure means:

Definitions

Personal Saftey

Personal safety risks include crime, health risks, natural disasters, transportation accidents, political instability, cultural misunderstandings and preparedness for emergency situations.

information security

Information security refers to preserving the confidentiality, integrity and availability of information. Information security risks are potential events or actions that could negatively impact the confidentiality, integrity, or availability of an organisation’s information. These risks can stem from various sources, including human errors, system failures, deliberate attacks or natural events.

IT Security

IT security involves implementing security measures to protect information within information systems. IT security risks include phishing and malicious software, inadequate password management, neglecting software updates, unsecured mobiledevices, poor handling of e-identification, lack of regular data backups and inadequate incident reporting.

Promoting environmentally responsible practices

Promoting environmentally sustainable business practices is a central pillar of NIR’s mission which means that making environmentally responsible choices in carrying out our operations is of the utmost importance. As an international organisation promoting Swedish sustainable business practices, we also support our in-country partners (beneficiaries) in making environmentally responsible choices and contributing to achieving the 2030 Agenda for Sustainable Development. We aim to promote the importance of environmental responsibility and sustainable business practices in all our programmes, activities and partnerships.

Promoting environmentally responsible practices means:

Contributing to diversity, equity and inclusion

NIR has zero tolerance for any form of discrimination.

All individuals in our workplace and operations shall be treated equally, fairly and with respect, regardless of age, sex, race, ethnicity, national or social origin, disability, medical conditions, pregnancy, marital status, sexual orientation, gender or gender expression and/or religion, belief or religious background.

We run operations across the globe in many different countries with varying cultures, norms and legislations. We therefore each play an important role in contributing to an organisation that upholds the values of diversity, equity and inclusion, which are key for us in delivering on NIR’s mission.

Contributing to a diversity, equity and inclusion means:

Definitions

Discrimination

Discrimination is the mistreatment of any person based on age, sex, race, ethnicity, national or social origin, disability, medical conditions, pregnancy, marital status, sexual orientation, gender or gender expression and/or religion, belief or religious background.

Equal Opportunity

An equal opportunity in our business relations and partnerships means never discriminating based on age, sex, race, ethnicity, national or social origin, disability, pregnancy, marital status, sexual orientation, gender or gender expression and/or religion, belief or religious background.

Zero tolerance for harassment, including sexual exploitation, abuse and harassment

NIR has zero tolerance for any form of harassment, including sexual exploitation, abuse and harassment.

We are committed to ensuring that our workplace and operations are free of any form of harassment, including sexual exploitation, abuse and harassment, or abuse of authority. Sexual exploitation, abuse and harassment are manifestations of power imbalances and abuse of power, and commonly associated with gender inequality. These types of manifestations of power imbalances go directly against our values and can result in supporting criminal activities, such as human trafficking. We prioritise the early detection of harassment, and prevention of harassment is all our shared responsibility.

A zero tolerance for harassment means:

Definitions

harassment

Harassment is unwanted behaviour which you find offensive, or which makes you feel intimidated or humiliated. It can happen on its own or alongside other forms of discrimination. Unwanted behaviour includes spoken or written words or abuse, offensive emails or comments on social media, images, physical gestures and jokes.

Sexual abuse

Sexual abuse is the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. All sexual activity with children (as defined under the UN Convention on the Rights of the Child as any person under the age of 18) is sexual abuse, regardless of the age of majority or consent locally.

Sexual exploitation

Sexual exploitation is any actual or attempted abuse by personnel (of a position of vulnerability, differential power or trust for sexual purposes, including profiting monetarily, socially or politically from the sexual exploitation of another). It is a broad term, but it includes transactional sex, solicitation of transactional sex and exploitative relationships.

Sexual harassment

Sexual harassment is any unwelcome conduct of a sexual nature that might reasonably be expected, or be perceived to cause offence or humiliation, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment. Sexual harassment may occur in the workplace or in connection with work. While typically involving a pattern ofconduct, sexual harassment may take the form of a single incident. In assessing the reasonableness of expectations or perceptions, the perspective of the person who is the target of the conduct shall be considered. Sexual harassment can take a variety offorms and may involve any conduct of a verbal, nonverbal or physical nature, including written and electronic communications.

Speaking up and responding

NIR’s mission, activities and partnerships are built on trust and accountability between all parties and responding and speaking up is vital to maintaining those core values. This means that any person who this Code applies to has a duty and responsibility to immediately respond and speak up in any instance where it is suspected or known that this Code or NIR’s policies have been breached and/or the law has been broken.

Reporting an incident

If as an employee you are aware of a suspected or known incident that violates this Code and/or NIR’s policies or breaks the law, you must immediately and formally report the incident in writing to your manager or any other manager you are more comfortable with, the head of Compliance or CEO. All managers have a duty to then immediately report the incident in writing to the head of Compliance or CEO. Alternatively, you may use the Whistleblower function. If you are unsure as to whether an incident constitutes a breach of this Code or NIR’s policies and/or is illegal, you may speak to your manager or the head of Compliance.

