Overall Purpose of this Guideline
Skanska Reporting Units (comprising one or more Skanska Group companies or Skanska units that report financial results directly to Skanska AB, as well as Skanska AB) shall use this Guideline in implementing the Skanska Code of Conduct. All Skanska Group companies are collectively referred to as Skanska. Provided that the core principles of the Code of Conduct are not eroded,this Guideline shall not restrain any Skanska Reporting Unit from addressing local, regional or other concerns. The Code of Conduct, this Guideline and Group Policies constitute Skanska’s Code of Conduct Program, as do policies, procedures, training and reviews developed by each Skanska Reporting Unit.
All Skanska employees shall comply with the Code of Conduct, this Guideline and their respective Skanska Reporting Unit’s Code of Conduct Program.
This Guideline is, inter alia, intended to implement Skanska's commitments under the ten principles of the UN Global Compact. The text is available here.
Skanska's policy manuals and employment contracts, where applicable, shall reflect Skanska’s commitment to the Code of Conduct.
1. General Principles
Code of Conduct Principle: The key responsibility of all Skanska Group companies, hereinafter referred to as Skanska, is to develop and maintain an economically sound and prosperous business. Skanska assumes its responsibilities where we have effective control. These include our responsibilities toward the communities and environments in which we operate, toward our employees, business partners and society in general.
Skanska's strategy for implementing the Code of Conduct is to make compliance an essential responsibility of each Skanska Reporting Unit. The responsibility for directing the implementation and achieving compliance by Skanska employees rests with the Head of each Skanska Reporting Unit, but shall be subject to the overall supervision by Skanska AB's Ethics Committee.
Each Skanska Reporting Unit shall:
- establish a Code of Conduct Program together with clear lines of authority to support compliance with the Code of Conduct as specified in this Guideline;
- institute a communication plan to ensure that relevant information on the Code of Conduct reaches all Skanska employees and Skanska clients, suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners conducting business with Skanska;
- organize an internal Ethics Commitee, reporting to the Unit’s management. The Ethics Committee shall be composed of Skanska Reporting Unit personnel including, at least, one in-house legal counsel, one human resources manager and a senior operations manager. The Ethics Committee shall have the power:
– to provide guidance on ethical queries; and
– to investigate alleged breaches of the Code of Conduct and recommend actions by management; and
- provide training on the Code of Conduct and this Guideline to all new employees not later than three months from their starting date at Skanska. All other employees shall be trained, or re-trained, not less than every two years.
The Skanska Reporting Unit shall maintain accurate records of completed training sessions, including the names of all employees undergoing each training session. Employees shall, after each training session, be required to attest that they:
- participated in the training;
- understand the Code of Conduct; and
- agree to act accordingly in their activities as Skanska employees.
1.1 Integrity and Ethics
Code of Conduct Principle: We are committed to doing business with a high degree of integrity and ethics.
Skanska employees shall exercise good judgment, honesty and integrity as they perform their duties to avoid even the appearance or suspicion of improper behavior.
Acting with "a high degree of integrity and ethics" includes doing what is right and always striving to treat each other and Skanska’s clients, suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners fairly and with respect. Skanska employees could apply the following test in relation to a certain course of action:
- Is it legal?
- Is it consistent with the Skanska Reporting Unit’s Code of Conduct Program?
- Will it reflect well on me and Skanska?
If in doubt, Skanska employees should discuss the issue with their immediate superior. If the employee remains in doubt, he or she should address the issue with the Skanska Reporting Unit's in-house legal counsel, Ethics Committee, Human Resources department or Sustainability function.
Additional guidance for maintaining our adherence to a high degree of integrity and ethics is found in Section 3.
1.2 Compliance with Laws
Code of Conduct Principle: We comply with legal requirements that apply in the countries where we do business.
We comply with legal requirements in countries, communities and environments in which we operate, even where those requirements exceed the standards contained in the Code of Conduct. Conversely, we apply the standards of the Code of Conduct even where those standards (such as minimum employment age requirements) exceed, but do not conflict with, local legal requirements. Custom or local practices may never take precedence over legal requirements.
