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
This policy describes the goals, responsibilities, and organization of Lassila & Tikanoja Oyj's (hereinafter L&T) environmental policy.
L&T's mission is to make the circular economy a reality. All our business operations build sustainable growth for the future based on the circular economy and its opportunities.
Our environmental policy covers both our own operations and the services we provide to our customers. It describes our key environmental goals, responsibilities, and organization. We comply with the legislation applicable to our operations. In addition, our operations are certified and meet the requirements of the ISO 14001 standard.
KEY OBJECTIVES
L&T's strategy is to create more value with the circular economy for our customers, personnel, and society in a broader sense. We create solutions to mitigate climate change, promote the circular economy, and preserve biodiversity. We are committed to promoting the goals of the Paris Climate Agreement and the EU Biodiversity Strategy.
Our long-term climate target is to achieve net zero by 2045 and to make a transition away from fossil fuels. In addition, our target is to increase the recycling rate of the materials to 70 percent by 2030.
PRINCIPLES
Climate Change Mitigation
We are committed to net zero targets by 2045. We encourage our partners to set their own climate targets and reduce their dependence on fossil raw materials.
We reduce emissions in our operations and value chain by promoting the use of renewable raw materials, improving energy efficiency, creating new solutions for our customers, and developing our operations with our climate targets in mind.
Sustainable Use of Raw Materials
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.
Preservation of Biodiversity
We preserve biodiversity by promoting the circular economy, preventing contamination of soil and water pollution, supporting sustainable forest use, and using chemicals sustainably. We create solutions to restore contaminated land and promote biodiversity in the built environment.
Supply Chain
We require our suppliers to take proactive steps to promote environmental responsibility. We encourage our suppliers to monitor and develop their operations, especially considering their negative environmental impacts.
Continuous Improvement of Operations
L&T's board and management are committed to achieving our sustainability targets and continuously improving sustainability. We recognize the negative environmental impacts of our operations. We develop and improve our operations together with our employees, customers, and supply chain.
We engage in open dialogue with our stakeholders, including our customers, authorities, and local actors. We monitor the environmental impacts of our operations and communicate them transparently.
RESPONSIBILITIES AND ORGANISATION
The environmental policy applies to all employees and all sectors of L&T. It is approved by the CEO and the management team of Lassila & Tikanoja Oyj.
The environmental policy is owned by L&T's Senior Vice President, Corporate Relations and Sustainability. Responsibility for implementing the policy lies with all L&T employees. L&T’s divisions and units are responsible for the implementation of the policy and the necessary allocation of resources in their respective operations.
ENTRY INTO FORCE
This policy has been approved by L&T's Group Management Team on 21.8.2024 and comes into effect immediately. The environmental policy replaces the environmental policy approved by L&T's Group Executive Board in October 2021.
The policy is updated every two years. The next update will take in place in 2026.
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.
Human Rights Policy
This policy outlines the purpose, directives, responsibilities, and organization of the Lassila & Tikanoja Group (hereafter L&T) human rights policy. This human rights policy applies to the entire L&T Group's workforce and value chain, including our suppliers and clients.
KEY TARGETS
L&T's goal is to be a safe, fair, equal, and equitable workplace. We commit to respect all internationally recognized human rights as well as national legislation and to avoid causing negative human rights impacts by acting conscientiously within our operating environment.
L&T may have both direct and indirect impacts on different groups' human rights. We have identified that L&T's operations have particularly significant impacts on the realization of human rights for three groups: our own personnel, the supply chain, and clients. We commit to identify and assess human rights impacts and risks in these groups and to address any issues that arise.
PRINCIPLES
We comply with laws, international agreements, rights, and principles in all our operations.
L&T respects the human rights defined in the United Nations Declaration of Human Rights and the rights of employees determined by the International Labour Organization (ILO), the OECD Guidelines, and the United Nations Guiding Principles on Business and Human Rights. We are committed to support the UN Global Compact initiative and its principles concerning human rights and labor rights. We also adhere to national laws, agreements, and other obligations.
