BE Group

Corporate Governance Information

BE Group’s business model as a trading company involves extensive business relationships with customers and suppliers. Risks related to corruption and business ethics have been identified as material areas. The company has established clear policies and an external whistleblowing service to ensure responsible conduct.

Material impacts, risks and opportunities		Position i the value chain	Potential/actual impacts	Time horizon
	Negative impact Suppliers may be dependent on the company’s payments	Own operations	Potential	Short-, medium-, long-term
	Positive impact Robust protection mechanisms for potential whistleblowers	Own operations	Actual	Short-, medium-, long-term
	Risk Unethical behaviour by company representatives that damages the company’s reputation	Own operations	N/A	Short-, medium-, long-term

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Material impacts, risks and opportunities and their relationship to strategy and the business model

BE Group has considered the nature of its operations and business relationships when assessing materiality within responsible business conduct.

Material impacts

A positive actual impact has been identified regarding the protection of whistleblowers. BE Group has established an external whistleblowing service that enables anonymous reporting of suspected misconduct with protection against retaliation. This is assessed to contribute positively to an open corporate culture and to the company’s ability to identify and address potential shortcomings. Payment practices towards suppliers have been identified as an area of impact. BE Group’s payment routines have a direct effect on suppliers’ liquidity and financial stability, particularly for smaller suppliers.

Material risks

Corruption and bribery have been assessed as material from a financial perspective. The risk is primarily located within the company’s own operations and concerns situations where individual employees may act in conflict with the Code of Conduct, business ethics policies, and internal guidelines. The primary financial exposure is considered to be reputational risk, where incidents could affect the company’s standing among customers, suppliers, and investors.

Connection to strategy and business model

BE Group’s business model as a trading company involves extensive business relationships with customers and suppliers, creating situations where corruption risks may arise. The strategy to manage these risks is based on clear policies, including the Code of Conduct and the Anti‑Corruption Policy, as well as established channels for reporting deviations. Payment practices are managed through the company’s financial routines and supplier relationships.

Time horizons

The identified impacts and risks related to responsible business conduct are considered relevant in the short term (reporting period), medium term (up to five years), and long term (more than five years).

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Policies for responsible business conduct and corporate culture

BE Group has established several policies and guidelines to support its sustainability work, including the Code of Conduct, corporate values, Environmental Policy, Safety First Policy, Anti‑Corruption Policy, Code of Conduct for suppliers, Sanctions Policy, and Whistleblowing Policy. All subsidiaries are required to comply with these ethical guidelines and policies, and the CEO of each subsidiary is locally responsible for ensuring their implementation in operations.

BE Group’s Code of Conduct has been adopted by the Board of Directors and applies to all operations and employees within the BE Group. The ethical guidelines provide direction for daily work in order to achieve the Group’s objectives and outline the responsibilities of all employees towards business partners, shareholders, employees, and society. The Code addresses issues such as business ethics, anti‑corruption, child labour, gender equality, work environment, career development, and competence development. Complementing the Code of Conduct, the Anti‑Corruption Policy stipulates that employees must not pay, offer, or accept bribes or other improper benefits, such as gifts or hospitality deemed excessive, for the purpose of influencing business decisions or securing undue advantages. BE Group must also not engage with suppliers, vendors, or partners who offer bribes or are involved in corrupt activities.

Respect for human rights is a key factor in achieving the UN Sustainable Development Goals. Internal guidelines within the company’s Code of Conduct outline the rights of employees, including the right to be represented by a trade union in negotiations, fair employment and wage conditions, a workplace free from discrimination and harassment, and a zero‑tolerance approach to child labour.

