Code of Conduct

Investors

Code of Conduct

All employees of Nightingale are required to comply with the Code of Conduct which is approved by the Board of Directors. The purpose of the Code of Conduct is to ensure that all employees of Nightingale follow shared basic ethical principles.

Nightingale’s Code of Conduct describes generally approved practices and the company’s commitment to abiding by laws and regulations, among others the following areas.

Legal compliance

Nightingale complies with all laws, regulations and binding commitments applicable to its business. Nightingale’s internal organisation is structured to meet the requirements of its Quality Management System certified according to EN ISO 13485. All employees are required to abide by valid legislation while conducting their professional duties in Finland or in other countries and the same is expected from Nightingale’s business partners.

Anti-bribery and anti-corruption policies

Nightingale does not approve of bribery or corruption in any form. All corruption and bribery is forbidden with regard to Nightingale’s operations. Nightingale and its employees, or third parties acting on Nightingale’s behalf, must not promise, offer or give bribes or other illegal payments directly or indirectly to any authorities or other parties in order to facilitate the launch or continuation of business or for any other reason. Neither shall Nightingale and its employees, or third parties acting on Nightingale’s behalf, request or accept bribes or any illegal payments. No employee of Nightingale, or third parties acting on Nightingale’s behalf, shall be involved in any activities that would diminish confidence in Nightingale’s impartiality or operational integrity.

Conflicts of interest

Nightingale and its employees avoid situations in which Nightingale’s and its employees’ interests are at odds. Employees should always act in the best interest of Nightingale and respect the rights of Nightingale’s customers. Nightingale’s employees must not participate in business or other activities that may create a conflict of interest between the company and the employee or his or her related parties. All employees are obligated to openly reveal any possible conflicts of interest.

Confidentiality

Nightingale’s employees may gain confidential information concerning the business operations of Nightingale or its contractual partners. Confidentiality of information must be maintained at all times.

Employees must ensure that all confidential information remains undisclosed, regardless of whether the information has been received from Nightingale or from a party engaging in business operations with Nightingale. Disclosing such information is only allowed if express permission has been granted for its disclosure, or if a disclosure obligation exists based on legal provisions.

Data protection

Nightingale complies with the applicable data protection legislation that establishes the obligations for collecting, handling, processing, transferring and possessing personal data.

A justified reason as required by the applicable data protection laws and regulations must always exist for processing personal data. Personal data can only be collected and processed on legal grounds specified in the law in accordance with Nightingale’s Privacy Policies and the agreements with its customers.

All Nightingale’s employees must abide by Nightingale’s Information Security and Data Protection Policies.

Ban on money laundering and related international sanctions

Each employee of Nightingale must comply with legislation related to preventing money laundering and financing of terrorism. No business operations must be engaged in with parties that are subjected to criminal prosecution or international sanctions.

Human rights

Nightingale respects and promotes human rights as they have been defined in the United Nations’ Universal Declaration of Human Rights. These rights include freedom of opinion, expression, religion, assembly and association, and the right to be free from any discrimination based on race, age, nationality, gender or sexual orientation.

Equal opportunities

Nightingale cherishes diversity and promotes the equal and consistent treatment of all employees in all areas of work regardless of the employee’s ethnic background, gender, religious beliefs, sexual orientation, marital status or other similar status protected under law.