We consider human rights in L&T's guiding policies and principles and instruct our staff and supply chain to act accordingly. We expect our supply chain to comply with these same statutes, agreements, policies, and principles as per the requirements of L&T's Supplier Code of Conduct. L&T may conduct audits, through third parties or ourselves, to verify compliance.
We do not tolerate human trafficking, forced labor, the use of child labor contrary to children's rights, or any form of modern slavery in our operations or supply chains. We do not expose young employees to work that is likely to harm their education, health, safety, or mental development.
Guiding requirements for our operations
Decent working conditions are a right for everyone
L&T complies with the laws and applicable collective agreements in its operations for example on working hours, minimum wages, and working conditions. Employees also have the right to sick leave, annual leave, and parental leave as stipulated by national laws and labor agreements. L&T expects the same from its supply chain.
L&T promotes a healthy work-life balance and flexible working practices whenever possible.
Ensuring L&T is a safe place to work every day
Our target is to think and act safely to prevent all workplace accidents. Our goal is also to ensure that every L&T employee and those in our supply chain have a safe and healthy work environment, allowing us to return home safely every day. We promote workplace safety by providing orientation training and proactive, consistent measures to ensure and improve safety.
Handling personal data lawfully and respecting privacy
At L&T, we handle the personal data of our personnel, clients, and possibly other stakeholders in accordance with applicable legislation, respecting their right to privacy. We ensure that our activities respect the privacy of our staff and stakeholder representatives.
We do not discriminate, and each person has a right to be themselves
L&T has a zero-tolerance policy for all forms of bullying, harassment, inappropriate behavior, and discrimination within our operations and supply chain. We do not discriminate based on gender, pregnancy, childbirth, gender identity, gender expression, age, origin, nationality, language, religion, belief, opinion, political activity, trade union activity, family relations, health status, disability, sexual orientation, or any other personal characteristic. Race, ethnicity, skin color, and national or social origin are also prohibited grounds for discrimination.
We set our own targets related to promoting an equal and equitable work community in our equality and equity plans and regularly monitor their progress.
We respect freedom of association throughout our chain
We respect our employees’ freedom of association and right to bargain collectively. We understand that freedom of association means the choice to organize or not to organize professionally. These are equally strong fundamental rights, and we respect one another's decisions regarding freedom of association.
Addressing misconduct and implementing necessary corrective actions
Any L&T employee, member of the supply chain, client, or individual associated with our stakeholder groups can report any suspicions of misconduct or behavior contrary to ethical principles through a Whistleblowing channel.
All reports are treated with care, thoroughly investigated, and transparently reported in such a way that does not lead to negative consequences for the whistleblower. If we find direct human rights violations in our operations, we strive to prevent broader effects through corrective measures and, where possible, rectify any damage caused. By thoroughly assessing our practices and implementing subsequent corrective measures, we ensure that such incidents do not recur.
We also promptly investigate any human rights abuses in our procurement. We agree on corrective actions in collaboration with our partners, and their implementation is monitored, among other ways, through supplier audits. The preference is not to terminate cooperation but to work together to improve operations. Boycotting is not a primary solution as it can worsen the situation for the most vulnerable employees. We terminate collaborations if corrective actions are not undertaken.
Collaborating with stakeholders on human rights work and listening to them
We and our stakeholders, including our personnel, suppliers, clients, investors, unions, and human rights activists, share common goals for a better future and the advancement of human rights.
We engage in open, constructive discussions on promoting human rights with our stakeholders.
We listen to and meet with our stakeholders to learn and work on human rights together. We respect the views of our stakeholders on human rights promotion and consider them when developing our operations.
Identifying and assessing our human rights risks and reporting transparently on our human rights work
We have identified potential and actual human rights risks and impacts in our staff, supply chain, and clients, considering particularly vulnerable groups through human rights risk assessments. Our assessment considers the severity and probability of human rights risks.
