1.     Ensuring sustainable business conduct

Renta Group (hereafter Renta) is a full-service equipment and machine services company. Renta has a broad geographical reach with presence in several countries with employees with varying cultural and educational backgrounds. Renta takes responsibility for the impact its business generates both locally and globally and we are proud of the positive contributions we make. Responsible and ethical procedures and practices are a prerequisite for every operation – to be professionals worth your trust.

Renta is committed to conducting its business according to international sustainable standards outlined in the UN Global Compact. Renta shall always work to uphold universal human rights and fair labour practices, in the organisation itself and in collaboration with business partners and suppliers. Renta shall work to contribute and support to battling climate change, minimising biodiversity loss and negative environmental impact. Furthermore, Renta shall work to combat corruption and maintain high ethical business standards. The purpose of this Business Code of Conduct (also referred to as “the Business Code”) is to ensure sustainable business conduct.

1.1      Scope and responsibility of the Business Code

This Business Code applies to suppliers, partners, and customers with whom Renta conducts business, including subsidiaries and sub-suppliers, partners, and customers (hereafter “Business partner”). The Business Code also applies to all the suppliers, partners, and customers’ employees, whether permanent, temporary or hired through manpower agencies, including working under suppliers, partners and customer’s control. The term “shall” in the Business Code is referred to as a mandatory requirement.

The Business Partner is responsible for communicating the Business Code to their sub-contractors and ensure that suppliers, partners, and customers in their supply chain adhere to the responsibilities and requirements set out in this Business Code.

1.2      Foundation of the Business Code

This Business Code defines the minimum standards that Renta requests suppliers, partners and customers to abide by when conducting business with Renta. The Business Code covers the following areas of sustainability, human rights, labour rights, environmental protection and anti-corruption. The Business Code is based on the Declaration of Human Rights, the International Labour Organisation’s Declaration of Fundamental Principles and the Rights at Work, the Rio Declaration on Environment and Development and the UN Convention against corruption, as outlined in the ten principles of the UN Global Compact.

1.3      Legal compliance and the Business Code

The Business Partner shall comply with local laws and regulations of each country of operation. If provisions in national and/or regional laws, regulations or rules in the country or countries of operation provide a more stringent position to the standards set forth in this Code, such legislation shall prevail. In case where this Business Code is in direct conflict with mandatory national legislation, the national legislation shall prevail. However, if the Business Code sets out stricter requirements than national legislation, this Business Code shall prevail.

2         Human rights and Labour rights

Internationally recognised human and labour rights shall be protected and respected at all times. All workers shall be treated with respect and dignity and shall be entitled to fundamental human rights or labour rights. The Business Partner is responsible for ensuring that they do not directly or indirectly violate human rights or labour rights.

2.1      Child labour

No person shall be employed who is below the minimum legal age for employment within the country of operation. Children under the minimum working age established by local law or fifteen (15) years, whichever is greater, shall not be used as labour force. Employees under the age of eighteen (18) shall not engage in hazardous or heavy work, or on night shifts.

2.2      Forced labour

All forms of forced, compulsory or illegal labour is prohibited including exploitation of vulnerable groups such as migrant workers. Employees shall not be required to lodge deposits or original identity papers to their employer or recruitment agent as a condition for employment. Employees shall be allowed to move freely at the workplace without supervision and have the possibility to leave the premises outside of working hours.

2.3      Fair working conditions

No one shall be subject to corporal punishment, nor physical, sexual, psychological or verbal harassment or abuse. Disciplinary measures such as monetary deductions are not permitted.

Employees shall not be forced to work more than 48 hours per week. Overtime hours are allowed in accordance with the law of the country in which they are employed, however shall not exceed twelve (12) hours per week unless a bargaining agreement states otherwise. All overtime time shall be voluntary. Employees shall be given at least one day off in every seven-day period and have sufficient time to rest between shifts. The Business Partner shall also provide employees with regular and sufficient workday breaks and meal periods.

Annual leave shall be afforded to each employee. Employees are entitled to at least three weeks of paid annual vacation. Sick leave and parental leave shall be permitted and paid for in accordance with the national legislation or regulation in the country of operation.

