We give and accept reasonable gifts and hospitality and cover our own expenses
Any gifts or hospitality offered or accepted by Outokumpu employees must occur in a legitimate business context and be reasonable, proportionate, and modest in value. Cash or cash equivalents (such as gift cards) shall never be offered or accepted. Gifts or hospitality should never create an expectation of receiving something in return.
As a general rule, we do not give gifts or provide entertainment or travel to government or public officials.
In certain situations, we may cover transportation and accommodation expenses for a business partner if it is appropriate, reasonable and permitted by the recipient’s organization.
Outokumpu employees’ travel expenses must normally be paid by Outokumpu, except for local transportation at the destination provided by a business partner. Any other travel expenses offered by a business partner must be approved in advance by the employee’s manager.
We work transparently with external business partners
Outokumpu works with commercial agents, consultants and other external business partners who provide sales and other support. Commissions or fees paid to these business partners must be based on a written contract agreed prior to the start of the cooperation, be reasonable in relation to the value of the service or work provided, and be paid only for lawful activities.
We avoid conflicts of interest
Outokumpu employees are expected to act in the best interest of Outokumpu and avoid situations where personal interests conflict – or could appear to conflict – with those of the company.
Employees shall not use their personal influence to secure commitments with businesses in which they or their family members have an interest. Employees shall not participate in decision-making involving a business partner in which they have a personal interest. Any commitments where an actual or potential conflict of interest exists – such as family connections or close personal relationships – must be referred to the employee’s manager for approval.
Private investments shall never influence, or appear to influence, independent judgment on behalf of Outokumpu. External activities such as additional work, board memberships, or financial interests shall not interfere with an employee’s role or create a conflict of interest. Employees shall not work for or receive payment from any competitor, customer, distributor, or supplier without prior written approval from their manager.
Open and honest discussion is essential. If an employee suspects a potential conflict of interest, it is important to promptly inform the manager. We all share a responsibility for acting with high integrity, being transparent about potential conflicts, and protecting Outokumpu’s reputation.
We compete freely and fairly
At Outokumpu, we compete openly and fairly. All employees must comply with applicable antitrust and competition laws and regulations at all times – whether in a formal or informal setting, during or outside work hours.
We do not tolerate any form of prohibited cooperation between competitors, such as fixing prices, allocating markets or customers, or exchanging confidential information. All agreements with competitors, customers, distributors and other business partners must comply with applicable competition laws, and Outokumpu will never abuse a dominant position, if one exists.
We know our business partners
Outokumpu must understand who our business partners are to ensure we are never involved in unethical or illegal activities. Employees must follow Outokumpu’s risk-based due diligence approach, which verifies the key facts about our business partners – such as company type, nature of business, location, end-use of our products, and the origin of purchased materials. Employees are also expected to pay close attention to potential compliance concerns in ongoing business relationships: red flags may include, for instance, unusual purchase orders, abnormal payment channels, and irregular shipment routes.
Outokumpu complies with all applicable sanctions and export control regulations as well as anti-money-laundering and terrorist financing laws. We do not buy from or supply products to any countries, territories, individuals, or entities that are subject to applicable sanctions, export restrictions, or similar measures. We expect our employees, customers, suppliers, and other business partners to comply with these laws and regulations as well.
We do not engage in money laundering
Outokumpu complies with all anti-money laundering requirements and works to ensure funds or assets linked to criminal activities – such as fraud, tax evasion, human trafficking, or bribery – are never disguised as legitimate. We do not conduct business with entities connected to terrorist organizations, or organized crime.
Employees must verify customers, suppliers and other business partners to ensure compliance with anti-money laundering laws.