Each Skanska Reporting Unit shall provide guidance to its employees with respect to national and local laws applicable to their work, and Skanska employees are responsible for familiarizing themselves and complying with such laws. Deliberate violations of such laws by a Skanska employee in the performance of his or her work may subject him or her to sanctions, including dismissal where appropriate.
Questions regarding compliance with national or local legal requirements should be referred to the Skanska Repor-ting Unit’s in-house legal counsel or Ethics Committee for guidance.
1.3 Human Rights
Code of Conduct Principle: We respect the United Nations Universal Declaration of Human Rights and recognize our responsibility to observe those rights that apply to our performance toward our employees and the communities in which we operate. This commitment includes activities that relate to the rights and entitlements of Indigenous Peoples.
The Universal Declaration of Human Rights adopted by the United Nations in 1948 is the most authoritative enumeration of human rights. The text is available here. The articles of particular relevance to Skanska are the following: Articles 1, 2 and 7 concerning dignity, equality and non-discrimination; Article 4 concerning forced labor; Article 18 concerning freedom of thought, conscience and religion; Article 19 concerning the right to freedom of opinion and expression; Article 23 concerning the rights to free choice of employment, good working conditions, equal pay for equal work, fair compensation sufficient to enable workers and their families to maintain an existence of human dignity, and to join and form trade unions; Article 24 concerning the right to reasonable working hours and paid periodic holidays; and Article 25 concerning the right to an adequate standard of living and social security.
Universal standards with respect to labor were further developed in a series of conventions of the International Labour Organization of the United Nations (the “ILO”). The text is available here. The provisions of these Conventions particularly relevant to Skanska are described in Section 2 of this Guideline pertaining to Employee Relations.
Skanska’s adherence to the principles of the Universal Declaration of Human Rights and the ILO Conventions requires efforts to avoid suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners whose practices violate these principles.
1.4 Stakeholder Relations
Code of Conduct Principle: We are open-minded in dialogue with those who are affected by our operations. We respond to inquiries from external parties and communicate with affected parties in a timely and effective manner.
We strive to inform and initiate dialogues with our clients, suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners as well as the general public and others likely to be impacted by our projects. We shall also involve such parties in our efforts to avoid or mitigate adverse impacts connected to the projects. In all situations where a major negative impact is anticipated we will identify the stakeholders affected and establish channels to enable effective, honest and respectful communication in the matter.
1.5 Suppliers, Subcontractors, Intermediaries, Joint Ventures and Other Partners
Code of Conduct Principle: Within our sphere of influence we endeavor to ensure that in our projects, our suppliers, subcon-tractors, agents, joint ventures and other partners abide by the principles set out in our Code of Conduct.
Skanska Reporting Units shall provide their suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners with an appropriately translated copy of the Code of Conduct, secure their commitment to adhere to its principles, or an equivalent of its relevant core principles, in their business with Skanska and retain effective remedies, such as a contractual option of termination in the event of their failure to do so in any material respect. The form of such adherence and option to terminate shall reflect standard contractual language prepared by in-house legal counsel of the applicable Skanska Reporting Unit.
Each Skanska Reporting Unit shall, when it deems appropriate, conduct due diligence in evaluating suppliers, subcontractors, intermediaries and joint venture partners and other cooperation partners’ overall conformity with the principles set out in the Code of Conduct prior to entering into an agreement with them. Additional guidance with respect to corruption prevention in relationships with intermediaries is found in Section 3.2.
2. Employee Relations
Code of Conduct Principle: A strong and consistent relation-ship with all employees, built on mutual respect and dignity, is of vital importance to Skanska. Employment conditions offered to employees will at least meet minimum requirements of national legislation and relevant ILO conventions.
It is a core value in Skanska, that all employees are respected equally. We strive to work as one team and to foster open, forthright and respectful communication among all employees. In Skanska every employee should feel comfortable to speak his or her mind.
2.1 Safe and Healthy Working Conditions
Code of Conduct Principle: We provide a safe and healthy working environment and are committed to continual improve-ment.
Skanska’s goal is to promote sound personal safety and accident prevention practices at all its projects and to always seek to improve upon its safety and accident prevention record. One of the tenets for Skanska’s health and safety practices is visible leadership.