Any other person that this Code applies to must immediately report any such incident either in writing to the head of Compliance and/or CEO, or may use the Whistleblower function. The Whistleblower function may be used to report anonymously and is available for NIR employees, any person this Code applies to as well as any other person that would like to make a report in good faith. The Whistleblower function is available on NIR’s website at www.nir.se.

NIR has zero tolerance for hindering reporting and retaliation if the reporting person has done so in good faith with reasonable grounds to believe that the information reported was true at the time of reporting, or if they had serious suspicions that they observed an illegal activity.

The failure to report a suspected or known incident may result in disciplinary action for employees, including termination if warranted, and response measures of equal proportion for any other person that this Code applies to but has failed to report.

Managerial responsibilities

NIR employees in a managerial position play a vital in leading by example to ensure that this Code is implemented and followed. Management should encourage employees to speak up and report suspected or known violations and ensure that a trusting environment and the opportunity for speaking up and reporting exists. Ensuring that there are adequate resources and expertise to prevent corruption, and any violations of this Code is also the responsibility of management.

Management must clearly specify NIR’s position on ethical and professional behaviour, anti-corruption and harassment in employee trainings and in its internal and external communications. NIR’s CEO is responsible for keeping the Board of Directors regularly informed of NIR’s anti-corruption work and any other work in relation to this Code.

EXECUTIVE SUMMARY

This executive summary presents the findings from the study “Workplace Cooperation: Finding Practical Solutions in the Colombian Context,” conducted by the Fundación Ideas para la Paz (FIP). The study evaluates the added value of the Swedish Workplace Programme (SWP) dialogue and cooperation model within the Colombian labor market.

Throughout 2022, FIP dedicated efforts to thoroughly understand the SWP model, including its concept, foundations, implementation process, and contributions to the labor market. In 2023, FIP documented the experiences of three companies—SKF Latin Trade, Securitas, and Epiroc—that implemented the SWP model in practice. The study also included face-to-face workshops to gather feedback from various stakeholders including civil society, businesses, government, academia, and international cooperation. The findings suggest that the SWP model has the potential to strengthen labor relations, contribute to decent work, and resolve workplace conflicts in Colombia.

The case studies highlight the importance of collaboration between employers and workers to promote decent work and sustainable development in Colombia. They demonstrate that social dialogue facilitates worker participation in labor decision-making, enhances their representativeness, and promotes cooperation between employers and employees, thus improving labor relations and contributing to the well-being of both employees and companies.

The SWP model is particularly noted for improving workplace relationships and commitment to jointly finding solutions to challenges faced by workers and the company. It empowers workers, enhances leadership, and helps integrate business policies into daily practices, reducing the initial disconnect between management objectives and the day-to-day realities of workers. The study also highlights the model’s capacity to manage conflicts constructively, transforming the perception of conflict as an opportunity for improvement. Structured dialogues deepen understanding of the underlying causes of conflicts, fostering empathy and facilitating effective resolution. This promotes a culture of collaboration and a democratic approach to decision-making, building trust.

Additionally, the model is recognized for enabling workers to make decisions, identify challenges, and propose solutions that impact their well-being, and bridging gender gaps in the workplace. Its inclusive approach adapts to the unique needs and characteristics of each company, promoting a stronger and more diverse organizational culture. It also drives good work performance and productivity by involving workers in problem identification and resolution, as well as in implementing improvements and efficiently identifying ESG (Environmental, Social, and Governance) risks for companies.

The document identifies the SWP model’s added value in empowering direct interaction among labor stakeholders in Colombia, overcoming historical or cultural reservations, and contributing to the development of stronger labor relations and improved workplace environments in the country.

Challenges and opportunities of the model are also discussed. The study points out the importance of addressing value chain risks, particularly in a global context where corporate clients demand decent work processes and due diligence. It emphasizes the need to integrate SMEs into this process and use anchor companies as drivers of social dialogue throughout the value chain. The role of the state in social dialogue and the importance of highlighting the benefits of the model for adoption across various business sectors are discussed.

The opportunities of the model include raising awareness of human rights in the workplace in line with the United Nations Guiding Principles (UNGP), to strengthen due diligence, manage risks, promote long-term sustainability, and improve organizational culture. The document also underscores the importance of involving workers in change processes, leveraging their insights for continuous improvement of processes, and fostering innovation opportunities. Lastly, it suggests replicating the model in value chains to address work environment risks and gender biases, involving suppliers and contractors, and integrating the model into corporate policies to strengthen existing programs and transform organizational culture towards resource efficiency and effective participation of employers and workers.