Ethical Operating Principles
To ensure the responsibility of our operations, we have defined the principles of responsible business practices, which also apply to our contract suppliers.
Principles and policies
L&T's policies and principles include environmental, ethical and social perspectives, which the group follows both in its own operations and in the services it provides to customers. L&T's policies are complemented by the Code of Conduct guidelines for personnel and suppliers.
Environmental Policy
Our environmental policy defines our environmental objectives and the principles we observe in our own operations as well as in the services we produce for our customers. We comply with legislation pertaining to our operations as well as orders issued by the authorities. We also observe the ISO 14001 standard in our operations.
With regard to environmental issues, L&T’s objective is to be closely involved in the development of a recycling society and a circular economy. We promote the sustainable use of natural resources by preventing waste, managing the recovery of materials to be recycled and reused and by replacing fossil fuels with bio-based raw materials. We aim to actively promote the operating conditions for a circular economy.
Our mission is to make the circular economy a reality. Together with our customers, we keep materials and properties in productive use for as long as possible and increase the efficiency of the use of raw materials and energy. This is to create more value with the circular economy for our customers, personnel and society in a broader sense. Our objective is to continuously grow our carbon handprint, which refers to the positive climate impact of our operations. We observe our environmental policy in our own operations and in the services we produce for our customers. To do this successfully, we need robust environmental competence that meets our customers’ needs and we must reduce the carbon footprint of our operations.
L&T’s Board of Directors and management are committed to the achievement of our sustainability targets and the continuous development of sustainability. Our sustainability targets also include environmental targets and their achievement is actively monitored.
To improve our services and achieve our environmental goals, we invest in training our employees and we also work to develop our customers’ processes. We also guide our employees to take environmental aspects into account when they work at our own premises and at customer premises. We also assess the environmental risks of our operations and, where possible, strive to eliminate or minimise risk factors. We also require our contractual partners, suppliers and service providers to commit to environmentally responsible operations. This environmental policy policy applies to the entire L&T Group and it is approved by Lassila & Tikanoja plc's President and CEO and the Group Executive Board.
Updated October 2021
HR Policy
This policy describes the purpose, responsibilities and organisation of the personnel policy of the Lassila & Tikanoja Group (“L&T”).
L&T complies with national legislation, collective labour agreements, internationally recognised human rights and complies with the core principles of the International Labour Organisation (ILO). Our work community is based on equality, we do not use child labour and we have zero tolerance for any form of discrimination.
Our personnel policy is based on L&T’s strategy and the principles of sustainability, operations and management. Good personnel experience consists of the implementation of these principles.
The aim of the policy is to ensure that L&T’s staff, who are aware of the objectives and strategy, are competent and committed, form the basis for achieving a good and sustainable financial result.
Our personnel policy consists of the key principles of the L&T Group in the areas of personnel management.
Our operating principles “Code of Conduct” defines how all L&T employees act and work together. Our operating principles set expectations for the responsible and ethical behaviour of L&T employees and help L&T employees make the right decisions in their daily work. Our operations are based on nine principles: We comply with the laws, rules and regulations, our actions are honest and transparent, we act in the interest of the company, we respect human rights, we respect each other and our common workplace, we work safely, we take care of our environmental obligations in an uncompromising manner, we require our suppliers to act responsibly, we intervene in cases of misconduct.
Management
The results of L&T are generated through the employees.
At L&T, we are committed to working together according to our leadership principles, which include caring and appreciation, co-operation and responsible renewal. The aim of the leadership principles is to create a better tomorrow at L&T.
Remuneration
The aim of all remuneration at L&T is to promote good performance and to motivate personnel to engage in long-term efforts to promote the achievement of the company’s goals. Remuneration is one factor through which the company strives to ensure the availability of skilled and motivated persons for all positions at all levels of the organisation. Remuneration solutions are based on strategy and business objectives and are supported by regular review of the base salary, L&T-level and business-specific performance bonuses as well as personnel benefits.
Competence
Competent personnel are a key common factor in L&T’s competitive advantage and positive customer experiences. Our goal is to provide our customers with the best personnel to assist them.