Each Skanska Reporting Unit is responsible for pur- suing this goal through strict and consistently enforced safety procedures, including health and safety training for all employees on our sites (including employees of our subcontractors) adapted to their local work situations and environments. Management systems to ensure continual improvement and adequate follow-up shall be in place in each Skanska Reporting Unit.
2.2 Equal Opportunities and Nondiscrimination
Code of Conduct Principle: We provide equal opportunities to people without regard to race, color, gender, nationality, religion, ethnic affiliation or other distinguishing characteristics. We do not allow discrimination or harassment.
Skanska’s commitment to equal employment opportunities encompasses the employment process, training, promotion and all other terms and conditions of employment. Skanska does not accept any form of discrimination or harassment aimed at, or conducted by, any of its employees.
2.3 Employment Grievance Process
Code of Conduct Principle: We provide means for employees and other persons involved with Skanska to report legitimate concerns and grievances in a manner that ensures proper review and action, without retaliation.
Skanska employees are encouraged to bring to the attention of management all suspected breaches of the Code of Conduct. If such suspected breaches involve either (i) serious ongoing violations of law, or (ii) other serious ongoing breaches of the Code of Conduct which may have a material adverse effect on Skanska, employees are required to report this information to management. Reports may be made to their immediate superior or to the Skanska Reporting Unit’s in-house legal counsel, Ethics Committee or the Human Resources department or to other channels available within the respective Skanska Reporting Unit, if any. Other persons (than employees) involved with Skanska may report suspected breaches of the Code of Conduct to the local operations manager or through other channels available, if any, within the respective Skanska Reporting Unit. If the reporter be- lieves that none of the aforementioned options would be feasible or appropriate under the circumstances and the issue relates to a serious breach of the Code of Conduct, reports can be made to the Skanska Code of Conduct Hotline as described in Section 5.
No one shall suffer any adverse effects upon their employment or other retaliation for reporting suspected breaches of the Code of Conduct, but employees may incur employment sanctions as the result of (i) failing to report serious breaches, as required above, or (ii) reporting information which they undoubtedly know to be false at the time of the report.
2.4 Right to Labor Union Affiliations
Code of Conduct Principle: We recognize employees’ rights to form or join trade unions in accordance with applicable national laws and principles.
Skanska shall seek to maintain good relations with labor organizations, trade unions and workers' representatives and complies with all applicable laws governing its relationship with its employees. This principle does not require, however, that all Skanska employees be members of such organizations except where required by applicable laws or agreements.
2.5 Employee Training and Education
Code of Conduct Principle: We provide training and education opportunities for employees that support their current and future work plans.
Skanska will not employ anyone below the age of 15 or below any higher minimum age specified by local law. Skanska shall also require written contractual commitments, as appropriate, by its suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners, to reject any such practices. Such commitment shall reflect standard contractual language prepared by in-house legal counsel of the applicable Skanska Reporting Unit.
2.7 Forced or Slave Labor
Code of Conduct Principle: We do not use forced labor, slave labor or other forms of involuntary labor at our work sites. We do not allow any practice that would restrict free movement of employees.
Although slave labor is rare and easily recognized and avoided, labor can be forced by various means such as: debt bondage which forces individuals to work to pay off alleged debts to their employers; employment conditioned upon employee deposits of funds which are subject to forfeiture if the employee departs the employment; employers’ retention of employees’ identity documents; and unlawful employer holdbacks of portions of wages.
Skanska firmly rejects any practices that impede freedom of movement of employees and shall, as appropriate, require equivalent written contractual commitments by its suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners. Such commitments shall reflect standard contractual language prepared by in-house legal counsel of the applicable Skanska Reporting Unit.
The above quoted Code of Conduct principle does not preclude a Skanska Reporting Unit’s involvement in prison labor programs where enrolment is voluntary and is part of an officially sanctioned program for the rehabilitation of prison inmates. Skanska Reporting Units should, however, refrain from any involvement with prison labor in countries where it involves involuntary exploitation of prisoners or is a means for violating basic human rights such as freedom of expression, association and movement. Additional guidance with respect to basic human rights is found in Section 1.3 above.
3. Behavior in Our Marketplace
Code of Conduct Principle: Corruption, bribery and unfair anti-competitive actions distort markets and hamper economic, social and democratic development. Skanska does not tolerate such activities.
