We have identified the following areas as relevant where we together with the industry can make a positive impact.
- Continuously develop technology enabling sustainable cities, communities and homes where reliable connectivity is a given
- Contribute to improved health and wellbeing by the enabling of the development e-health and home care technology and applications
- Assist in improving the quality of education by providing and enabling robust and high-speed products and infrastructures
- Reduce on traveling and commuting supported by a well-established infrastructure and applications reducing the CO2 footprint
- Build long term partnerships governing for the possibilities to improve over time
Business Continuity Management policy (BCP)
The Inteno Group AB Business Continuity Management process aims to:
- Identify and mitigate potential threats in the operations
- Identify the impact on operations if those threats are realized
- Provide a framework for building organizational resilience
- In times of disruption, safeguard the Inteno Group stakeholders and as soon as possible get business back to a normalized situation.
We commit to comply with all applicable legal, statutory, corporate and contractual requirements.
We commit to create and maintain a company-wide Business Continuity Plan including risk and impact analyses.
We provide adequate training, information and instructions with regards to Business Continuity as well as crises management and workplace health and safety.
We communicate to our customers, suppliers, employees and owners our commitment and information regarding our Business Continuity Plan.
We periodically review the policy for continued sustainability and applicability.
Inteno Group endeavors to work in accordance with the principals of Business Continuity as stipulated in the international standard ISO 22301.
Corporate social responsibility policy (CSR)
Ensuring ethical business conduct at the highest standards
The Inteno Group AB (hereinafter “Company”) is committed to conducting its business at the highest ethical levels. We have adopted this Code of Conduct to ensure all employees and affiliates are aware of what is expected from them.
Scope of the Code
It is important that goods and services handled by Company are produced and provided in an ethical way. Therefore, the Company expects this Code to be applied and upheld in the organizations’ every affiliate, Suppliers, sub-Suppliers and Vendors and producer to the Company, notwithstanding if the Suppliers and Vendors delivers services or goods.
Legal compliance and the Code
The Company complies with local laws and regulations of each country in which we operate. This Code sets up a minimum requirement. If provisions in other laws, regulations or rules, be it local, national or international, have a more stringent position to the Corporate Responsibility matters mentioned in this Code, those shall be observed and complied with.
Suppliers and vendors
Our contractual relationships with suppliers and vendors, dealers and customers are important elements of the Company’s success. Supplier, vendor selection and purchasing decisions must be made objectively and in the Company´s best interests, striving for the best deal by evaluating costs, requirement fulfillment, expected delivery capability, quality and other relevant factors. Any agreement with a supplier and vendor should be concluded according to the Company Purchasing Procedures and Ethical Principles.
Negotiations with suppliers, vendors and dealers should be conducted in a professional manner, engaging the Company employees and with the use of the four-eye principle. Our people must always be sure that business decisions are made without any unjustified influence from a third party. Suppliers and vendors which are proven to attempt to unduly influence the Company´s purchasing decisions may be excluded from any future transaction with the Company.
No Company employee or member of our Management Team may offer, ask, give or accept, directly or indirectly, any undue advantage for personal gain from any third party, unless it can be constituted as being within the boundaries of accepted business practices such as representation and reasonable hospitality given in the ordinary course of business.
As guidance, no single gift or benefit should exceed the value of 50 Euro. When In doubt, employees are expected to seek advice from their managers.
In most countries gifts or benefits to government employees or public officials are considered a violation of law or regulation. Company employees must not offer money or any gift to an official or employee of a governmental entity, except for symbolic gifts of insignificant monetary value provided this is allowed by local law.
The Company is firmly committed to fair competition and open markets. We remain firm believers that free and fair competition works in our favor allowing us to provide the Best Deal, i.e. we deliver expected quality and price leading communication solutions to our customers.
Conflict of interest
Business decisions are always made in the best interest of the Company. The power invested in us by the Company may not be used for other goals than furthering Company´s interests. Personal relations or considerations may never influence our decision making. This includes not only potential gains for us, but also for our relatives and friends.
To avoid risk of conflict of interest the following applies: – Employees may not, without the Company’s written consent, work outside the Company in any capacity (e g employment, consultancy, Board membership). – If there is any risk, however small, for conflict of interest, employees are expected to immediately inform their manager.
