We estimate that the main climate impact comes from the energy consumption in our operations including heating and cooling of our facilities and transportation of ourselves. The energy consumption of the organization itself is estimated to:

• Our facilities and operations consume around 1,000 kWh per person per year in energy consumption (based on electricity consumption).
• The annual heating and cooling based on rent contracts is around 3,000 kWh per person.
• We strongly encourage the use of fossil free transportation and our car policies incentivize electric vehicles. Our estimates of transportation energy consumption (electric equivalents) add another 2,000 kWh/year to each individual.

The climate impact from our products varies heavily over the years based on annual shipped volumes. During 2021 most of our projects did not include delivery of volume products and the contribution from this was low. In general, our product development processes and environmental policies have defined clear targets on designing for low energy and design to eliminate hazardous substances (ROHS) and conflict materials from our designs.

By being a part of Qamcom Group we have an ambition to compensate for our impact:

• Qamcom Group invested in wind power plants in 2008. The energy produced by the wind power plants (to the portion we owned) in 2021 was around 3 million kWh.
• The consumption of energy for the operations and people (when at work) is around 6,000 kWh/person.
• Being 300 persons in the organization, we hereby get an estimate of a total yearly energy consumption of 300 x 6,000 = 1,800,000 kWh.

This means that we through Qamcom Group compensate by our own injected renewable energy from our wind power plants of well over our estimated consumption. We can state that we compensate for a fair amount of our employees private impact from an energy consumption perspective as well.

All interactions between employer and employees is based on mutual respect and being open and responsive to good ideas as well as to criticism. All employees are welcome to express their opinions at their workplace. Qamcom is responsible for ensuring that all employees and contractors have a safe and secure working environment. All Qamcom employees should know and abide by the applicable regulations, processes and policies for health and safety.

Qamcom has zero tolerance for corruption and bribery in all of its operations and business relations. This includes direct bribes, influence payments, kickbacks or other unlawful payments to any government or similar agency officials.

Our employees shall not provide or offer gifts, meals or entertainment that might be perceived as a bribe or means of influencing a business decision or to get benefits in a business context to anyone exercising public authority or decides on public procurements.

Qamcom employees shall not receive or accept a promise of gifts or similar from someone who does business with Qamcom if it creates a sense of being offered to influence a business decision.

Any such offer or proposed arrangement must be reported immediately to the Board of Directors.

Internal and external representation is to be conducted in a reasonable manner and in accordance with local legislation and tax regulations. Qamcom employees can offer or receive benefits only if they are offered openly, moderate and consistent with local legislation.

We regularly educate our staff on aspects of corruption, according to guidelines provided by Transparency International.

We respect all internationally proclaimed human rights, including the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. We strive to ensure that we are not complicit in human rights abuses. We shall, in all contexts, seek ways to honor the principles of internationally recognized human rights, even when faced with conflicting requirements.

Freedom of association – All employees shall be free to form and to join, or not to join, trade unions or similar external representative organizations and to bargain collectively. Information and consultation with employees can be done through formal arrangements or, if such do not exist, other mechanisms may be used.

Forced labor avoidance – Forced, bonded or compulsory labor shall not be used and employees shall be free to leave their employment after reasonable notice as required by applicable law or contract. Employees shall not be required to lodge deposits of money or identity papers with their employer.

Fair employment conditions – Employees shall understand their employment conditions. Pay and terms shall be fair and reasonable and comply at a minimum with applicable laws or industry standards, whichever is higher. Working hours shall comply with applicable laws. The normal work week shall not exceed 48 hours.

Hours worked beyond the normal work week shall be voluntary, unless a collective bargaining agreement allows for required time under certain conditions and/or, if legal, in exceptional circumstances. Other than in such circumstances, a work week shall not exceed 60 hours.

Exceptional circumstances include short-term business demands and natural disaster but do not include anticipated peak or seasonal increases in production requirements.

Absent exceptional circumstances, personnel shall be provided with at least one day off in every seven-day period. One day off shall be interpreted as at least twenty-four consecutive hours.

Deduction from wages as a disciplinary measure shall not be permitted. Corporal punishment, physical or verbal abuse or other unlawful harassment and any threats or other forms of intimidation shall be prohibited.

Child labor avoidance – No person shall be employed who is below the minimum legal age for employment. Minimum age is the age of completion of compulsory schooling, or not less than 15 years or not less than 14 years, in countries where educational facilities are insufficiently developed. Children shall not be employed for any hazardous work, or work that is inconsistent with the child’s personal development. A child means a person below the age of 18 years. Personal development includes a child’s health or physical, mental, spiritual, moral or social development.

Elimination of discrimination – All employees shall be treated with respect and dignity. All kinds of discrimination based on partiality or prejudice is prohibited, such as discrimination based on ethnicity, gender, skin color, sexual orientation, marital status, pregnancy, parental status, religion, political opinion, nationality, social origin, social status, indigenous status, disability, age, union membership and any other characteristic protected by local law, as applicable.

Employees with the same qualifications, experience and performance shall receive equal pay for equal work with respect to those performing the same jobs under similar working conditions.

Fair Working Conditions – A healthy and safe working environment and, if applicable, housing facilities shall be provided for employees, in accordance with international standards and national laws.