The purpose of competence management is to ensure that L&T has the necessary competencies at its disposal today and in the future. Competence management is based on L&T’s strategy. The assessment of individual competencies is part of this process, as it supports the selection of effective competence development actions.
At L&T, competence refers to an individual’s ability, knowledge and skill to act professionally in different situations in L&T’s operating environments. At the L&T level, competence refers to the organisation’s ability to implement its strategy.
The need for competence development is assessed and planned in development discussions together with the supervisor. The main responsibility for developing competence lies with the employee themselves, supervisors support the development of the competence of their team members. We develop the competence of our supervisors to ensure responsible management and supervisory work.
Equality and non-discrimination
Promoting diversity is one of the key themes of L&T’s sustainability programme. L&T is committed to promoting equality and non-discrimination. L&T companies draw up equality and non-discrimination plans in accordance with national legislation.
Our goal at L&T is to foster an increasingly diverse work community that accepts and respects differences. At L&T, we believe that our extensive diversity work strengthens the personnel experience of every L&T employee. We pull together to develop our culture and operating methods so that everyone finds it easy to join our organisation and enjoys being part of our work community.
Safety and well-being at work
We promote the safety, work ability and well-being of our personnel through proactive work and management of work ability. Our goal is zero accidents. We use effective proactive measures—such as risk assessments, safety observations, safety walks and safety talks—to improve our safety as well as the safety of our customers and other stakeholders, while also eliminating risk factors.
We increase our employees’ awareness of occupational safety and risks starting from induction training and also through online training and clear guidelines as well as by providing regular information on instructions, procedures and operating models. Our systematic efforts on this front are aimed at making our employees realise that everyone can contribute to occupational safety. L&T’s occupational safety activities are coordinated under an ISO 45001 certified management system as well as the Group’s occupational safety management principles.
We take care of our employees’ work ability throughout the life cycle of the employment relationship. At L&T, work ability management is aimed at increasing employees’ well-being, identifying problems at an early stage and focusing on their prevention.
Recruitment
We are constantly developing and measuring our recruitment methods, applicants’ experience and supervisors’ recruitment skills.
In recruitment, we are committed to equality, non-discrimination and making choices based on the things that predict success at work. Our personnel selections emphasise suitability for the task, motivation, competence and training.
In addition, we support internal career paths. Our goal is to create versatile and long-term employment relationships during which our employees can grow and develop.
Responsibilities and organisation
The personnel policy is approved by L&T’s Group Executive Board.
L&T’s HR unit is responsible for the personnel policy.
The personnel policy covers the operations of L&T’s companies in all operating countries. L&T’s personnel must adhere to the policy. L&T’s companies and units take care of the implementation of the policy and the necessary resourcing in their own operations.
Entry into force
Approved by L&T’s Group Executive Board on 18 December 2023. Effective on 1 January 2024. Replaces the personnel policy approved by the L&T’s Group Executive Board in 2012.
Communications Policy
L&T’s communications support the company in its efforts to implement its business strategy, achieve its objectives and build its reputation among key stakeholder groups. This policy defines the communications principles, channels and responsibilities.
Principles of communications
Our communications are geared towards openness and bilateral interaction. We engage in continuous dialogue with our stakeholder groups and develop our operations on the basis of this interaction.
In our investor communications, we comply with Finnish legislation and the regulations and guidelines of NASDAQ OMX Helsinki and the Financial Supervisory Authority. Our disclosure policy specifies the operating principles and methods we use in our communications with the capital markets.
L&T’s crisis communications seek to minimise the negative impacts of unexpected, sudden situations on the company. In crisis communications, we follow our crisis communications process.
In Finland, L&T’s corporate communications department co-ordinates all media contacts and agrees on guidelines for comments with the selected spokespeople. In our other business countries, contacts from the media are forwarded to the communications responsible or the Country Manager.
Company-wide position statements and major news announcements are made public by the President & CEO or his designated spokesperson. Only the President & CEO, CFO and Head of Investor Relations may make public statements concerning the company’s financial position.
