Brunswick Real Estate’s (“Brunswick”) focus on real estate investment management brings a significant impact on climate and individual lives, and therefore also a great responsibility. One way or another, buildings make a difference to us all. At Brunswick we try to make sure it is a positive one. But we cannot stop there. We aim to make a positive impact by considering sound business ethics as well as environmental, social and governance aspects throughout all our operations. Cooperation with other parties is the very nature of our business. We prioritize working with consultants, financial partners, investors and suppliers and other business partners (collectively our “Business Partners”) who share our values and who have processes in place to ensure compliance with this Code of Conduct, in their own daily operations as well as in their supply chain.
This Code of Conduct (the “Code”), is built on the principles of UN Global Compact and which describes our ethical principles and business standards and applies to Brunswick, including employees and non-permanent staff, as well as our Business Partners. The Code shall be revised annually, and the latest version shall be posted on the corporate website.
Brunswick will take action if anyone violates the Code, laws or regulations. Potential incidents related to unlawful activities are naturally subject to immediate actions. When applicable, reports will be made to the relevant authorities.
Signed by:
Patrik Andersson, CEO Brunswick Real Estate
Laws, regulations and business ethics
Brunswick shall comply with applicable laws, directives, regulations and standards, as well as any collective agreements relevant to its business activities, wherever business is conducted. Business activities are to be conducted in accordance with good business practice, and shall thus promote fair competition, maintain high ethical standards, as well as hold all relevant permits, licenses, and registrations.
No form of corruption, bribery, money laundering or unlawful restriction of competition is tolerated. Activities and gifts shall always be connected to the business relationship and characterized by transparency and moderation.
Human rights
Brunswick shall support and respect human rights, in accordance with the UN Declaration of Human Rights, and treat employees and suppliers fairly, equally, and in a manner that exhibits respect for the equal value of all people.
Brunswick shall work proactively against discrimination, harassment or threats based on age, race, gender, religion or other belief, sexual orientation, transgender identity or expression, pregnancy, political opinions or disability. Discrimination in any form whatsoever may not occur in the context of recruitment, wage setting, training, promotion or termination.
Brunswick does not accept child labor or possible use of child labor. The minimum age of employment, under applicable legislation, shall be respected. 15 years is the minimum age ever allowed and no employee under the age of 18 years shall carry out assignments that may be classified as unsafe labor.
Working environment
Brunswick shall work for a safe and innovative work environment where team and individuals can grow and prosper. Safe and healthy working conditions shall be ensured for all employees, as well as the right to freedom of association and collective bargaining in accordance with local labor laws. Relevant information must be accessible in a language understood by the concerned individuals at work. Any accident or incident occurring while carrying out work on behalf of Brunswick shall be reported without delay.
Environment and climate
Brunswick recognizes the scientific evidence stating that the human activity since the industrial revolution is accelerating climate change, leading to e.g. extreme weather, rising sea levels, reduced biodiversity and extinction of species. The UN Sustainable Development Goals works as a framework for our ESG-initiatives. Brunswick supports the reduction targets stated in the Paris Agreement and will continuously work to reduce its operational greenhouse gas emissions to contribute to the efforts limiting the global temperature increase.
At its core, Brunswick’s business model is about partnering up and co-investing with investors from all around the world to build independent investment platforms. Every investment platform has its own sustainability policy, strategy and goals, matching the nature of the different investments.
Brunswick shall actively impose environmental and sustainability requirements on suppliers in connection with procurement. To further ensure control over the supply chain, Brunswick sees an advantage in limiting the number of suppliers and primarily choosing local suppliers.
Taxation
Brunswick supports the OECDs guidelines for taxation and the importance of enterprises contributing to the public finances of the countries where business is conducted by making timely payment of tax liabilities. Brunswick shall comply with both the letter and the spirit of the tax laws and regulations of the countries in which we operate. Complying with the spirit of the law means discerning and following the intention of the legislature.
Brunswick shall take proactive tax compliance measures and provide the authorities with timely and relevant information that is relevant or required by law for purposes of the correct determination of taxes to be assessed in connection with our operations, and conforming transfer pricing practices to the arm’s length principle. We shall use tax governance and tax compliance as important elements of our oversight and broader risk management strategies to ensure that the financial, regulatory and reputational risks associated with taxation are identified and evaluated.
Whistleblowing
Brunswick is committed to the highest standards of corporate governance. The whistleblower service, which is located on the corporate website, enables permanent and non-permanent staff as well as other Business Partners to report concerns with total and guaranteed anonymity, including:
- Illegal activities
- Misconduct
- Violation of Brunswick’s principles and policies
- Ethical or moral concerns
All complaints and reports are investigated by an independent third party.
Information management
Confidential information or data concerning business activities or Business Partners may only be used for the purpose intended. Information technology shall be reliable and developed in accordance with globally recognized ethical standards and comply with the General Data Protection Regulation (GDPR) and other applicable laws.
Brunswick shall proactively work against any type of misuse of insider information and employees are therefore not allowed to trade in instruments in listed real estate companies, nor engage in business which could be seen as competitive to Brunswick’s engagements.
Brunswick strives for open and honest communication with all stakeholders. Knowledge sharing within Brunswick to improve our way of working is encouraged, but confidential information may only be shared within Brunswick on a need-to-know-basis.