Code of Conduct Sepcotech A/S
Version number and date of policy update: V.1.0 November 2025
1. Purpose
2. Coverage and Subcontractor Obligations
3. Failure to comply
4. Revision
5. Social Responsibility
6. Environment and Climate
7. Governance
1. Purpose
1.1. At Sepcotech A/S (hereafter ‘Sepcotech’) we strive to take responsibility for our impact on people, the environment, and the climate. This applies both to our own operations and to our suppliers and business partners (all together known as “business partners” or “BP”). This policy sets out the expectations we have for our BP’s, so we can work together to ensure responsible business practices in relation to human and labour rights, environmental and climate impacts, and governance.
1.2. At Sepcotech we aim to engage in responsible procurement practices, including fair pricing, flexibility in case of changes, and a responsible approach to ending partnerships to ensure a mutually beneficial and constructive relationship.
2. Coverage and Subcontractor Obligations
2.1. By signing an Agreement with Sepcotech the BP commits to collaborating on compliance with all elements of this policy.
2.2. The BP also commits to complying with all applicable national laws and regulations in the country where the BP operates.
2.3. If the BP uses subcontractors to deliver services or products to Sepcotech, this must be disclosed in advance and updated on an ongoing basis if any changes occur.
2.4. When subcontractors or other external partners are involved, the BP is responsible for ensuring that they also comply with this BP policy.
3. Failure to comply
3.1. If the BP identifies any failure to comply with the expectations outlined in this policy, the BP must inform Sepcotech, providing an explanation of corrective actions taken and a plan for preventing future failure to comply.
3.2. Repeated, undisclosed, or ignored violations may lead to warnings and, in the worst case, termination of the partnership.
4. Revision
4.1. The responsibility for working with this BP policy, as well as maintaining, updating, and communicating it, lies with the Compliance Officer. The policy is reviewed and updated when deemed relevant.
5. Social Responsibility
5.1. At Sepcotech, we are committed to treating people with dignity and respect, and to uphold human rights. We expect the same from our BPs.
5.1.1. Contract The BP must ensure that all employees have a written employment contract, ideally before or at the latest within 7 calendar days of beginning their employment at the BP. The contract must outline all terms of employment, be written in a language the employee understands, comply with applicable collective agreements, minimum wage regulations, and other local labour laws — as well as the requirements of this BP policy.
5.1.2. Workings hours and wages
5.1.2.1. The BP must ensure that employees work reasonable hours in accordance with local legislation.
5.1.2.2. Employees must be paid in full and on time, in line with applicable laws. Wage deductions as a form of disciplinary action are not permitted.
5.1.3. Breaks, absence and leave The BP must comply with local laws and regulations regarding working conditions and, as a minimum, meet the requirements of the EU Working Time Directive.
5.1.4. Freedom of association and collective bargaining agreements The BP must respect employees’ right to organise, join a union, and engage in collective bargaining agreements. At Sepcotech we are aware that this right may be restricted or challenged in some countries.
5.1.5. Child and youth labour
5.1.5.1. The BP must not engage in or benefit from child labour that violates applicable laws. The minimum age for full-time employment must not be less than 15 years (14 years if permitted by local legislation) or lower than the age for completing compulsory schooling in the respective country.
5.1.5.2. The BP must ensure that no employees under the age of 18 are assigned tasks or working conditions that involve hazardous work or are harmful to their physical or mental health, safety, or development.
5.1.6. Forced labour and human trafficking The BP must not use or benefit from any form of forced labour or human trafficking.
5.1.7. Equal treatment The BP must ensure a workplace culture free from discrimination, harassment, or violent behaviour. This applies to - but is not limited to - gender, race, colour, religion, political opinion, sexual orientation, age, disability, or national, social, or ethnic origin. This applies to all stages of employment, including recruitment, promotion, transfer, and dismissal.
5.1.8. Health and safety
5.1.8.1. The BP must protect employees and prevent workplace accidents by implementing appropriate safety measures and providing proper equipment.
5.1.8.2. All employees must be informed and trained in key procedures such as evacuation plans and fire safety. When relevant, they must be trained in the safe handling of hazardous materials, chemicals, and/or machinery.
