Code of conduct

Objective

The objective of this Code of Conduct is to state the requirements for business practice and personal conduct within Skau Reipurth & Partnere (“SR&P”).

Our values and the purpose of the Code of Conduct

Furthermore, SR&P considers corruption as incompatible with its vision of providing legal advice on the highest possible level and being a law firm every employee is proud to work for.

SR&P recognizes that corruption and other unethical practices undermine the support and confidence of its business environment (customers, donors, suppliers, agents, consultants and all other business relations), which is key to its business.

In support of these principles, SR&P has developed this Code of Conduct for countering corruption, bribery and other unethical behavior. The Code of Conduct provides the framework for SR&P’s behavior and will be supported by more detailed policies and guidelines. Within SR&P everyone is obliged to comply with both applicable laws and regulations and this Code of Conduct and all relevant policies and guidelines in the daily work.

If local laws and regulations require higher standards than this Code of Conduct, such standards must be followed.

Commitments

Combating corruption

SR&P will make active efforts to secure that bribery and corruption does not occur in its business activities.

Bribery is a form of corruption consisting in the offer or the exchange of any improper advantage made to influence someone in the conduct of their duties, e.g. any gift, loan, fee, reward, credit, discount, travel, accommodation or the other advantage between anybody working for or on behalf of SR&P and any person external to SR&P.

Danish companies and citizens can be prosecuted in Denmark for corruption committed in a foreign country.

The prohibition against bribery applies to both the private and the public sectors.

A kickback is a form of bribery between private entities, inter alia, made with the purpose of winning a tender for a contract. In this situation, the person who shall award a contract or an order does not necessarily award it to the best bid or proposal, but rather to the payer of the kickback. A kickback in this situation is illegal even if the company, which pays it, presents the best bid and would have won the contract even without the kickback.

SR&P will not promise, solicit, give or receive any kickbacks or advantages that can be seen to be in connection with the awarding of a contract, regardless of whether such advantage is exchanged before or after the contract has been awarded.

Facilitation payments are a form of bribery made with the purpose of expediting or facilitating the performance by a public official of a routine governmental action, and/or expediting or securing the provision of products or services to which SR&P has rightful claim.

SR&P is against facilitation payments and will actively oppose them if/when we meet them. The fact that corruption is a common practice in a given country does not make it more legal. In particular, even in cases of small illegal payments, references to local habits and patterns of trade are not a defense acceptable to the given country’s or Danish courts.

Political contributions are defined as financial or other kinds of support given to political parties and political campaign efforts, whereas charitable contributions are defined as contributions made to charitable causes or organizations.

SR&P does not support individual political parties or individual politician. Employees in SR&P may, however, exercise their private rights to participate in democratic political activities, provided that this is without any reference to or connection with their relationship to SR&P.

Charitable contributions and community support as well as donations, e.g. knowledge, services exchange, or direct financial contributions are acceptable, provided that such donations are not given with the purpose of obtaining or retaining business or any other undue advantage. SR&P’s employees must ensure, through due diligence and transparency, that charitable contributions and sponsorships, are not used as a substitute for, and do not constitute, bribery. Consequently, such donations should only be given to organizations, not individuals.

Gifts and Hospitalities such as confectionary, wine, tickets to sporting and cultural events provision of meals, receptions, social events, entertainment etc. must always comply with the laws of the country in which they are promised, solicited given or received. In this respect SR&P’s employees shall keep in mind that stricter rules normally apply to dealings with the public sector than with the private sector.

Consequently, SR&P’s employees will not offer or accept hospitality or gifts with the purpose of obtaining or retaining business or any other undue advantage or hospitality. Neither will SR&P’s employees offer or accept gifts or hospitalities which are unreasonable, excessive or exceeding normal market practice. Gifts in cash form or those equivalents to cash – such as gift certificates – are prohibited for SR&P’s employees to promise, solicit, give or receive. Gifts for or entertainment of parties engaged in tenders or competitive biding processes are forbidden altogether.

Maintaining records and accurate bookkeeping

While respecting confidentiality obligations, SR&P is committed to transparency and accuracy in all its dealings. Consequently, SR&P’s employees are responsible for maintaining records of SR&P’s business and must never make any false or misleading entries in SR&P’s books and records.

Furthermore, all transactions must be fully and completely recorded in SR&P’s accounting records in order for all accounting information to be correct and registered in accordance with applicable laws and regulations.

Confidential information and intellectual property

SR&P’s employees must never use confidential information in an improper way and must at all times comply with information classification requirements for confidential treatment of such information, however, such obligation shall not apply if disclosure is required by law or similar regulations.

SR&P’s employees must respect confidential information and intellectual property rights belonging to others and must never engage in industrial espionage.

The duty of confidentiality continues to apply after termination of the employment relationship with SR&P.

Fair competition and anti-trust laws

SR&P will compete in a fair and ethically justifiable manner and will not engage in any competitive behavior which can illegally affect pricing or market share, or lead to abuse of a dominant market position. SR&P must always act within the framework of the antitrust and competition regulations in the markets where SR&P operates.

Independence and conflicts of interest

SR&P’s employees must behave impartially in all business dealings and must strive to avoid situations where their loyalty may be compromised and their personal interest may conflict with the interest of SR&P or could in any other way have negative impact on their freedom of action or judgement.

SR&P’s employees must not work on or deal with any matter in which they themselves or any other physical or legal person with whom they have close relations has a direct or indirect financial interest. In this respect SR&P’s employees must also abstain from engaging in any activities having potential to be misinterpreted in this way if such activities are publicly disclosed.

Furthermore SR&P’s employees may in no way use or contribute to others using insider information about SR&P or other companies to trade in securities on SR&P’s behalf and/or privately.

Protection of personal data

SR&P is committed to process personal data carefully and in accordance with applicable laws and regulations.

SR&P’s employees must only use, collect and process personal data such as personal information about individuals if required for specific, lawful purposes and must never store such data longer than necessary.

Reporting and sanctions

SR&P’s employees are encouraged to report all instances of unethical or corrupt behavior in relation to SR&P’s conduct of business.

No employee of SR&P will be penalized or be subject to other adverse consequences for refusing to pay bribes, even if doing so may cause SR&P to lose business or suffer any other negative consequence. Additionally, no employee will be penalized for raising questions about or reporting on unethical behavior or corruption.

Failure to observe this Code of Conduct is a cause for disciplinary action and possible dismissal.