Grandparent and “4 eyes” principle
To further limit the risk of conflicting interests and to make sure that business decisions always are made in the best interest of the Company, all contractual relationships of material significance between the Company and a third party (e.g. suppliers, vendors, dealers and partners etc.) need to be negotiated and approved in writing by at least two persons (=four-eyes principle) prior signing of the final agreement. Whenever possible the second person approving the contractual relationship should be the manager of the first approver (=grandparent principle). Final agreements shall be approved and signed in accordance with the local legal policy, however never signed by less than by two signatories jointly. In certain cases, as outlined in other policies and guidance, the grandparent principle is mandatory.
The integrity of the Company´s financial records is critical to the operation of the business and is a key factor in maintaining the confidence and trust of our shareholders. We must ensure that all transactions are properly recorded, classified and summarized in accordance with the Company accounting policies. No employee may enter or remove information in the Company’s books or records that intentionally hides, misleads or disguises the true nature of any financial or non-financial transaction or result.
Employees involved in financial reporting shall always provide full, fair, accurate, timely and understandable disclosure in reports and documents that the Company files with, or submits to, government agencies, tax authorities and in other public communications. Comments about financial reporting and prospects to external parties shall only be made by authorized official spokespersons.
The Company strongly believes in transparent and consistent corporate governance practices and abides with the applicable regulations and standards in each of its geographical markets. This protects the legitimate interests of all the Company shareholders and stakeholders.
Treating people with respect
Fair working conditions
The Company employees are entitled to fundamental human rights which shall be known, understood and respected and be applied equally. No one shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse. Forced labour, exploited or bonded labour is strictly forbidden. Employees shall not be required to lodge deposits or original identity papers as a condition for employment. Employees shall not be forced to work more than the limits on regular and overtime hours allowed by the law of the country in which they are employed.
Overtime shall be compensated at the legally required rate. All employees shall have contracts specifying the terms of employment. Children under the minimum working age established by local law or fifteen (15) years, whichever is greater, shall not be used as labour force. Employees under eighteen (18) years shall not be engaged in hazardous or heavy work, or on nights shifts.
The Company does not accept discrimination, whether active or by means of passive support, whether based on ethnicity, national origin, religion, disability, gender, sexual orientation, marital or parental status, union membership, political affiliation or age. The Company regards diversity as a lever for profitability. The ambition is to focus on behaving in a way that attracts diversity.
The rights of employees to freely associate and to bargain collectively, in accordance with the laws of the countries in which they are employed, shall be recognized and respected.
Compensation and benefits
Employees shall be paid at least the minimum total wage required by applicable national law or minimum wage agreed with trade unions including all mandated wages, allowances and benefits. All employees shall have the right to equal pay for equal work, as well as periodic holiday with pay.
Occupational health and safety Safety at work is a prioritized concern of Company. Adequate steps to prevent accidents and injury to health shall be taken by minimizing the causes of hazards inherent in the working environment and by providing appropriate safety equipment.
The individual’s personal integrity and the security of his or her personal data is important to companies in Inteno Group AB and its subsidiaries (all jointly hereinafter referred to as ”Inteno” or the ”Company”), which is responsible for ensuring that all personal data is processed properly and in accordance with applicable data protection legislation. This Integrity Policy (the “Integrity Policy“) is a consent document and describes how Inteno processes personal data. We therefore ask you to carefully read the Integrity Policy before you share your personal data with us.
2. Scope of applicability of the integrity policy
This Integrity Policy applies to individuals in the capacity of candidates, employees, customers, suppliers and other stakeholders. Different parts may be relevant to you, depending on your relationship with Inteno.
This Integrity Policy governs how Inteno collects and processes personal data for our range of services consisting of sales of CPE and Network products, software licenses and related services (consulting and technical support services) to enterprises (our “Service”). The policy also governs personal data processing for individuals at the parties with which Inteno has a business relationship, such as suppliers and customers and their representatives.
Inteno may occasionally advertise news and press releases on third party websites that are not owned or managed by Inteno. Inteno has not inspected these websites or other websites that contain links to the Inteno website. This Integrity Policy does not apply to any personal data processing that takes place on such websites and Inteno is not responsible for personal data processing on websites that are not part of Inteno’s website. Nor does the Inteno Integrity Policy apply to processing carried out by testing companies.