Unit managers and experts can make statements concerning their own area of responsibility. They must agree on guidelines for their comments with L&T’s corporate communications department.
The company does not comment on confidential or incomplete business transactions or on its competitors.
We have specified permit procedures for sponsored advertising and sponsorships with a view to ensuring consistent visibility in line with our brand at selected sites.
Communications responsibilities
L&T’s corporate communications department is responsible for company-level guidelines, development and channels. It provides expert assistance and communications training. In addition, we also make outlays on developing our supervisors’ communications capabilities and opportunities.
L&T's corporate communications department coordinates the communication of Group-wide topics and develops internal communications channels. Responsibility for communicating division specific topics lies with the Marketing Managers of each division.
The CFO and the company’s IR staff are responsible for investor communications. The divisions’ Marketing Managers hold the main responsibility for customer communications. When organising customer events, we follow a separate permit procedure, which aims to ensure the appropriateness and fairness of events.
Major channels
In Finland, the primary channels for internal communications are the intranet, e-newsletters and internal info meetings.
The most important channel for external communications is our Internet site. We publish all communications materials for external stakeholders on the site without delay.
We have drafted separate guidelines for the use of L&T's social media channels.
Occupational safety policy
The goal of our occupational safety operations is to guarantee a safe workplace for all employees. We are committed to the idea of zero accidents and we believe that all accidents can be prevented.
We comply with all legislation pertaining to our operations as well as orders issued by the authorities. We also observe the ISO 45001 standard in our operations. In the event of any action or conduct in violation of the applicable legislation, orders issued by the authorities or instructions, we take immediate action in accordance with mutually agreed upon rules.
We survey the hazards and risks of our services and various tasks in advance in order to eliminate or minimise the risks. We encourage our employees to actively engage in proactive safety efforts, such as making safety observations, conducting Safety Walks and participating in occupational safety sessions. We investigate all accidents immediately and take corrective action without delay. To secure our operations, we have sufficient resources as well as harmonised processes, tools and instructions. Our management has a strong commitment to the continuous development of occupational safety by providing the necessary resources, maintaining an awareness of their organisation’s level of occupational safety and actively setting an example.
The responsibility for occupational safety lies with the line organisation. Occupational safety is an integral aspect of day-to-day management at all levels of the line organisation. However, it is the right and duty of each L&T employee to monitor and make observations to improve the safety of the working environment. We guarantee our personnel sufficient induction, occupational safety training and personal protective equipment for safe work. When we work in the customer’s premises, we take into account the customer’s safety targets and instructions as well as the safety of shared workplaces in our operations.
We are continuously developing and improving occupational safety together with all the personnel groups and on all levels of the organisation. Our occupational safety activities are transparent: information and materials are open to all employees and they encourage people to learn from each other. We also require L&T’s contractual partners to make a commitment to the continuous development of occupational safety.
This occupational safety policy applies to the entire L&T Group and it is approved by Lassila & Tikanoja plc’s President and CEO and the Group Executive Board.
Updated October 2021
Quality Policy
Our quality policy describes the key principles governing our operations. In accordance with our principles, we operate responsibly and in line with L&T’s values in all of our business functions. We are com-mitted to the continuous development of our operations and ensuring responsibility and sustainability in everything we do.
In our operations, we comply with applicable legislation and orders issued by the authorities. We also observe the ISO 9001 standard and L&T’s Code of Conduct in our operations.
The satisfaction, well-being and professional development of our employees are important to us. We want to provide an equal, non-discriminatory and safe work environment for our employees. We take customer needs and expectations into account in our operations. We bear social responsibility and also require our contractual partners and suppliers to operate responsibly.
We always aim to ensure sufficient resources in order to keep the quality of our services as high as possi-ble. In our management, we apply a risk-based approach to serve our customers as efficiently, reliably, innovatively and safely as possible.