We conduct regular human rights risk assessments and report on our human rights impacts and risks both internally and publicly as part of our sustainability reporting.
We implement the principles stated in this human rights policy to our staff and value chain through communication and training.
RESPONSIBILITIES AND ORGANIZATION
The human rights policy is approved by L&T's Board of Directors. L&T's management team is committed to respecting and promoting human rights.
Responsibility for the human rights policy lies with the HR Director of the L&T Group. The policy covers all L&T Group companies and sectors in all countries of operation and applies to all staff. We require our subcontractors and other external labor suppliers to comply with the principles outlined in this L&T human rights policy.
L&T's sectors and units are responsible for the implementation of the policy and for allocating the necessary resources within their operations.
EFFECTIVE DATE
This policy was approved by the L&T Group Board of Directors at their meeting on September 11, 2024, and is effective immediately.
The policy is reviewed every two years. The next update is due in 2026.
Key principles and guidelines related to the policy:
- L&T's Code of Conduct
- L&T Supplier Code of Conduct
- L&T's Personnel Policy
- L&T's Occupational Safety Policy
- L&T's Data Protection Policy
- L&T's Quality Policy
- Company-specific diversity plans of L&T companies
- L&T's guidelines for preventing suspected harassment, inappropriate behavior, discrimination, and bullying at work
- L&T's Whistleblowing channel guidelines
- L&T's occupational safety action program
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
This Policy describes the objectives, responsibilities and organisation of the Occupational Safety Policy of Lassila & Tikanoja plc (hereinafter referred to as "L&T").
L&T’s mission is to make the circular economy a reality in a safe and sustainable way. Our Occupational Safety Policy covers both our own operations and our supplier network. It describes our key occupational safety objectives, responsibilities and organisation. We comply with the legislation applicable to our operations as well as orders and regulations issued by the authorities. Our operations are also certified and meet the requirements of the ISO 45001 standard. Occupational safety objectives are included in the objectives of the L&T sustainability programme.
KEY OBJECTIVES
The goal of our occupational safety operations is to guarantee a safe workplace for all personnel. We are committed to the idea of zero accidents and we believe that all accidents and damage can be prevented. 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.
PRINCIPLES
Preventing accidents through proactive occupational safety work
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 personnel 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 and take corrective action, including occupational accidents involving our subcontractors and leased employees in L&T’s tasks.
Common ground rules, common goals
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. We monitor and report on occupational safety progress in a transparent and public way to all stakeholders.
Occupational safety as an integral part of daily management
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.
Supply chain involved in health and safety work
We expect our suppliers to commit to L&T’s safety practices and take the initiative to promote occupational safety. It is possible for both subcontractors and leased employees to report their safety observations to the L&T safety system.
Continuous development of occupational safety
L&T’s Board of Directors and management are committed to the achievement of our sustainability targets and the continuous development of sustainability. 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 personnel 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.
RESPONSIBILITIES AND ORGANISATION
The Occupational Safety Policy applies to all personnel and all of L&T's divisions. It is approved by Lassila & Tikanoja plc’s President and CEO and the Group Executive Board.
The Occupational Safety Policy is owned by the Property and Risk Management Director at L&T. The responsibility for implementing the Policy lies with all L&T employees. L&T's divisions and units are responsible for the implementation of the Policy and the allocation of the necessary resources in their respective operations.
ENTRY INTO FORCE
This Policy has been approved by L&T's Group Executive Board on 21.08.2024 and it enters into force immediately. The Policy replaces the Occupational Safety Policy approved by L&T's Group Executive Board in October 2021.
The Policy is updated every two years. The next update will take place in 2026.
Quality Policy
This Policy describes the objectives, responsibilities and organisation of the Quality Policy of Lassila & Tikanoja plc (hereinafter referred to as "L&T").
L&T’s mission is to make the circular economy a reality in a sustainable and high-quality way. Our Quality Policy covers both our own operations and the services we provide to our customers. It describes our key quality objectives, responsibilities and organisation.
