1. WHY WE HAVE THIS CODE
DP Patterning makes flexible electronics for customers in telecom, automotive, healthcare, industry and aerospace. Those customers qualify their suppliers before they buy, and they are right to. This code says how we work, so that anyone who deals with us can hold us to it.
We act according to our values: Pioneer, Integrity and Commitment.
The code applies to everyone who works in our operations: employees, managers, the board of directors, consultants, interns and hired staff. It applies in every work-related setting, including the workplace itself, customer visits, business travel, company events and digital communication. We expect the same standards from our suppliers and partners, and we ask about them before we place business.
Where local law sets a higher standard than this code, local law applies. Where it sets a lower one, this code applies.
2. THE LAW IS THE FLOOR, NOT THE CEILING
We follow the laws of the countries we operate in and sell to. In our own work environment policy we state it plainly: legislation is a minimum level, and we aim to keep improving beyond it. Meeting the legal minimum is not the same as acting well, and this code covers the difference.
3. BUSINESS INTEGRITY
3.1 Bribery and improper payments
We do not offer, give, ask for or accept anything of value in order to win business or influence a decision. This holds whether the other party is a public official or a private company, and whether the payment goes through us or through an agent. We do not make facilitation payments, meaning small payments to speed up a routine approval, even where they are common practice.
3.2 Gifts and hospitality
A modest meal or a small gift can be a normal part of a business relationship. It stops being acceptable when it is frequent, expensive, secret, offered in cash, or timed around a decision. If you would not be comfortable telling a colleague or a customer about it, do not do it. Ask your manager when you are unsure.
3.3 Conflicts of interest
Tell your manager if a private interest could affect your judgement at work, for example a family connection to a supplier, or an outside engagement in a related business. Disclosure is the point. Most conflicts are manageable once they are known.
3.4 Fair competition
We compete on our technology, our price and our delivery. We do not agree with competitors on prices, markets or customers, we do not exchange commercially sensitive information with them, and we do not seek information about competitors by deception.
3.5 Export control and sanctions
Some of what we make goes into products that are subject to export control, and some of our markets are subject to sanctions. We screen counterparties and destinations, we apply for the licences that are required, and we do not supply where we may not supply. Ask before committing to a delivery that may be affected.
3.6 Money laundering
We check who we do business with, we do not accept cash for commercial transactions, and we report payment arrangements that make no commercial sense.
4. PEOPLE AND WORKPLACE
This chapter summarises our work environment policy, our equal treatment policy, the annual equal treatment plan and our procedure for harassment and victimisation. Those documents are internal. We provide them to customers and auditors on request.
4.1 Health and safety
Nobody should be harmed by working here. Our aim is a workplace that is sound physically, psychologically and socially, with real job satisfaction and room to develop.
We investigate risks, assess them, act and follow up, regularly and ahead of any change to the operation. Every incident and injury is reported and investigated so that something can be done about the cause. The work is carried out jointly by the employer, the employees and the safety representatives.
Managers are given the training, the resources and the authority to act on the work environment, not only the responsibility for it. Every employee is introduced to it when they start. We also work actively with health promotion, so that looking after your own health is practical rather than just encouraged.
Everyone has the right to stop a task they believe is unsafe, and to raise a concern without it counting against them.
4.2 Equal treatment and non-discrimination
We do not accept discrimination, harassment, sexual harassment, victimisation, bullying, exclusion or other degrading treatment, in any form.
Decisions on employment, working conditions, pay, development, promotion, training, allocation of work and termination are made on objective grounds. We promote equal rights and opportunities regardless of the seven grounds set out in the Swedish Discrimination Act: sex, transgender identity or expression, ethnicity, religion or other belief, disability, sexual orientation and age.
Equal treatment does not mean treating everyone identically. It means giving everyone fair and comparable conditions, judged against what the work requires and what the individual's situation is.
Beyond not discriminating, we take active measures and review them at least annually, as the Discrimination Act requires. The method has four steps: investigate risks and obstacles, analyse the causes, decide and carry out measures with a named owner and a timetable, then follow up on whether they worked. The analysis looks at ways of working, structures, norms, routines and decisions, not at individual personalities.
We review these areas every year:
- Working conditions, including workload, allocation of work, hours, meeting formats, premises, equipment and digital working methods.
- Pay and terms of employment, through an annual pay survey that looks for differences we cannot justify.
- Recruitment and promotion, by keeping requirement profiles clear, relevant and free of unnecessarily excluding criteria, writing job advertisements inclusively and using structured interview questions. When we use an external recruitment agency, we require the same of them.
- Training and development, so that development opportunities, mentoring and demanding assignments are distributed on objective grounds. Every employee has a documented development review where this is followed up.