Our management is committed to the continuous development of our operations. To ensure development, we regularly measure customer and employee satisfaction as well as the effectiveness of our management system. Based on the results of these measurements, we create corrective measures and monitor their implementation. This quality policy applies to the entire L&T Group and it is approved by Lassila & Tikanoja plc’s President and CEO and the Group Executive Board.
Updated October 2021
Procurement Principles
The bulk of L&T’s procurements comprise subcontracted external labour and services as well as vehicles and fuels, technical products and various materials. We seek to engage in safe, sustainable, reliable and cost-effective procurements, taking the entire life cycle and processes of products and services into account. We comply with the principles of sustainable development, which guide us to save raw materials, energy and nature. We also comply with good business practices and follow our ethical guidelines in our dealings with all our suppliers and subcontractors.
These procurement principles provide more detailed guidelines for cooperation with suppliers. The guidelines also apply to the subcontractors of our suppliers (please note that this is not stated again below). Supplier Code of Conduct (PDF)
Compliance with legislation
In all of our operations, we comply with relevant national legislation and official regulations as well as both national and international agreements, and expect our suppliers to do likewise. We monitor compliance with collective bargaining agreements, environmental, labour and occupational safety legislation and regulations on the management of finances, and comply with local legislation on contractors’ obligations when using labour.
Our co-operation may not involve bribery or any such hospitality or gifts that might influence decision-making in our business relationships.
Quality requirements
The performance and operating methods of our suppliers must meet the requirements we have set for the product group in question. If necessary, we carry out tests and checks to ensure that they fulfil the technical and operational requirements. When selecting a major new supplier, we review information concerning their competitiveness and finances in order to ensure that they can provide high-quality products and services. We also send them a written query and check their credit rating. If, when selecting a provider of services or goods, we note any such issues on which we would like a more detailed report, we request one from the supplier.
We monitor the quality and performance of suppliers in a manner appropriate to the product group in question. We require our suppliers to have good and reliable operating methods. Good delivery reliability is a must. We use regular monitoring and product group-specific indicators to ensure the delivery reliability and quality of our suppliers as well as the adequacy of necessary replacement measures.
Environmental requirements
We require our contractual partners and suppliers of goods and services to comply with applicable environmental legislation and official regulations as well as to engage in environmentally responsible operations.
As an environmental company, we have many environmental requirements for specific products and services, which we include in our product group-specific requirements.
We monitor the environmental performance of our suppliers and encourage them to improve it continuously as well as to use environmental management systems and technologies that place a smaller burden on the environment.
Social requirements
We require our suppliers to comply with local collective bargaining agreements, local labour legislation and ILO agreements by adhering to the regulations that best protect the rights of employees. Our suppliers must ensure that their employees have safe and healthy working conditions. If we observe any risks during the pre-selection of a supplier, or risks in the operations or operating environment of a supplier, and these risks are such that we would like a more detailed report on them, we either request one from the supplier or carry out an inspection or audit.
Selection and monitoring of suppliers
We review these procurement principles in detail with prospective major suppliers before becoming business partners. We define our product group-specific requirements for our suppliers in greater detail in our purchase terms and agreements.
We use the following methods in selecting major partners and monitoring our regular suppliers:
- supplier questionnaire and self-assessment of how well the company manages environmental, quality and occupational safety issues
- inspection or supplier audit
- information on the competitiveness and finances of suppliers
We use appropriate means in the selection of methods.
Non-compliance
If we observe non-compliance with these principles, we request the supplier to propose a corrective action programme and carry it out in the specified schedule. If the supplier cannot implement the required improvements, we will terminate our cooperation.
Approval of the principles
L&T’s Chief Procurement Officer is responsible for the procurement principles. The contents are approved by the Group Executive Board. The principles apply to the entire L&T Group.
L&T’s Group Executive Board approved and ratified these principles on 14 December 2012.
Data Protection Policy
Data Protection as a part of L&T’s business
The data protection policy defines L&T’s internally approved principles of data protection regarding the processing of personal data of customers, co-operation partners and other partners, employees and job applicants. With the data protection policy and the operation-specific data protection guidelines derived from the policy, we strive to ensure the lawful processing of personal data and the appropriate level of data protection. Taking care of data protection is a part of L&T’s compliance activities and principles of responsible operations.