Inteno may occasionally advertise news and press releases to existing and prospective new customers, suppliers and partners. Such advertisement sole purpose is to generate new business with your company and Inteno is responsible for processing of personal data related to such advertisement.
3. Processing of personal data
Inteno’s personal data processing based on your relationship with Inteno is described below.
For Candidates and Employees
The purposes for which personal data is processed
Personal data is only processed for the purposes and objectives described in this Integrity Policy.
Inteno only processes personal data if such processing is necessary for providing our Service or for the other purposes described below.
Inteno processes job applicants’ and employees’ personal data to enable us to offer you the opportunity to be part of the Company (as candidate and/or employee) and manage our relationship with you as candidate and/or employee.
By accepting this Integrity Policy, you give your consent for Inteno to process your personal data in accordance with this Integrity Policy. If you do not give your consent for your data to be processed, you should not provide us with personal data. Below you will find information on the types of personal data that Inteno processes and how Inteno can obtain/acquire that information.
The personal data that Inteno processes on candidates is based on the details you yourself provide to Inteno via the Inteno website, e-mail and through contact with Inteno personnel to allow Inteno to provide review you as a candidate and potential future employee of Inteno. Inteno will not process your personal data unless you have first given your approval by accepting the Inteno Integrity Policy.
The personal data we may process on you includes data such as your name, address, e-mail address, personal ID number, grades, certificates, training and work experience, photographs, results of tests, information om background checks, results of drug tests, information from referees (such as assessments and health, observations on absence due to illness, for example) and information that is necessary for reviewing you as a candidate and potential future employee of Inteno.
If you agree to be photographed or provide a photograph of yourself without being asked to do so by Inteno, you are giving your consent for Inteno to process any such photograph.
The personal data we will process on you includes contact details for relatives, salary and account details in addition to the data specified in section Candidates.
Inteno may also need to process sensitive personal data such as information on your health. Health data may need to be processed to allow Inteno to comply with its obligations as an employer, for example.
Saving personal data
The length of time for which personal data is saved depends on the type of personal data in question and the purpose for which it is processed.
Inteno has to save some personal data related to you as an employee as this is provided by law, and Inteno consequently has to comply with any such legislation.
Inteno will, as a general rule, save personal data relating to:
- information linked to the application and recruitment process (e-mail applications), during the current year for the most recent activities and for two (2) years thereafter;
- contract for employment, during current year for the most resent activities and for ten (10) years thereafter;
- client and supplier agreements and information on business events such as information on timesheets, participants, assignments, salaries, invoices, declarations, accounts during the term of the agreement and thereafter for ten (10) years; and
- control data until Inteno’s pension obligation has ceased.
For Customers or Suppliers
Purposes for which personal data is processed
Personal data is only processed for the purposes and objectives described in this Integrity Policy. If you choose not to provide certain personal details, it may affect the use of the Service or the provision of the Service. Inteno only processes personal data if such processing is necessary for the Service and for services provided by suppliers for Inteno or for other purposes as specified below. Inteno processes personal data on Customers’ and Suppliers’ employees:
- to enable you to take advantage of the Service or provide other services for Inteno;
- to manage our relationship with you;
- to enable Inteno to manage its obligations in relation to you or the individual concerned, deal with cases of alleged discrimination, deal with disputes and complaints; and
- to facilitate future business relationships.
By accepting this Integrity Policy, you give your consent for Inteno to process, where applicable, your personal data in accordance with this Integrity Policy.
Inteno can also ask individuals to provide more personal information than is specified herein. Personal information that is provided/processed through a specific approval will also be covered by this Integrity Policy.
Inteno may process contact persons’ personal data. Such data includes their name, address, e-mail address, post, responsibilities and other data necessary for providing and monitoring the Service and for facilitating future business relationships.
Inteno may process contact persons’ and other employees’ personal data. Such personal data includes the information specified in section Customers and other data necessary for providing and monitoring the Service, for ensuring satisfactory supply of services to Inteno and for facilitating future business relationships.
Storage of personal data
The length of time for which personal data is saved depends on the type of personal data in question and the purpose for which it is processed. Inteno does not save personal data for longer than is necessary for the purposes for which it was collected, unless otherwise provided by law.