Appropriate health and safety information and training shall be provided to employees including, but not limited to, arrangements for safe evacuations of buildings and correct handling and marking of chemicals and machinery.

Dealing with conflicts of interest
At Qamcom, we make business decisions based on the best interests of the company rather than personal considerations or relationships. A conflict of interest arises when anything interferes with or influences the exercise of an employee’s independent judgment in the best interests of Qamcom. We must avoid situations in which our personal interest may conflict with, or even appear to conflict with, the interests of the company.

The following are examples of situations to be particularly aware of:
Business opportunities – You may not take business opportunities for yourself that are discovered in your duties for Qamcom if this could be contrary to the interests of Qamcom. Nor may you otherwise use Qamcom property or information or your position at Qamcom for personal gain.

Personal Investments – Avoid making any investments that affect or could affect the integrity of yourself or the integrity of Qamcom. This means, for instance, using information you gain through your employment to better your own investing position(s). There is of course rules and regulations regarding dealing with insider trading, but we advise you to please consider any, and all, investments that could lead to the questioning of the Company’s integrity. Any investment in a private company that is or can be a potential competitor to Qamcom or have a business relationship to Qamcom requires written approval from CEO of Qamcom Group and that relevant stakeholders are informed.

Other employment – Any employment outside Qamcom, with or without compensation, must not harm job performance at Qamcom. You may not engage in outside business interests that divert time and attention away from Qamcom responsibilities or require work during Qamcom time. Any Employment that could be seen as in competition with Qamcom’s business or business interests is not allowed. If in doubt, contact CEO of Qamcom Group for written approval on beforehand.

Equipment – Tools and Equipment provided by Qamcom or available to you through your employment at Qamcom may not be used for any activities or purposes that could be in competition with Qamcom’s business interests.

Board memberships and other outside affiliations – Service on a board of directors, advisory board or similar body of a for-profit enterprise outside Qamcom Group or government agency is permitted if it is obvious that it does not create a conflict of interest. If there is any doubt if it can create a conflict of interest such service must be approved in writing and in advance by the CEO of Qamcom Group. Serving on boards of not-for-profit or community organizations does not require prior approval.

Political activities – Qamcom will not make contributions or payment or otherwise give any endorsement, directly or indirectly, to political parties or committees or to individual politicians.

Disclosure of conflicts of interest – We require that employees disclose situations or transactions that reasonably would be expected to give rise to a conflict of interest. If you suspect that you are involved in a transaction or any other arrangement that presents a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it.

At Qamcom, we make business decisions based on the best interests of the company rather than personal considerations or relationships. A conflict of interest arises when anything interferes with or influences the exercise of an employee’s independent judgment in the best interests of Qamcom. We must avoid situations in which our personal interest may conflict with, or even appear to conflict with, the interests of the company.

The following are examples of situations to be particularly aware of:

Business opportunities – You may not take business opportunities for yourself that are discovered in your duties for Qamcom if this could be contrary to the interests of Qamcom. Nor may you otherwise use Qamcom property or information or your position at Qamcom for personal gain.

Personal Investments – Avoid making any investments that affect or could affect the integrity of yourself or the integrity of Qamcom. This means, for instance, using information you gain through your employment to better your own investing position(s). There is of course rules and regulations regarding dealing with insider trading, but we advise you to please consider any, and all, investments that could lead to the questioning of the Company’s integrity. Any investment in a private company that is or can be a potential competitor to Qamcom or have a business relationship to Qamcom requires written approval from CEO of Qamcom Group and that relevant stakeholders are informed.

Other Employment – Any employment outside Qamcom, with or without compensation, must not harm job performance at Qamcom. You may not engage in outside business interests that divert time and attention away from Qamcom responsibilities or require work during Qamcom time. Any Employment that could be seen as in competition with Qamcom’s business or business interests is not allowed. If in doubt, contact CEO of Qamcom Group for written approval on beforehand.

Equipment – Tools and Equipment provided by Qamcom or available to you through your employment at Qamcom may not be used for any activities or purposes that could be in competition with Qamcom’s business interests.

Board memberships and other outside affiliations – Service on a board of directors, advisory board or similar body of a for-profit enterprise outside Qamcom Group or government agency is permitted if it is obvious that it does not create a conflict of interest. If there is any doubt if it can create a conflict of interest such service must be approved in writing and in advance by the CEO of Qamcom Group. Serving on boards of not-for-profit or community organizations does not require prior approval.

Political activities – Qamcom will not make contributions or payment or otherwise give any endorsement, directly or indirectly, to political parties or committees or to individual politicians.

Disclosure of conflicts of interest – We require that employees disclose situations or transactions that reasonably would be expected to give rise to a conflict of interest. If you suspect that you are involved in a transaction or any other arrangement that presents a conflict of interest, or something that others could reasonably perceive as a conflict of interest, you must report it.

For both external and internal violations (real, alleged or suspected) against any part of the code should be reported and discussed with senior colleagues, the site manager or operations responsible, the chairman of the board. Our staff can escalate and report any observations that is suspected or judged to be a violation to this policy where the reporter can remain anonymous.

It is impossible to frame every single ethical scenario we might encounter, please always use your best judgement. If you’re uncertain speak up to a senior colleague, a coworker or anyone else you feel might be able to give you guidance. At Qamcom trust is an important cornerstone.

You can report a violation through this form: Report Code of Conduct Violation.