Contact the legal department if you have any questions concerning data protection.
Processing of personal data
Key definitions
Personal data refers to all kinds of information describing a person or his/her personal aspects that may be identified to concern him/her. Personal data is e.g. a person’s name, social security number, date of birth, address, telephone number, e-mail address, location data, picture, video, IP-address and cookie data, if the data can be connected to a person. Personal data is not considered to refer to information that cannot be used to identify a person. Such information may be, for example, various statistics.
Sensitive data refers to data describing a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, sexual orientation, health, illness or disability or a criminal act, punishment or other consequence due to crime.
Data subject refers to a person whose data has been saved in the personal data register and whose data is being processed.
Processing of personal data refers to any operations which are performed on personal data, whether or not by automated means. Processing of personal data is the collection, recording, organising, structuring, storage, alteration, retrieval, use, transmission, disclosure, erasure or destruction of personal data.
Personal data register refers to any set of personal data collected for a specific purpose that is processed by automated means or is organised in paper format in such a way that the personal data is easily accessible without unreasonable costs. Separate notes do not usually form a personal data register, nor are a part of one. All data processed for the same purpose (e.g. customer relationship management) belong to the same register regardless of where and in which form they are stored.
Controller refers to a company or an organization that decides the methods and purposes of the processing and for whose use the personal data register is established. The controller is primarily responsible for that the personal data is processed according to the requirements of data protection legislation. For example, L&T is the controller for the personal data of its employees, job applicants and the consumer customers, as well as the executives and contact persons of its business customers and cooperation partners.
Processor refers to a party that participates in the processing of personal data on an agency, subcontractor or cooperative relationship basis, and that processes personal data on behalf of and for the controller. For example marketing service providers, IT and cloud service providers or personnel service providers are processors, when they process personal data on behalf of L&T.
Principles for processing personal data
L&T’s data protection policy and guidelines as well as the data protection legislation are complied with when processing personal data. We at L&T comply with the following principles in all our processing of personal data:
Planning the processing of personal data
The processing of personal data is planned in advance and L&T’s data protection policy and guidelines as well as the data protection legislation are complied with when planning the collection of personal data. For example, when developing and planning software and services that include or rely on the processing of personal data, or when planning new means of processing, the party responsible for the project or change shall, in a documented way, make sure that the privacy of the data subject is appropriately protected, taking into account the personal data collected and the need for protection.
The legal department assists, if needed, with the appropriate documentation of the project and with the planning of the lifespan of personal data.
Lawfulness, fairness and transparency
We will ensure that the processing of personal data is lawful, fair and transparent for the data subject. We will inform the data subjects i.a. of what personal data is collected from them, for what purpose, where the data is collected from and to whom the data is disclosed. A privacy notice will be drafted for each personal data register and we will make sure that the data subject is informed of the processing of personal data in a timely manner. The information concerning L&T’s existing personal data registers and their privacy notices are found at Silta.
Personal data is never collected or processed without an appropriate legal basis. Legal bases for processing are i.a. the consent given by the data subject, L&T’s legal obligations, the legitimate interests of L&T or the performance of a contract to which the data subject is a party.
Respecting the rights of the data subject
We will ensure that we inform data subjects appropriately and in a timely manner of the processing of their personal data and the data subjects’ rights concerning the processing of personal data. The rights of the data subject include i.a. the right to inspect the data, the right to demand the rectification and/or deletion of data, the right to data portability and the right to restrict the processing of personal data.
The data subject has a right to inspect what data of him/her has been collected and stored in the personal data register of L&T. The data subject may also demand the rectification of incorrect data or the deletion of personal data regarding him/her.
In our operations, we will ensure that the rights of the data subjects will be taken care of and that the requests are responded to without delay.
Purpose limitation
We collect personal data only for specific purposes defined in advance and we do not use the data for other purposes. The intended purposes are defined when planning the collection of personal data and they are described in the privacy notices.