Employees shall have written contracts, in languages understandable to the employee, specifying the terms of employment including working hours, overtime compensation, wage, frequency of payment and notice period. Overtime shall be compensated at the legally required rate. The Business Partner shall also ensure that employee wages and benefits composition are detailed clearly and regularly to them in writing for each pay period.

Employees shall have the right to equal pay for equal work. The Business Partner shall ensure that all employees are paid a living wage, which should be sufficient to cover the basic needs of the employee and provide some discretionary income. All employees shall be provided with adequate insurance and benefits.

2.4      Freedom of association and collective bargaining

The rights of employees to freely associate and to bargain collectively, in accordance with the laws of the countries in which they are employed, shall be recognised and respected. Where the right to freedom of association and/or collective bargaining is restricted under law, The Business Partner shall facilitate, and not hinder, the development of alternative forms of independent and free workers representation and negotiations.

The Business Partner shall ensure that workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. The Business Partner shall ensure that no one interferes with, or obstructs, the formation of unions or collective bargaining.

Workers’ representatives shall not be discriminated and shall have access to carry out their representative functions in the workplace.

2.5      Non-discrimination

The Business Partner shall ensure equal treatment in its practices and recruitment. Discrimination, whether active or by means of passive support, whether based on ethnicity, national origin, religion, disability, gender, age, sexual orientation, medical or disability status, marital or parental status, pregnancy, union membership, political affiliation or other grounds recognised under ILO conventions or national law in the country or countries of operations, is not accepted.

2.6      Occupational health and safety

The Business Partner shall ensure a safe and healthy work environment, both physically and mentally. A detailed risk assessment shall be established where occupational hazards have been listed and preventative measures have been taken. Adequate fire safety shall be ensured in all workplace operations and there shall be reasonable number of fire extinguishers, clear evacuation routes, emergency preparedness plans and first aid kits at the workplace. Safety instructions, evacuation drills, fire safety, first aid training and work specific training shall be documented and provided regularly in a language understandable to the employees. Injuries and accidents occurring at work shall be logged, investigated and preventative measures shall be introduced. Adequate personal protective equipment shall be identified and provided to employees free of charge. The Business Partner shall also take measures to ensure that workers are protected from exposure to harmful levels of chemicals through inhalation or skin contact.

Information and training shall be provided to employees including, but not limited to fire safety, handling of chemicals, work tools/machinery, hazardous waste, emergency awareness and first aid.

All premises shall be clean and safe. Employees shall have ready access to safe drinking water, lockable and gender separated toilets and a sanitary place for food storage separate from hygiene facilities. The facilities shall be well lit, ventilated and kept at acceptable temperatures and noise levels.

When provided by the Business Partner, dormitory facilities and other accommodation shall be clearly segregated from the factory and production area. Worker accommodation shall be equipped with potable water, clean and private toilet and bathing facilities. Accommodation shall be safe and meet the health and safety standards as specified in this Business Code. The accommodation shall not be overcrowded and the Business Partner shall provide each worker with personal storage space.

A record of accidents and injuries on the workplace shall be kept together with an action plan to minimise the causes of hazards in the working environment.

2.6.1       Alcohol and drugs

Many of the tasks carried out within Renta’s value chain are demanding in terms of occupational safety and technical performance. Because of this, the Business Partner is required to have a zero-tolerance policy on drugs and alcohol, combined with a process for early intervention and referral to treatment.

2.7      Subcontracting

Unauthorised subcontracting is prohibited. All cases of subcontracting must be agreed upon in writing between authorised parties and verified by a senior manager. Failure to comply with the no-subcontracting policy may be grounds for immediate termination of the order placement.

2.8      Privacy and integrity

The Business Partner shall ensure the employees right to privacy and integrity and take appropriate measures to protect personal information of employees. No one shall be subjected to arbitrary interference with his/her privacy, family, home or correspondence, nor to attacks upon his/her honour and reputation.

The Business Partner shall protect the personal data of employees, customers and other business partners. Privacy and personal data protection are fundamental rights; thus, all personal data shall only be processed within the boundaries of applicable law.

2.9      Product safety

All products and services delivered to Renta shall meet valid product safety standards applicable to the function of the finished product. The Business Partner shall also ensure that products and materials delivered to Renta meet the requirements for product safety set by the EU.