Business ethics are pertinent to all aspects of Skanska’s business. The Code of Conduct and this Guideline focus on the following significant ethics matters: competition law; the payment and acceptance of bribes, political contributions and facilitation payments, proper accounting practices regarding both financial and business transactions; and client data protection. To the extent necessary, policies governing ethical conduct in other aspects of our business shall be estab- lished by each Skanska Reporting Unit consistent with the Code of Conduct and this Guideline.
3.1 Competition Law
Code of Conduct Principle: We shall not act contrary to applicable competition laws.
Competition guidance is set forth in the following detailed compliance manuals: the Competition Law Compliance Manual for European Union and Norwegian Skanska Group companies; the Antitrust Law Compliance Manual for United States Skanska Group companies; and the Competition Law Compliance Manual for Latin American Skanska Group companies.
Skanska Group companies are required to consult the in-house legal counsel of the Skanska Reporting Unit before entering into joint venture or other business cooperation with non-Skanska parties in order to ensure that the business does not conflict with applicable competition laws. Each Skanska Reporting Unit shall have policies in place that require prior approval of senior management of such Unit before entering into joint venture or other business cooperation with non-Skanska parties.
3.2 Corruption and Bribery
Code of Conduct Principle:
a. We shall not, directly or indirectly, offer or give any undue payment or other consideration to any person or entity for the purpose of inducing such person or entity to act contrary to prescribed duties in order to obtain, retain or direct business or to secure any other improper advantage in the conduct of Skanska’s business.
b. We shall not, directly or indirectly, solicit or accept any undue payment or other consideration that is given for the purpose of inducing us to act contrary to prescribed duties.
General guidance. Skanska is committed to ensuring that its business operations are free from the influence of corruption. Additional implementation responsibilities are pre-scribed in Section 1.5.
The portions of this Guideline related to the prevention of corruption and bribery are intended to implement Skanska's commitments under the UN Global Compact 10th Principle, the text is available here, and World Economic Forum Partnering Against Corruption Initiative (PACI), information is available here, which was derived from Transparency International’s Business Principles for Countering Bribery.
Intermediary. An intermediary is a person or entity retain-ed by a Skanska Group company and authorized to act for or represent the company in furtherance of its business in- terests, such as a business agent, business development consultant, lobbyist, adviser or other person or entity serving a similar function. All Skanska Reporting Units shall exercise great diligence in assessing the reputation for business integrity of prospective intermediaries and shall have policies in place that require prior approval of senior management of such Unit for entering into an agreement with an inter-mediary. Skanska’s anti-corruption principles prohibit all illegal payments or gifts made through or by intermediaries for the purpose of obtaining, retaining or directing business for Skanska. Any commission or fee to be paid to an intermediary must be:
- reasonable in amount in relation to the extent and nature of the services actually performed by the intermediary;
- paid in accordance with the Skanska Reporting Unit's customary payment procedures and recorded properly on the company’s accounts; and
- governed by a written agreement with the intermediary, which specifically prohibits illegal payments or gifts and provides for immediate termination of the agreement and cessation of future fee payments in the event of misconduct.
Severe penalties may be imposed upon Skanska if an intermediary engages in misconduct while representing a Skanska Group company. Skanska employees may also be subject to sanctions if they have authorized the wrongful conduct of an intermediary or retained the intermediary knowing that misconduct would occur or have consciously ignored obvious evidence of the likelihood of misconduct.
Facilitation payments. Skanska does not permit so-called “facilitation payments” to induce the timely performance of duties by government employees. Lawful payments to a government agency are not “facilitation payments.”
Political contributions. Skanska does not permit the offering or giving of political contributions by a Skanska Group company, joint venture or other business cooperation of which a Skanska Group company is a partner or shareholder, unless such contribution is approved by the CEO of Skanska AB. The prohibition does not apply to political contributions by employees in their own names using their personal funds in conformity with applicable laws.
Corporate hospitality and gifts. Limited corporate hospital-ity is a widely accepted aspect of building good business relationships, and the Code of Conduct does not prohibit Skanska employees from making or accepting hospitality or gifts provided that they:
- conform to local laws and customs;
- do not place the recipient under any obligation to the donor or appear to do so;
- serve a valid business purpose; and
- are not prohibited by the policies of the recipient’s employer.