Minimizing data
We collect and process only adequate and relevant personal data that is necessary for the described purposes. The collected data must be limited to what is necessary for the purposes for which they are processed. Especially the collection and processing of sensitive information is kept as restricted as possible.
Up-to-dateness of data and correcting errors
We will not process erroneous or outdated personal data. We strive to ensure that the personal data which, in relation to its purposes is erroneous or inaccurate, is updated or erased without delay. We try to verify the correctness and up-to-dateness of the data by checking the data with the data subject him-/herself or other reliable sources (such as the Population Register Centre).
Retention periods and deletion of data
We store the personal data only for as long as it is necessary considering the purpose of the data processing. Before we start processing the data we determine retention periods for the collected data or criteria according to which the retention period is determined. When the data no longer is necessary for the purpose, we delete or archive the personal data. The retention periods for the personal data being processed by L&T are documented in privacy notices.
Data security and confidentiality
We strive to ensure the appropriate data security of personal data by for example protecting the data from unauthorized and unlawful processing and destruction of data by using the appropriate technical and organizational measures. Technical and organizational measures shall mean various security measures which are used to ensure the data security of personal data in electric and paper form. Such measures may be for example personnel training and guidelines, non-disclosure commitments, access control, supervision of use, information system data security and technical restrictions, auditing, inspection and supervision systems, data encryption, anonymization and pseudonymizing of data.
We restrict access to personal data in electric or paper form only to those persons who need to process the personal data due to their duties.
The main responsibilities and duties as well as the minimum requirements for data security are described in L&T’s data security policy and guidelines related thereto.
Liability of the controller and accountability
We assess regularly the processes concerning personal data processing and the related risks, with special attention to the implementation of the rights of the data subjects, and we make sure that the measures taken are sufficient to ensure data protection. We make sure that the data protection documentation is appropriate and up-to-date, so that we, for example in case of a supervisory authority inspection, are able to prove that we comply with data protection obligations in our operations.
Processing data on behalf of L&T and data processing agreements
When transferring personal data to third parties, we always clarify in advance the grounds for the transferal. If the third party (for example a service provider, cooperation partner, subcontractor or IT provider) processes personal data on L&T’s behalf, the transfer in question is an outsourcing of personal data processing. For example purchasing data processing services or cloud services from a service provider is considered as an outsourcing of data processing. In this case, we will make a written agreement concerning the services and processing of personal data, in which we agree on how the service provider (the processor) processes personal data on behalf of and for L&T (the controller). In outsourcing the data processing the primary responsibility concerning the processing operations remains with L&T and therefore we will ensure that the agreement will contain provisions concerning the extent of the assignment and the requirements concerning data protection and data security. The service provider, as a contractor, shall not have the right to process the data for purposes of its own or connect the data with its own data registers. The service provider is given the right to process the data only to the extent required by the assignment and following the guidelines of L&T (the controller). The service provider is responsible for the processing of data pursuant to the service agreement between the contracting parties.
The processor’s data processing activities shall be agreed on in writing. Therefore L&T has drafted an annex concerning the data processing, which may be attached to the service (or similar) agreement between L&T and the service provider. The content and scope of the data processing agreement depend on the type of data processed, the scope of the processing activities and the risk assessment. If necessary, please contact the legal department.
Data transfer outside the EU/EEA
It is allowed to transfer the personal data from one country to another within the EU and the EEA. Even then we will ensure that the general principles of data processing are adhered to.
It might be necessary to transfer personal data outside of the EU or the EEA for example when transferring personal data within L&T from one group company to another or to an external service provider. Examples of data transfers are when a server, where personal data is stored, is situated outside of the EU or the EEA or when a service provider or L&T group company is outside of the EU or the EEA and has technical access to a server in the EU area that stores personal data (e.g. due to maintenance or repairs).
Personal data may not be transferred outside of the EU or the EEA without the prior consent of the legal department. When transferring personal data outside of the EU or the EEA we, in addition to the general principles regarding data processing, also ensure that an adequate level of data protection is guaranteed in the target country. Depending on the target country for the transfer, an adequate level of protection may be guaranteed by entering into an agreement with the transferee by using the standard contractual clauses adopted by the EU Commission.