The Business Partner shall ensure that products and materials delivered to Renta meet chemical requirements at set by the EU. Substances restricted or limited according to the European Union directives REACH and RoHS should not occur in products and materials delivered to Renta. The Business Partner should therefore apply the substitution principle, meaning that chemical substances shall be substituted when a safer alternative is available.

3         Environmental protection

The Business Partner shall actively work to minimise its negative impact on the environment in general and the climate and biodiversity. In situations where risk or uncertainty of the safety of an action, product, substance or compound prevails, a precautionary approach and protective action shall be taken.

3.1      Environmental risk assessment

To ensure responsible production, The business partner shall conduct an environmental risk assessment and implement actions to prevent, mitigate and control the impacts of their operations accordingly. The risk assessment shall always include an assessment of impact on biodiversity and ecosystem services. Biodiversity and ecosystem resilience shall not be decreased due to business activities, and all negative impact shall be reduced and kept to a minimum.

3.2      The precautionary principle and environmentally friendly technology

The precautionary principle shall always be applied in situations where risk or uncertainty of the safety of a product, substance or compound prevails, and action shall be taken accordingly.

The Business Partner shall always promote the development and use of environmentally friendly technologies.

3.3      Sustainable use of resources

The Business Partner shall use all resources, including raw material, energy and water, responsibly and within the limits of the planetary boundaries. The Business Partner shall:

• Constraint all use of resources, especially resources from fossil sources
• To the greatest extent possible use material that is recyclable
• Prioritise energy from renewable sources
• Foster responsible water stewardship and minimise water consumption. If operating in areas with water scarcity, extra precaution shall be made to not compete with local water supply.
• Implement energy efficiency measures to reduce overall energy consumption
• Ensure that biodiversity is not decreased due to the business operations
• Reduce or eliminate deforestation caused by operations

When selecting packaging materials, the Business Partner shall use recycled and recyclable materials (e.g., cardboard and plastic) to the greatest extent possible. The Business Partner should limit redundant packaging materials.

3.4      Sourcing of materials

The Business Partner shall not source or use materials from high conservation value areas (HCVA) or endangered forests as listed by Convention of International Trade in Endangered Species (CITES) and/or the International Union for Conservation of Nature (IUCN). The Business Partner shall work proactively to ensure that minerals in its products and its supply chain are responsibly sourced. When applicable, the Business Partner shall have a policy and due diligence frameworks in place, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas[1].

3.5      Emissions, waste and effluents

The Business Partner shall identify, monitor and reduce all emissions from operations, including, but not limited to, air, water and noise emissions, with a specific focus on reducing greenhouse gas emissions. This includes choosing transportation methods with the least negative environmental impact.

Wastewater and solid waste, both hazardous and non-hazardous, generated from operations, industrial processes and sanitation facilities shall be monitored, controlled and treated before discharge or disposal. Wastewater treatment should enable reuse of water aiming for a closed loop system. Toxic materials including organic materials, metals (such as zinc, silver, cadmium, thallium, etc.) acids, alkalis, non-metallic elements as well as oils and organic components (BOD and COD) should be treated in such system.

All waste material and production by-products shall be disposed of according to the law and handled in an environmentally responsible manner by a certified waste contractor. To minimising the amount of waste created, the Business Partner is encouraged to reduce, reuse and recycle products and material, in that priority order.

3.6      Chemicals and hazardous substances

Chemicals and hazardous substances shall be eliminated when possible or kept to an absolute minimum. When chemical or hazardous substances are used, Suppliers, partners and customers shall ensure safe handling, storage and disposal of the substances. All substances shall be marked with Material Safety Data Sheets (MSDS) to ensure the protection of employees and the environment. Substances restricted or limited according to the European Union directives REACH and RoHS should be phased out according to the substitution principle. The Business Partner should further regularly risk assess chemicals and hazardous substances used in operations and should strive to substitute all chemicals listed in the Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) candidate list[2] of restricted substances.