Policy	Description	Management	Owner
Code of Conduct	BE Group’s Code of Conduct sets out expectations for employee behaviour in areas such as human rights, work environment, business ethics, anti‑corruption, and the environment. The policy is based on the UN Global Compact.	The policy applies to all employees across the Group. The President and CEO holds ultimate responsibility for the policy. The current version was approved by the Board of Directors in April 2018. The policy is communicated to employees at the start of their employment and is available on the company intranet. Employees are expected to confirm that they have read and understood the policy. The policy was developed internally and, as documentation is not available, the company assumes that no stakeholder dialogue was conducted during its initial development.	President and CEO
Whistleblowing Policy	BE Group’s Whistleblowing Policy sets out the procedures for reporting serious misconduct within the Group. The policy covers the reporting of suspected criminal offences, corruption, serious environmental violations, significant safety deficiencies, and severe cases of discrimination. Reporting is carried out through an external whistleblowing service called Trumpet, which is administered by an independent third party..	The policy applies to all individuals operating within BE Group in a work‑related context, including members of the Board of Directors, employees, interns, hired personnel, as well as shareholders and auditors. The CFO holds ultimate responsibility for the policy. Reports are handled under strict confidentiality by a limited group consisting of the external service administrator and BE Group’s internal Whistleblowing Committee. Reporting can be made anonymously. Individuals who report concerns in good faith are protected against retaliation, a protection that also extends to colleagues and union representatives who provide assistance. The policy is communicated via the company’s website, where the whistleblowing service is accessible. The policy was adopted in July 2022. It has been developed internally with consideration of the EU Whistleblowing Directive and Swedish whistleblowing legislation.	CFO
Anti-Corruption Policy	BE Group’s Anti‑Corruption Policy sets out the company’s prohibition against bribery and corruption. The policy prohibits employees from offering, giving, soliciting, or accepting bribes, whether directly or indirectly. It also regulates the handling of gifts and hospitality, where limited and reasonable business gifts may be accepted provided they are transparent, proportionate, and have a legitimate business purpose. The company maintains political neutrality and does not make political donations.	The policy applies to all employees in the Group. The CFO holds ultimate responsibility for the policy. The current version was approved by the Board of Directors in October 2021. The managing directors of the subsidiaries are responsible for ensuring that employees within their respective units understand and comply with the policy. Managers are responsible for introducing the policy to both new and existing employees. The policy complements BE Group’s Code of Conduct. Employees are encouraged to report any breaches through the company’s whistleblowing function or to their immediate manager. The policy was developed internally, and as documentation is not available, the company assumes that no stakeholder dialogue was conducted during its initial development..	CFO

Policy	Beskrivning	Hantering	Ägare
Trade Sanction Policy	BE Group’s sanctions policy defines the Group’s approach to trade sanctions and export controls. The policy aims to ensure compliance with applicable sanctions and export control regulations, in particular those of the EU, the United Kingdom and the United States. The policy prohibits conducting business with sanctioned parties and identifies high‑risk countries where trade is either prohibited (red countries) or requires enhanced due diligence and written approval from the Group CEO (yellow countries). All business partners must undergo sanctions screening.	The policy applies to all companies and employees within the Group, regardless of the country of operation. The CEO and Group President holds ultimate responsibility for the policy. The current version was approved by the Board of Directors in 2023. The Group CEO is responsible for granting exemptions and providing guidance on specific matters. The management teams of the subsidiaries are responsible for implementation within their respective entities. The policy is communicated through the intranet and the company’s website, as well as through training provided to board members, management, and employees involved in cross‑border transactions. Training is repeated on a regular basis. The policy has been developed in collaboration with an external law firm.	President and CEO
Code of Conduct for suppliers	BE Group’s Code of Conduct for suppliers specifies minimum requirements for suppliers in areas such as legal compliance, labour rights and human rights, occupational health and safety, the environment, and business ethics. The policy references the ILO Core Conventions, the UN Global Compact, the OECD Guidelines for Multinational Enterprises, and the UN Universal Declaration of Human Rights.	The policy applies to all suppliers to the Group. Suppliers are encouraged to apply equivalent requirements within their own supply chains. Ultimate responsibility for the policy lies with President ad CEO. The policy is communicated to suppliers during contractual processes. BE Group seeks to ensure that all suppliers sign the Code of Conduct for suppliers. In cases where suppliers do not sign BE Group’s Code, this may be accepted provided that the supplier can present its own code of conduct with equivalent or higher standards. The policy was developed internally with consideration of international frameworks. As documentation from the development process is not available, the company assumes that no stakeholder dialogue was conducted during the policy’s initial formulation.	President and CEO

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Management of relationships with suppliers

The company’s Code of Conduct for suppliers outlines minimum requirements and expectations in areas such as human rights, health and safety, non‑discrimination, working conditions, child labour, anti‑corruption, information regarding sanctions, import and export restrictions, and environmental responsibility. The Code of Conduct is signed by suppliers and monitored by the procurement organisation. As part of future development, the company plans to introduce clearer processes for supplier screening and follow‑up.