Data security and personal data breaches
We strive to protect the data from data breaches, i.e. accidental or unlawful destruction, deletion, alteration, unauthorized disclosure or access to the data. L&T has defined a process that will be adhered to concerning data breaches. Everyone is obligated to notify of any noted data breaches in L&T’s operations without delay in accordance with a separate guideline concerning data breaches.
We will regularly assess the risks related to the data processing in our operations and act to minimize perceived risks, taking into account the newest technology and costs of implementation related to the risks of data processing and the nature of the personal data being protected. In this way we can ensure the adequate level of security.
We will take care of the protection of the data during its lifespan in all phases of the processing, starting from the collection of data and ending with its destruction. The security of the processing requires the ability to ensure the continued confidentiality, completeness, usability and fault tolerance of the systems and services as well as the ability to recover the accessibility of the data and access to the data if a physical or technical fault occurs. Protecting the data requires regular supervision and keeping track of the processing of personal data.
At L&T, the employees are offered guidance and training concerning data security matters. All employees must know the data security obligations concerning their duties and adhere to them. Each person is obligated to follow L&T’s data security policy and guidelines.
Organisation and responsibilities
Taking care of data protection is a vital and inseparable part of L&T’s business activities.
The ultimate responsibility for the compliance of data protection legislation and this data protection policy rests with the managing director. The general counsel is responsible for the organising of the compliance of data protection legislation and L&T’s data protection policy and guidelines. L&T’s IT management is responsible for the development and supervision of data security. The governance for data protection and data security is outlined in more detailed in a separate governance model.
At L&T, the employees are offered guidance and training concerning data protection matters. All employees must know the data protection obligations concerning their duties and adhere to them.
Consequences
L&T is obliged to compensate the data subject for damage caused by unlawful processing of personal data. Violations of the data protection obligations may also result in fines imposed by the supervisory authorities, which may be up to EUR 20 million or 4% of L&T's global total turnover. In addition, violations may lead to criminal liability.
Activities violating the data protection laws, this data protection policy or L&T’s data protection guidelines are considered to compromise the data protection and may lead to consequences under labour law.
Approval of the data protection policy
The board of directors of Lassila & Tikanoja Oyj has approved this policy on 25 April 2018.
Disclosure Policy
This disclosure policy lays down the operating principles and methods that Lassila & Tikanoja Plc (L&T) follows when communicating with the capital markets. The disclosure policy is approved by the company’s Board of Directors.
Goals and Principles of Investor Communications
L&T’s shares are listed with Nasdaq Helsinki Ltd. In its information policy and investor communications, L&T follows the applicable EU legislation, Finnish legislation, the rules of NASDAQ Helsinki, the regulations and guidelines of the European Securities and Markets Authority (ESMA) and the Financial Supervisory Authority, and L&T’s internal guidelines.
The aim of L&T’s investor communications is to convey correct, significant information to the capital markets that supports the correct price formation of the company’s shares and is simultaneously published to all market participants. The information to be published must be reliable, logical, credible and timely and must not be misleading.
All information is published in Finnish and in English.
Financial Reporting
L&T’s financial year is one calendar year. L&T publishes its financial statements release, half-year report and two interim reports in accordance with a schedule indicated before the end of the previous financial year. In addition, L&T publishes its financial statements and report, and, based on the Corporate Governance Code, a CR report and a remuneration statement.
Future Outlook
In its financial statements release, half-year report and interim reports, L&T presents a verbal assessment of trends in net sales and profit for the current financial year. L&T only provides assessments that concern the whole financial year.
Profit Warning
L&T publishes a profit warning if it can reasonably assess that its future outlook has changed from previously published assessments and that the change is likely to have a major impact on the price of L&T’s share or other financial instruments. The change is assessed in relation to the most recent published economic survey.