We comply with the legislation applicable to our operations as well as orders and regulations issued by the authorities. Our operations are also certified and meet the requirements of the ISO 9001 standard. Quality objectives are included in the objectives of the L&T sustainability programme.
KEY OBJECTIVES
L&T's strategy is to support our customers’ sustainability, create excellent customer experiences and develop the best services in our industry. We carry out good administration in our own operations. We act appropriately and transparently throughout the value chain.
Our quality promise has been developed together with customers and L&T personnel:
- We keep our word.
- We make your life easier.
- We help you succeed.
We live up to our promises both in our work with customers and in our own operations. Our goal is for the Net Promoter Score, NPS of our services to be above 50 by 2026.
PRINCIPLES
Customer experience and employee satisfaction as indicators of the quality of operations
We measure customer satisfaction with the Net Promoter Score (NPS) of the services as part of L&T’s strategic objectives. The NPS results are also available to all our personnel in a transparent way. Our success as a quality employer is reflected in the Employee Net Promoter Score eNPS. The target setting for both indicators are included in the L&T sustainability and stakeholder targets.
Service quality indicators and targets are defined together with the customer
L&T offers a very wide range of services. The divisions and business lines have quality indicators in place to monitor and develop the service quality of the business in question in cooperation with our customers. Quality is monitored regularly with our customers in accordance with our cooperation models.
Quality is part of the work of all L&T employees
We recognise that good quality and customer experience starts with us all. Every L&T employee has the right and duty to highlight the overall aspects of quality development. We strive to support the continuous development of our personnel by providing them with the necessary training in addition to adequate induction.
While we do everything we can to avoid mistakes, we recognise that they can sometimes happen. We are committed to taking responsibility for our errors and correcting them appropriately. L&T uses an electronic complaint processing system that is shared by the entire Group. We record all complaints in the system and handle them according to uniform instructions.
Audits ensure continuous development and improvement
We conduct both external and internal audits of our management systems on an annual basis in accordance with our audit plan. We record all findings and suggestions for improvement from these audits in the L&T system, which also records their handling and corrective actions with the schedules and person in charge.
We want to be transparent in our own operations and therefore, as part of our customers’ supply chain, we also participate annually in customer audits and various voluntary third party assessments.
Supply chain
When selecting a supplier, we put emphasis on the quality and reliability of the supplier’s operations, as well as ethical operating principles in addition to cost efficiency. When assessing suppliers, we use e.g. self-assessment. For the most significant suppliers, we monitor operations using separately set indicators. We also conduct risk-based supplier audits.
Continuous development of operations
L&T’s Board of Directors and management are committed to continuous improvement of operations and the quality management system and create the conditions for achieving quality objectives. We continuously develop and improve the quality of our operations together with our personnel and customers.
RESPONSIBILITIES AND ORGANISATION
The Quality Policy applies to all personnel and all of L&T's divisions. It is approved by Lassila & Tikanoja plc’s President and CEO and the Group Executive Board.
The Quality Policy is owned by the Property and Risk Management Director at L&T. The responsibility for implementing the Policy lies with all L&T employees. L&T's divisions and units are responsible for the implementation of the Policy and the allocation of the necessary resources in their respective operations.
ENTRY INTO FORCE
This Policy has been approved by L&T's Group Executive Board on 21.08.2024 and it enters into force immediately. The Quality Policy replaces the Quality Policy approved by L&T's Group Executive Board in October 2021.
The Quality Policy is updated every two years. The next update will take place in 2026.
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.
Download the Code of Conduct for Suppliers
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.
You may also be interestedin these
L&T's Culture
At L&T, daily work is guided by guidelines and principles that create a strong foundation for our culture. Get to know the factors that drive our culture.
Governance: fair and reliable operations
Our goal is to ensure that no serious damage occurs in the company's operations. We require responsible behavior from our personnel and suppliers.