Each Skanska Reporting Unit shall have a written policy prescribing monetary thresholds, as well as procedures for reporting and monitoring of corporate hospitality and gifts. Each Skanska Reporting Unit shall, as appropriate, inform its suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners about these monetary thresholds.
Charitable contributions and sponsorships. Each Skanska Reporting Unit shall have policies in place that require prior approval of the Unit’s senior management for charitable contributions and sponsorships. Charitable contributions and sponsorships shall not be used to circumvent the bribery prohibition.
Conflicts of interest. Skanska employees must avoid conflicts of interest between their personal financial interests and their involvement in Skanska's business. Any Skanska employee in a position to influence a Skanska decision with respect to a transaction with any entity in which the employee has a financial interest (other than portfolio investments in public companies’ securities) shall disclose to his or her immediate superior such financial interest and refrain from participation in the transaction.
Skanska's computers and equipment shall not be used for illegal or unethical activities. To the extent necessary, Skanska Reporting Units shall have policies detailing this prohibition.
Skanska employees shall avoid situations that may present a conflict of interest, or appear to do so. This includes situations in which the employee’s relationship with another person may interfere with the employee’s ability to make sound business decisions in the best interest of Skanska. Employees are obligated to inform their immediate superior of any participation, directly or indirectly, with any entity that competes with, or engages in business with, Skanska.
Skanska employees may participate and contribute back to the communities in which we live and work. Service as an officer or director of a charitable or other non-profit organization is, as such, not considered a conflict of interest.
3.3 Proper Accounting for All Transactions
Code of Conduct Principle: We record the correct nature of all financial transactions by recording them in accordance with locally Accepted Accounting Principles and in all Group reporting follow International Financial Reporting Standards (IFRS) and applicable Skanska Policies and Rules.
Each Skanska Reporting Unit shall implement processes to ensure that recording of all business and financial transactions conform to the above Code of Conduct principle. Record keeping of all business and financial records, such as time and expense reports, invoices, journal entries and project reporting, shall be complete, accurate and timely. Ensuring accurate and complete business and financial records is the responsibility of each and every employee providing input to such records.
3.4 Data Protection
Code of Conduct Principle: We have controls in place in our IT procedures to ensure adequate levels of data protection for our clients.
Electronic data. Implementation of an adequate level of pro8 July, 2010 tection for data entrusted to Skanska by its clients is not only legally required but also essential to the continued success of Skanska’s business and preservation of its reputation. Each Skanska Reporting Unit shall implement policies and procedures to ensure the necessary level of protection for this data.
Skanska employees are required to abide by confidentiality agreements and to otherwise observe the proprietary nature and knowledge of Skanska’s and our clients’ businesses.
Privacy. Although the stated Code of Conduct principle explicitly refers only to clients, Skanska Reporting Units shall also have controls in place to ensure adequate levels of data protection for its employees, suppliers, subcontractors, intermediaries, joint venture partners and other cooperation partners. Personal data and non-public information must be treated in accordance with applicable laws and in accordance with contractual obligations. Information is to be used only for legitimate business purposes and care must be taken to prevent unauthorized disclosure of sensitive information.
Code of Conduct Principle: Based on the strong belief that project development and construction related services can make a major contribution to a more sustainable world, Skanska is committed to proactive environmental management at all levels.
Skanska’s goal is zero environmental incidents and Skanska is committed to proactive environmental management at all levels from local to global. Each Skanska Reporting Unit is responsible for implementing this approach by planning and acting responsibly so as to make a positive contribution to the environment in which they work.
4.1 Organization and Systems
Code of Conduct Principle: We maintain organizational structures, management systems, procedures and training plans that as a minimum ensure compliance with all relevant laws, regulations and standards.
Where required by law or regulation, an Environmental Impact Assessment (“EIA”) must be completed and approved by the relevant authorities. In the case of a Skanska Reporting Unit involved in construction, an EIA is typically commissioned by the client and then submitted to the relevant authorities for approval. The approved EIA is a formal requirement before execution of the works can start. It is the responsibility of the Skanska Reporting Unit involved in construction to develop an appropriate response plan to the issues identified in the EIA. In the case that a Skanska Reporting Unit is the client (alone or in association with others), it is obliged to ensure that an EIA is completed and submitted for approval to the relevant authorities.