It is mainly the Board of Directors that makes the decision to issue a profit warning. If the Board of Directors constituting a quorum cannot be summoned at sufficiently short notice, the Chairman of the Board or the President and CEO will decide on issuing a profit warning. They seek to talk to as many Board members as possible before publishing the release. The profit warning is issued as a stock exchange release that also includes the previously published future outlook. Issuing the profit warning cannot be postponed.
Stock Exchange Releases and Press Releases
With a stock exchange release, information is simultaneously issued to all market participants about facts, matters and conditions that L&T believes are likely to have a major impact on the price of L&T’s share and other financial instruments. Regulated information that is required to be published with a stock exchange release (such as business transactions made by the management using the company’s financial instruments, the notice to a General Meeting and decisions of the General Meeting, flagging notifications and changes in the Group Executive Board not concerning the President and CEO) is also published with a stock exchange release even if the information did not contain details affecting the price of the financial instruments.
For example, the following information may have a considerable impact on the price of L&T’s shares and other financial instruments: major investments and acquisitions, significant redirection of business or a new cooperation arrangement, a pending important legal process or a decision awarded in this, and an important decision made by an authority or information concerning a joint venture.
As part of the aforementioned important arrangement or other event, the company prepares a case-specific assessment based on aspects and conditions related to each individual case and indicating whether the question is of insider information and whether the preconditions for postponing the publishing of information are met in that case. The assessment and, where necessary, the decision to set up an insider project and postponing the publishing of the information, are made by the Board of Directors or the President and CEO or a party authorised by them based on the recommendation of the CFO and the General Counsel. When the project is implemented, L&T publishes the postponed information with a stock exchange release and submits a notification to the Financial Supervisory Authority about postponing the publishing of the information.
Investor communications is responsible for publishing stock exchange releases through Nasdaq Helsinki and for distributing releases through news distribution and automatically to the Central Storage Facility for regulated information.
In addition to the above, news not meeting the preconditions of a stock exchange release but which L&T believes will have news value or arouse general interest among stakeholders, is published as a stock exchange release and on the company’s website.
All publications and financial reports are available on LT’s website for at least five years from their publishing.
Rumours, Market Speculation and Data Leakages; Crisis Communications
L&T does not comment on market rumours, speculation presented by the media, share price trends, the actions of competitors or customers or analysts’ forecasts. The company does not comment on unpublished or ongoing business transactions either. If insider information, the publishing of which has been postponed, has leaked before it is published, its confidentiality can no longer be guaranteed or the preconditions for postponing the publishing of the information are not otherwise met, L&T will immediately publish a stock exchange release about the matter.
In a situation where the rumour is evidently connected with insider information, whose publishing has been postponed, and is accurate enough to indicate that the confidentiality of the information can no longer be guaranteed, L&T will publish a stock exchange release concerning the matter as soon as possible.
The company’s crisis communication guidelines are followed in case of a crisis.
Responsibilities and Spokespersons
L&T’s President and CEO and CFO are responsible for contacts with investors, shareholders and analysts. Inquiries to the Board of Directors from capital market participants are directed to the Chairman of the Board. Where necessary, the Chairman either replies to them or directs them to the President and CEO.
Other persons are not entitled to give statements about the company’s finance. The contact details of responsible persons are found on the company’s investor pages.
Communications and contacts with the capital markets are coordinated by investor communications, which acts under the CFO. Depending on case, other representatives from the company can participate in the investor relations function.
Policies Followed in Investor and Analyst Meetings
L&T arranges a briefing for analysts and investors in connection with publishing its financial statements release, half-year report and interim reports. Investors are also met in analyst and investor meetings, during analyst and investor visits to the company and in roadshows arranged by brokerage firms.
The discussions held at the meetings are based on previously published information or information generally available on the markets. The purpose of the discussions is to provide background information about L&T and its business environment.
Silent Period
Meetings are not arranged and L&T’s representatives do not comment on the company’s financial position or future outlook between the end of the period and the publishing of the stock exchange release for that period. An exception to the rule for a silent period is the Annual General Meeting arranged during the silent period and providing information on major business transactions with a stock exchange release during the silent period. In these situations, information and other communications must only concern the transaction in question.
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