Hemnet Group ENG 2022

Sustainability results and progress

Focus area 3: Living by strong ethical principles

Hemnet’s Supplier Code of Conduct sets out our expectations on our suppliers regarding basic ethical and moral principles related to sustainability and human rights. We have zero tolerance for child labor and slave-like conditions. Right to privacy Data is a key asset for Hemnet and we collect and process large amounts of data that can be directly or indirectly associated with an individual. All processing of such information (personal data) is carried out with respect for privacy and in accordance with applicable data protection legislation. We do not share personal data with suppliers unless a data processing agreement is in place. If the supplier is located outside the EU/EEA, we will only transfer personal data if we have ensured that there is a legal basis for the transfer and that appropriate safeguards are in place for it. As we further develop our technology and business or change how we handle personal data, we ensure that these changes are properly addressed from a data protection perspective. These principles form the basis for all of our work related to personal data protection and are described in our Code of Conduct and in more detail in Hemnet’s Guidelines for data protection.

Our Code of Conduct gives us a strong ethical foundation Hemnet’s business is run on the basis of principles of ethics and responsibility that permeate all aspects of our operations and are summarised in our Code of Conduct. The Code of Conduct provides clear ethical and moral guidance and sets the expectations of Hemnet in relation to our employees. It helps us to ensure that principles of ethics and responsibility are integrated into all aspects of our business and that we act in a trustworthy and transparent manner in all aspects of our operations. The code articulates the company’s zero tolerance for bullying, harassment, intimidation, bribery and corruption. Our approach to Human Rights is also a part of our Code of Conduct, stating that Hemnet and its employees respect the internationally recognised human rights as described in the UN Universal Declaration on Human Rights. We are guided by the UN Guiding Principles on Human Rights in Business and we conduct our business with respect for the human rights of all individuals. We expect the same from our suppliers. Our employees must know about our Code of Conduct, what it stands for and what responsibilities it comes with for them as Hemnet employees. All new colleagues are educated in the code as they start at Hemnet. In the beginning of 2023, we implemented a new e-learning tool to give all employees a better opportunity to understand the code fully, while at the same time giving the company solid tracking of how many have completed the course. We promote a culture of openness where everyone is encouraged to speak their mind and raise any issues relating to non-compliance with the code. Violations of our ethical guidelines are reported internally through managers or anonymously through our whistleblower function, which is available through our website hemnetgroup.com and on our intranet. Demands on suppliers We expect our suppliers to conduct their business in a responsible manner compatible with the law and our values. No part of our supply chain must go against the principles of our Code of Conduct.

Long term goal - Living by strong ethical principles : • 100% of Hemnet’s employees should acquaint themselves with Hemnet’s Code of Conduct and go through the yearly e-training

Performance indicators:

2019

2020

2021

2022

Communication and training on anti-corruption policies and procedures (GRI 205-2) Share of employees informed about the company’s Code of Conduct Share of employees who complete and passed e-training in Code of Conduct*

N/A N/A

N/A N/A

100% N/A

100% 98%

Confirmed incidents of corruption and actions taken (GRI 205-3)

N/A

0

0

0

Number of incidents reported through Hemnet’s whistleblowing function

N/A

N/A

0

0

Data protection incidents Number of personal data incidents related to customer data reported to the Swedish Authority for Privacy Protection

0

0

0

0

* E-learning module was implemented in the beginning of 2023 and results are from February.

26 · Hemnet Group | Annual and sustainability report 2022

Sustainability report

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