5.1.8.3. The BP must ensure a healthy physical work environment, including access to clean drinking water and sanitation, sufficient lighting, ventilation, and ergonomic working conditions. The BP must also promote a psychologically safe workplace based on mutual respect and recognition across all levels of staff.
5.1.9. Training and development The BP must ensure that all employees receive relevant training that supports awareness of and compliance with this BP policy. This includes training on procedures related to health and safety, environment and climate, anti-discrimination, anti-corruption, and bribery prevention.
6. Environment and Climate
6.1. At Sepcotech we work to reduce our negative impact on the environment and climate. We expect our BPs to do the same.
6.1.1. Legislation and permits The BP must comply with all relevant local and national environmental and climate legislation, and must obtain and maintain all necessary permits, approvals, and certifications.
6.1.2. Energy and CO2e emissions The BP must operate energy-efficient processes to minimize energy consumption and CO2e emissions.
6.1.3. Pollution The BP must minimize pollution, including emissions of wastewater and contamination of air, water, and soil. Additionally, the BP must minimize or avoid using problematic and particularly hazardous substances.
6.1.4. Biodiversity The BP must be aware of whether their activities negatively impact biodiversity.
6.1.5. Water The BP must strive to minimize water consumption and operate water-efficient processes. Additionally, the BP must disclose if operating in water limited areas.
6.1.6. Resource consumption and circular economy The BP must ensure activities are conducted as efficiently as possible to minimize resource consumption.
6.1.7. Waste
6.1.7.1. The BP must, at a minimum, comply with local waste management regulations and work actively to reduce the amount of waste generated. In addition, the BP should increase the share of waste that is reused or recycled.
6.1.7.2. The BP must ensure that waste is handled and disposed of safely and in accordance with national and local legislation. All relevant employees must receive appropriate training in handling hazardous waste to ensure their health and safety.
6.1.8. Transport When transporting materials, components, or finished products, the BP should prioritise road, sea, or rail transport.
7. Governance
7.1. Responsible procurement The BP must avoid sourcing raw materials from conflict-affected areas or from regions where extraction poses health risks to workers or local communities.
7.1.1. Animal welfare The BP must respect animal welfare in its own operations and in the activities of any subcontractors.
7.1.2. Confidentiality The BP is required to protect the confidentiality of trade secrets and other non-public information received as part of its collaboration with Sepcotech whether such information is shared in writing, orally, or digitally.
7.1.3. Personal data and data security The BP must comply with applicable data protection laws. This includes the handling of personal data related to the BP’s own organization, employees, and customers.
7.1.4. Anti-corruption and bribery The BP must not engage in or accept any form of bribery, corruption, money laundering, fraud, blackmail, embezzlement, or deceitful conduct in its business operations, transactions, or through its business partners. The BP must also comply with all applicable anti-corruption and anti-bribery legislation.
7.1.5. Risk Management The BP is encouraged to have systems or procedures in place to prevent, limit, and manage risks of negative impact within the areas covered by this BP policy. The BP is also encouraged to monitor and evaluate both its own efforts and those of subcontractors in meeting the expectations outlined in this policy.
7.1.6. Complaints-handling Mechanism The BP must ensure that when required by law, all employees have the possibility to report complaints related to inappropriate behaviour or activities that violate this BP policy, anonymously and without fear of retaliation.
7.1.7. Export control The BP must comply with all applicable export control laws and regulations, including those governing dual use items—products, software, or technologies that can be used for both civilian and military purposes. The BP is responsible for ensuring that any export, transfer, or provision of dual use items to or on behalf of Sepcotech is conducted in accordance with relevant national and international export control requirements. The BP must obtain and maintain all necessary licenses, permits, and approvals prior to exporting or transferring such items. The BP must promptly inform Sepcotech of any restrictions, denials, or compliance risks related to dual use items, and provide documentation upon request to demonstrate adherence to export control obligations.
Transparency and documentation
7.1.8. We expect the BP to operate in an open and transparent manner, to show commitment to the content of this policy, and to integrate relevant topics into their own internal policies and processes.
7.1.9. The BP is expected to actively support the implementation of this BP policy through ongoing dialogue and collaboration. This includes informing Sepcotech of any known risks related to compliance and, upon request, providing documentation demonstrating compliance to this policy, to a reasonably possible extent.