4         Anti-corruption

The Business Partner shall ensure transparent and consistent corporate governance practices and abide by applicable regulations and standards in each of its geographical markets. All forms of corruption are unacceptable. Corruption includes, but is not limited to bribery, extortion, facilitation payments, nepotism and cronyism, fraud, money laundering, transfer mispricing, tax evasion or tax avoidance, market distortion, conflict of interest, and unfair competition. This entails but is not limited to the abuse of a position of trust, influence, or power to gain an undue advantage. The definitions used in this policy are based on the UN convention against corruption and the OECD anti-bribery convention and guidelines for multinational enterprises and the UN Global Compact.

4.1      Bribery

Bribery is a form of corruption, i.e., the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action, which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage. The promising, offering, or giving is referred to as “active bribery[3]”, as opposed to the act of receiving or soliciting, which is “passive bribery”.

4.2      Facilitation payments

Facilitation payments (sometimes referred to as “grease payments”) are a form of bribery that involves expediting or facilitating the performance by a public official of a non-discretionary, routine governmental action.

4.3      Kickbacks

Kickbacks are payments of any portion of a contract made to employees of another contracting party or the utilisation of other techniques, such as subcontracts, purchase orders or consulting agreements, to channel payment to public officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.

4.4      Gifts and hospitality

The activities of gifts and hospitality, facilitation payments and political and charitable contributions involve some form of economic exchange and are typically seen as carrying heightened bribery and corruption risk, as bribery and corruption can be disguised under those.

It is forbidden for Business Partner employees to offer or give any gift or hospitality which could be regarded as illegal or improper, violates the recipient’s policies, or in contradiction to local tax legislation unless approved in writing by a senior manager or board.

No employee may accept any gift or hospitality from Renta’s business partners or third parties if it could be regarded as illegal or improper or is perceived to be of a significant monetary value or if it is in cash; or if there is any suggestion or implication that a return favour will be expected.

4.5      Personal relationships or interests

Business decisions must never be motivated or influenced by personal relationships and/or interests. A financial or other business relationship with a partner who contributes to, or risks contributing to, conflict of interest should never be initiated. For both internal and external recruitment, a specification of the desired competencies must be established to ensure that candidates receive the employment based on knowledge and not on relationships. Employees may not conduct activities that are competing with Renta.

4.6      Fair competition

Renta is firmly committed to free and fair competition in open markets. Our Business Partners respects and complies with all applicable competition laws, and shall not engage in any form of cartels, abuse of power, beneficiary services or market distortion. Our Business Partner shall further not engage in activities that may hinder the development of fair competition.

Business Partners shall always submit truthful and accurate tax declarations to tax authorities in all countries where the Business Partner has operations. The Business Partner will further not conduct transfer mispricing.

4.7      Political and charitable contributions

Renta shall not make political contributions, whether in cash, in kind, or by any other means, to support any political parties or candidates, as this may be perceived as an attempt to gain an improper business advantage. Therefore, Renta asks our business partners to respect our standpoint on political contributions.

5         Right to audit and inspection

Renta reserves the right to request the Business Partner to participate in a self-assessment questionnaire, in which the Business Partner shall cooperate.

Renta also reserves the right to conduct on-site audits and follow-up of the Business Partner, itself or through independent third parties, to ensure that the Business Code is complied with. The Business Partner shall, on request, provide the appropriate resources and documentation at any time of inspection.

The Business Partner shall ensure these rights at its sub-suppliers, partners, and customers.  In case of violations of the Business Code, the Business Partner will be asked to provide a corrective action plan for Renta to approve.

In case of serious violations of the Business Code, Renta has the right to terminate contracts with the Business Partner.

6         How to raise concerns

If the Business Partner discovers breaches against this Business Code, within the company or amongst its suppliers, partners and customers, the business partner shall without delay inform Renta.

For anonymous grievances, Renta has set up a reporting function with a commitment to fair treatment of information. The anonymous function is available at https://report.whistleb.com/en/renta.

–

[1] https://www.oecd-ilibrary.org/governance/oecd-due-diligence-guidance-for-responsible-supply-chains-of-minerals-from-conflict-affected-and-high-risk-areas

[2] https://echa.europa.eu/candidate-list

[3] The term does not mean the active briber has taken the initiative, since the bribe may have been demanded (“solicited”) by the receiving party who commits “passive bribery”.