The company requires suppliers to comply with applicable regulations, including sanctions and import/export restrictions related to certain products, and to refrain from conducting business with sanctioned individuals, countries, or companies. Suppliers must also be transparent regarding the customers they conduct business with.

Working conditions and human rights

The Code of Conduct for suppliers states, among other things, that suppliers shall:

eliminate physical risks and provide appropriate technical protective measures such as safety equipment, safety locks, and barriers
identify, assess, and eliminate workers’ exposure to hazardous chemical, biological, and physical substances
respect their employees’ human rights and treat all employees with dignity and respect, in accordance with international laws and standards
ensure a workplace free from harassment and discrimination and refrain from threatening or subjecting employees to harsh or inhumane treatment
refrain from human trafficking or the use of any form of forced labour. All work must be voluntary, and employees must be free to leave their work or terminate their employment with reasonable notice. Employees must not be required to surrender government‑issued identification documents, passports, or work permits as a condition of employment
employ only workers who are at least 15 years old or have reached the legal minimum age, whichever is higher. Child labour is strictly prohibited
encourage the reporting of concerns by employees

Environment

The Code of Conduct for suppliers also states that suppliers shall:

comply with all applicable laws and regulations such as REACH and RoHS, which prohibit or restrict the use or handling of specific substances
manage and dispose of hazardous and non‑hazardous waste generated through their operations in accordance with applicable laws and regulations
take appropriate precautions to prevent contamination of stormwater runoff from their facilities
monitor, control, and treat air emissions of volatile organic compounds, corrosive substances, particulates, ozone‑depleting chemicals, and combustion by‑products generated in their operations, in accordance with applicable laws and regulations, before release
ensure compliance with applicable laws and regulations relating to soil contamination
obtain, maintain, and keep current all required environmental permits and registrations, and comply with associated operational and reporting requirements
strive to use energy more efficiently and avoid energy waste

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Prevention and detection of corruption and bribery

Like many other companies, BE Group is exposed to risks of involvement in unethical business practices in areas such as sales and procurement processes. The company maintains zero tolerance for unethical business conduct. BE Group has an Anti‑Corruption Policy and a Code of Conduct applicable to employees, suppliers, and business partners. All BE Group employees receive the Code of Conduct and Anti‑Corruption Policy as part of the onboarding programme at the start of their employment. The policies are also available to all employees on the company intranet. Each subsidiary CEO is ultimately responsible for ensuring compliance with group‑wide policies. BE Group also applies central and local authorisation manuals, has procedures for the approval of payments, and follows procurement processes that ensure sound business ethics.

Risk assessments are conducted annually at group level, and the corruption risk is assessed as low, considering factors such as geographic markets and authorisation procedures. Suspicions of potentially illegal behaviour or behaviour inconsistent with the Code of Conduct can be reported to the immediate manager, HR, or anonymously through BE Group’s whistleblowing system. The Whistleblowing Committee, which includes the Chair of the Audit Committee among its members, handles potential reports in consultation with an external party.

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Incidents of corruption and bribery

BE Group has not identified any relevant events during 2025 in relation to:

convictions for violations of anti‑corruption or bribery laws, or fines associated with such violations
confirmed incidents of corruption or bribery
contracts with business partners that were terminated or not renewed due to breaches relating to corruption or bribery
legal cases concerning corruption or bribery involving the company or its employees

As no confirmed incidents, convictions, or legal cases occurred, no corrective measures related to breaches of standards have been required.

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Payment practices

In line with group guidelines, BE Group strives to ensure that payments are approved in a timely manner so that they are executed within the agreed payment terms with suppliers. Payments are processed at least twice per week.

Payment terms vary between 10 and 90 days and are negotiated individually with each supplier. The company strives for a minimum payment term of 30 days. As of 31 December 2025, the average number of days it took BE Group to pay invoices was 46 days. At the end of the year, BE Group had no outstanding legal proceedings related to late payments.