Inteno will, as a general rule, save personal data contained in:
- application and recruitment processes during the current year for the most recent activities and for two (2) years thereafter;
- customer and supplier agreements and information on business events such as information on timesheets, participants, assignments, salaries, invoices, declarations and accounts, during the term of the agreement and thereafter for ten (10) years;
Personal data for marketing purposes
The consent given also covers the fact that the information that you supply to Inteno can be used by Inteno and companies in Inteno for marketing and market research purposes in order to provide candidates, employees, customers and suppliers with an enhanced experience and improve and optimise the quality of the Service (for example, by displaying content that may be of interest to you and providing information that is more relevant to you) and generating new business to Inteno.
If you no longer wish to receive marketing, you can contact us and indicate that you do not wish to be contacted for marketing purposes.
Use of the Inteno website and cookies
4. Protection of personal data
Inteno has adopted the appropriate technical and organizational measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration and destruction. To ensure that personal data is processed in a secure, confidential manner, we use data networks that are protected against hacking by such means as firewalls and password protection according to industry standards. Relevant Inteno employees and suppliers are bound by confidentiality agreements and are obliged to comply with Inteno’s rules for information and IT security, this Integrity Policy and other internal regulations that further govern the processing of personal data.
5. Sharing of personal data between companies in Inteno Nordic
As a general rule, Inteno shares personal data obtained from candidates, customers and suppliers’ personnel with all companies in Inteno to enable us to conducting our business. Employee related personal data is only available to very few individuals – those that need the information to handle administrative aspects of an employment such as paying out salary.
As a general rule, sensitive personal data is not shared between the companies in Inteno. Before sensitive personal data is shared, Inteno always carries out an assessment to ascertain whether it is necessary for the sensitive personal data to be shared for the purpose for which it was collected and whether further consent is required in order for the data to be shared or whether legal support for sharing the personal data exists.
6. Sharing of personal data outside Inteno
Inteno will not sell, disclose or distribute personal data to third parties, except as specified in this Integrity Policy. Within the framework of the Service, personal data may be forwarded to an Inteno customer, supplier, contractor and partner if such is necessary for the performance and supply of the Service. Inteno may occasionally also disclose your personal data to other third parties such as Inteno’s suppliers for business activities such as salary administration or suppliers that manage job searches on our behalf.
Parties to which Inteno may disclose personal data may be located outside the European Economic Area, EEA, which means that personal data may be transferred to countries outside the EEA. If Inteno discloses personal data to Inteno suppliers outside the EEA, we will take steps to ensure that the personal data continues to be protected and we will also take the necessary steps to transfer personal data to countries outside the EEA in a lawful manner.
Furthermore, we may disclose personal data if we are required to do so by law or through a court order or if such disclosure is otherwise necessary to cooperative with a legal investigation.
7. Personal Data Controller
Inteno Group AB and its subsidiaries, Id No 559058-0634, Stensätravägen 13, S-127 39 Skärholmen, Sweden, is the personal data controller for processing your personal data and is responsible for ensuring that such processing takes place in accordance with applicable legislation.
8. Inteno as a Personal Data Processor
Inteno is the personal data controller for Inteno personal data, but situations may occur in which Inteno is not the personal data controller, but only a personal data processor for third parties. When Inteno processes personal data as a personal data processor, the data is processed on behalf of a third party and Inteno is then bound by the instructions that Inteno received from the personal data controller. Inteno will always ensure that processing takes place in accordance with applicable legislation and as far as possible in accordance with this Integrity Policy.
9. Your rights
As an individual, you have the right to obtain information on what personal data Inteno processes on you and information on the scope and purpose of such processing by submitting a signed application in writing to Inteno at the above address (under “Personal Data Controller”). As an individual, you also have the right to request at any time that we block, delete or correct your personal information. You have the right at all times to revoke any consent you have given and inform us that you do not wish us to continue to process your personal data.
10. Amendments to this integrity policy
Inteno reserves the right to revise this Integrity Policy from time to time. The date of the most recent amendment is specified at the end of the Integrity Policy. If we carry out any amendments to the Integrity Policy, we will publish those amendments at the website. It is therefore recommended that you read this Integrity Policy regularly in order to note any amendments. If we amend our Integrity Policy so that it clearly differs from what was specified when your consent was obtained, we will notify you of these amendments and, if necessary, ask you to give your consent once again for Inteno to process your personal data.
If you have any questions regarding this Integrity Policy or our use of your personal data, please contact us at gdpr(a)intenogroup.com.
Integrity Policy updated on May 25, 2018.