We act ethically and transparently

Our Code of Conduct is based on our values. It defines our ethical requirements, and serves as our guide in everyday work. We have a Code of Conduct for Skanska employees as well as a Code of Conduct for our suppliers (links above).

We encourage open dialogue that makes space for all kinds of perspectives, including raising concerns about shortcomings.

If you suspect or identify illegal, unethical, or otherwise behaviour or actions that are contrary to our Code of Conduct or our practices, please let us know so that we can respond in time:

We are committed to ensuring that everyone working on our sites is paid appropriately for their work and that all employees are treated fairly, with respect for the rights to which they are entitled as employees.

All Skanska employees complete training related to our Code of Conduct when they join the company and every two years thereafter.

In addition, we provide training for, for example, those in leadership positions on ethical and legal matters, such as anti‑corruption measures and compliance with competition law.

Our Code of Conduct provides guidance for practical situations, but it does not contain answers to every ethical question or dilemma. That is why we foster a transparent and open corporate culture in which ethical issues and our values are discussed openly.

We hold joint ethics discussions both on sites and in offices. Managers go through the discussion materials with their teams and reflect on the thoughts they provoke as well as our guidelines and practices.

In this way, we aim to ensure that every Skanska employee has the opportunity to raise ethics‑related questions with their manager and colleagues.

We want to act transparently and honestly and ensure that companies offering us products or services are treated equally in evaluation situations. Our zero‑gift policy covers the giving and receiving of gifts as well as hospitality in relation to our stakeholders, such as our subcontractors and customers.

Gift ban

In practice, this means that Skanska employees may not give gifts to representatives of external stakeholders or receive gifts from them. We return any gifts we receive to the sender.

A few exceptions to the gift ban:

• Events celebrating partners’ milestones (e.g. significant anniversaries) or retirement, to which stakeholder representatives are invited. A value cap of EUR 100 applies to gifts.
• Gifts given in connection with housing transactions and housewarming gifts, which we may give to a consumer who has purchased a home from us.
• Gifts given by a consumer who has purchased a home, provided their monetary value is low (e.g. a bouquet of flowers).
• Trade fairs and other comparable marketing events, as well as events organised in schools, educational institutions or day‑care centres, where we distribute Skanska marketing merchandise.

Representation and hospitality

Our policy states that representation must take place at events that relate to performing one’s job duties.

When representing Skanska in relation to customers, partners or other stakeholders, the value of hospitality must not exceed EUR 150 per person. This applies both when we act as host and when we are a guest.

Cooperation and networking with representatives of public authorities must take place at events where the programme clearly relates to job duties. Events should primarily be held on Skanska’s or the authorities’ own premises and during the authorities’ working hours.

Any potential exceptions to the zero‑gift policy and representation are always addressed separately by the Management Team of Skanska.

We all have the right and the obligation to report any suspicions of illegal or unethical conduct, or any other inappropriate behaviour.

Everyone also has the right to feel safe when reporting, without fear of being treated unfairly afterwards.

Our ethics committee provides general guidance on ethical practices, advises Skanska employees on work‑related ethical questions, and, when necessary, investigates suspected ethical violations.

Questions and reports submitted to the committee are anonymized for processing.

The committee confidentially reviews all reports it receives and responds to the questions presented to it. In addition, the committee’s decisions are communicated both to the concerned parties and to all Skanska employees.

We assess ethical risks annually and plan measures to mitigate them. We monitor compliance with our ethical guidelines, among other things, by continuously tracking and reporting the number of ethics trainings completed and the implementation of our ethics action plan.

At the project level, ethics come up in, for example, project evaluations and internal audits.

We examine our employees’ attitudes towards ethical issues in the employee survey and through feedback collected from ethics discussions.

We evaluate our contractual partners and engage them to operate in accordance with the Code of Conduct for suppliers.

Through our operating models and tools, we ensure that there is no grey economy in our projects and that any deviations are addressed without delay. We take a comprehensive approach to tackling the grey economy and combat it in various ways throughout all phases of our projects.

We make extensive use of digital and data‑driven tools to support checks and monitoring. Our preventive measures include policies and guidelines, contractual terms, supplier background checks, and the active identification of risks.