On the occasions where Skanska’s stakeholders have not identified significant environmental risks or opportunities, Skanska should engage them on the subject. Each Skanska Reporting Unit shall give preventive measures priority and endeavor to reduce adverse environmental impact using the best available technology taking into account what is technically feasible, economically viable and environmentally responsible.
4.2 ISO 14001
Code of Conduct Principle: Our Environmental Management System is certified in accordance with ISO 14001. Since line management is responsible for our environmental perfor-mance, it is integrated into core business processes and plans.
All Skanska Group companies shall operate an environmental management system registered/certified to ISO 14001 that covers all activities where Skanska has management control or a majority shareholding. New businesses shall comply with this requirement within two years of acquisition.
4.3 Subcontractors and Partners
Code of Conduct Principle: In a spirit of continual improvement, we involve our workforce in the process of environmental management including subcontractors, partners and other interested parties.
Skanska Reporting Units shall involve all components of their workforce, including subcontractors, suppliers, joint venture partners and other cooperation partners, in the task of responsible environmental management, emphasizing good communication and engagement as well as the effec- tive implementation of technical solutions.
Skanska Reporting Units are encouraged to engage with other interested and legitimate parties, such as community groups and non-governmental organizations interested in environmental performance.
4.4 Life Cycle Approach
Code of Conduct Principle: Our ambition is to continually improve the environmental credentials of our projects, products and services by actively looking for ways to reduce negative environmental impacts during their entire life cycle.
Skanska Reporting Units shall ensure that, through good design and planning, the consumption of materials during construction is as low as possible. Furthermore, Skanska Reporting Units shall think ahead, together with clients, joint venture partners and other cooperation partners, given economic and other considerations, to ensure that materials that may be considered environmentally acceptable today, from a legal perspective, but that are under scrutiny by legitimate experts are carefully considered before usage. Usage of materials that generate a significant environmental impact or large carbon footprint or materials, systems, elements, components, technologies and the like that consume large amounts of energy, especially those requiring electrical energy, should be reduced where possible.
5. Skanska Code of Conduct Hotline
In accordance with Section 2.3, each Skanska Reporting Unit shall provide several channels for reporting suspected breaches of the Code of Conduct and these channels are the primary means for reporting. However, if none of those channels are feasible or appropriate under the circumstances, it is possible to report serious breaches of the Code of Conduct directly to the Skanska Code of Conduct Hotline. The Skanska Code of Conduct Hotline is open every day, around the clock. Reports can be made in the respective Skanska Reporting Unit’s local language(s) or in English and, if so desired, anonymously.
A report to the Skanska Code of Conduct Hotline is first received by an external service provider. The message is translated and transcribed into text, which is then e-mailed to the Ethics Committee at Skanska AB. Consequently, no one at Skanska will hear the actual recording. When recording the message, the reporter will receive a unique case number, which can later be used to call the Skanska Code of Conduct Hotline to receive feed-back on the report, including possible follow-up questions from the Ethics Committee at Skanska AB. This procedure allows for anonymous communication with the reporter to supplement and/or verify the reliability of the report, before any action is taken. After an initial evaluation, the Ethics Committee at Skanska AB decides if and how the case shall be investigated further.
6. Review and Measurements
Review. Each Skanska Reporting Unit shall review its Code of Conduct Program not less than every two years, and the results of these reviews shall be used for improvements to their respective Code of Conduct Program.
Measurements. The below measurements with respect to the implementation of the Code of Conduct shall be made every six months and be reported by the Head of the Skanska Reporting Unit to Skanska AB's Ethics Committee.
- Percentage of Skanska employees trained in the Code of Conduct during the two years prior to the end of each reporting period and who remain employed as of such date.
- Percentage of Skanska employees trained in the Code of Conduct who commenced their employment during the three months prior to the end of the reporting period and who remain employed as of such date.
- Most recent results of the annual employee survey to the following questions:
a. I understand what behavior is expected of me in order to comply with the Code of Conduct.
b. Actions of management in my Skanska Reporting Unit consistently demonstrate their commitment to promote work in accordance with the Code of Conduct.