- Combining work and parenthood, including how meetings, travel and availability are planned. Meetings are placed at times that work around dropping off and collecting children.
- The risk of harassment, sexual harassment and victimisation, including whether managers know enough to recognise the early signs.
4.3 Harassment and victimisation
We have zero tolerance, and a written procedure that says what happens when something is reported. It is built on the Work Environment Act, the Swedish Work Environment Authority's provisions on the organisational and social work environment, and the Discrimination Act.
A report can be made to your manager, your manager's manager, HR, a safety representative, the managing director, or another member of management you trust. If the report concerns your own manager, take it to one of the others. Anyone who is affected, who sees someone else affected, or who learns of an incident, should report it.
Once a report is received, the process starts immediately. HR leads the investigation and holds separate conversations with the person affected, the person named and any witnesses. Everything is documented, and the matter is handled confidentially, with the documentation kept to the people who need it. No measures are taken without the consent of the person affected, unless safety requires it.
The person affected has the right to a support person, for example a safety representative or a union representative.
Depending on what the investigation shows, measures can include mediation, a reprimand, a formal warning, reassignment or termination of employment. A criminal act may be reported to the police.
We follow up within a month, or at another time agreed with the person affected, to check that nothing has been left unresolved and that nobody has faced retaliation for reporting.
Nobody may face negative consequences for raising a concern, making a report, taking part in an investigation, or supporting someone else in a case. Retaliation is treated as a serious breach in its own right.
4.4 Employment and labour rights
We respect the right to organise and the right to union representation. We use no child labour and no forced labour, and we require the same of our suppliers. Employment terms are set out in writing and follow Swedish law.
We support the human rights set out in the UN Guiding Principles on Business and Human Rights and the core conventions of the International Labour Organization, and we apply them to our own operations and to what we ask of our suppliers.
4.5 Skills
The process we run is our own, and the people who run it learn it here. We train for the job, we follow up development in documented reviews, and we plan for the skills the next production step will need.
5. ENVIRONMENT
Our process is dry and mechanical. It replaces etching and printing, which takes the etching chemicals and the process water out of the equation, and it uses aluminium, copper-clad materials and paper rather than precious metal inks. That is the main environmental contribution we make, and it is in the product itself rather than in an offset.
We work to reduce the energy, material and waste in our own operations, we sort and recycle production waste, and we handle the chemicals we do use according to the rules that apply to them. Our ESG page describes this in more detail.
6. PRODUCT AND QUALITY INTEGRITY
Test results, measurement data and certificates that we issue are accurate. We do not adjust a result to make a delivery pass, and we do not release material that has failed inspection. If we discover a quality problem after delivery, we tell the customer, including when telling them is inconvenient for us.
We buy material through legitimate channels and keep traceability, so that counterfeit or falsely declared material does not reach a customer's product.
7. CONFIDENTIALITY AND INTELLECTUAL PROPERTY
Customers give us their designs. Those designs stay theirs, they are used only for the work agreed, and they are shared internally only with the people who need them. Confidentiality survives the end of a project.
We protect our own process knowledge in the same way, and we respect the intellectual property of third parties. We do not use software or material we do not have the right to use.
8. PERSONAL DATA
We handle personal data lawfully and no more widely than the purpose requires. Our GDPR / Privacy Policy sets out how.
9. SUPPLY CHAIN
We expect our suppliers to meet the standards in this code and to be able to show that they do. Our material base is aluminium, copper-clad laminates and paper rather than tin, tantalum, tungsten or gold, which keeps us largely outside the conflict minerals question, but we still require our suppliers to source responsibly and we ask where material comes from.
We require our material suppliers to declare what their material contains, so that our customers can meet their own obligations under chemical and product legislation.
10. SPEAKING UP
If something in this code is not being followed, say so. The routes are the same ones set out in section 4.3: your manager, your manager's manager, HR, a safety representative, the managing director, or another member of management you trust. If the matter concerns your own manager, take it to one of the others.
Reports are handled promptly, objectively and with respect for everyone involved. Nobody is penalised for reporting a concern in good faith, and retaliation against someone who reports is itself a breach of this code.
Customers, suppliers and other external parties can raise a concern at info@dppatterning.com.
11. HOW THIS CODE IS MANAGED
Management owns this code and follows it up. It is reviewed at least once a year and whenever something happens that shows it needs changing. New employees are introduced to it, and to the policies behind chapter 4, when they start.
A breach is handled according to how serious it is, up to and including termination of employment, ending a supplier relationship, and reporting to the authorities.
Questions about this code go to info@dppatterning.com.