Code of Conduct

Volvo Group

A
Dear Colleague,

The Volvo Group is home to some of the world’s

most iconic brands, with a reputation that has been
earned over a century. It is up to all of us to honor
that heritage and build an even stronger future for
our company.

You are empowered and encouraged to take the

initiative, make decisions and drive our business
forward. The Code of Conduct is a tool to help you
navigate what is right in a particular situation and
act in a way that manages legal and ethical risk.

Read the Code of Conduct. Discuss with your

manager and your colleagues how it applies to your
specific circumstances and line of work. Don’t be
afraid to ask for support from our legal experts if
there is something you do not understand or need
help clarifying. And speak up if you notice behavior
that does not seem right to you.

It is what each and every one of us does that defines

who we are as a company, and how the world sees
us. We drive prosperity through transport solutions.
I am proud of what we do and how we do it.
 Volvo Group Code of Conduct

Table of Contents
I. Why Do We Have a Code?....................................................................................................................................2

II. Key Principles.......................................................................................................................................................4

We Respect One Another....................................................................................................................................4

Mutual Respect...............................................................................................................................................5

Non-Discrimination..........................................................................................................................................5

Safe and Healthy Workplace...........................................................................................................................6

Environmental Compliance.............................................................................................................................6

Freedom of Association...................................................................................................................................7

Working Hours and Compensation.................................................................................................................7

Modern Slavery and Child Labor.....................................................................................................................7

We Earn Business Fairly and Lawfully..............................................................................................................8

Product Compliance........................................................................................................................................8

Fair Competition..............................................................................................................................................9

Anti-Corruption, Including Gifts & Entertainment..........................................................................................10

Trade Compliance (Exports and Imports)..................................................................................................... 11

Anti-Money Laundering................................................................................................................................. 11

We Separate Personal Interests from Business Activities............................................................................12

Conflicts of Interest.......................................................................................................................................13

Political Activities...........................................................................................................................................14

Insider Dealing..............................................................................................................................................15

We Safeguard Company Information and Assets...........................................................................................16

Confidential Information................................................................................................................................17

Intellectual Property......................................................................................................................................17

Physical and Financial Assets.......................................................................................................................18

Data Privacy..................................................................................................................................................18

We Communicate Transparently and Responsibly........................................................................................19

Accounting and Reporting.............................................................................................................................19

III. Speak Up!...........................................................................................................................................................20

1
Why do we
have a Code?
AT V O LV O G R O U P, W E WA N T TO C O N D U C T B U S I N E S S
E T H I C A L LY A N D I N C O M P L I A N C E W I T H T H E L AW.

Doing business this way is the right thing to do. It builds trust with
our customers as well as with society which enhances our com-
mercial success. And it helps us avoid situations that might lead to
adverse legal issues or damage to our reputation.

This Code of Conduct clearly states the expectations for how we do

business – not just in a few locations, but everywhere we operate.

The Code is what we stand for and what we expect from you.

VOLVO GROUP VALUES

Customer Success Change

We make our We change to stay
customers win. ahead.

Trust Performance
We trust each other. We are profitable to
shape our future.
Passion
We have passion for
what we do.

2
 Volvo Group: Code of Conduct: Introduction

Are you a manager?

Live our Values and the Code. Set an example by

your own behavior.

Make sure your team is familiar with the Code and

how to use it. Encourage employees to talk to you if
they have questions or concerns.

D O E S T H E C O D E A P P LY T O W H AT I F I D O N ’ T F I N D A N
E V E R Y O N E AT V O LV O G R O U P ? ANSWER IN THE CODE?
Yes. The Code applies everywhere we do business, The Code contains rules and principles for how we
and to everyone who works on Volvo Group’s behalf, do business. It can’t, however, describe every real
including full- and part-time employees, consul- situation that might arise and sometimes the right
tants, temporary staff, senior management, and the answer is not obvious.
boards of directors of Volvo Group companies.
If you’re ever in doubt about a course of action, ask
You are accountable for following the Code, and fail- yourself:
ing to do so can have consequences for both you and
the company. Is it against the law?
l

You may be disciplined, including the risk of losing Is it unethical?

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your job, or even facing criminal charges. The com-
Could it damage Volvo Group’s global reputation?
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pany may be fined, face lawsuits or investigations, or
suffer damage to its reputation or share price. Would I be embarrassed to read about it in
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the media?

If yes, stop and consult your manager who can help you
find a way to handle the situation. Legal & Compliance
HOW SHOULD I USE THE CODE? can provide legal advice and guidance if the require-
Read it to understand what’s expected of you. Then ments of the Code are unclear in any respect.
use it as a reference if you need guidance in a par-
ticular area.

You should also consult Volvo Group’s policies, re- W H AT I F T H E R E I S A C O N F L I C T

sources, and compliance programs. These are meant BETWEEN THE CODE AND
to supplement the Code and provide additional
L O C A L L AW ?
direction and details.
We want to conduct all of our business in compliance
with the Code. Nothing in this Code, however, should
be understood as an instruction to break the law.

3
 We Respect
One Another

4
 Volvo Group Code of Conduct: We Respect One Another

MUTUAL RESPECT N O N - D I S C R I M I N AT I O N
At Volvo Group, we are proud of our inclusive work Volvo Group values a diverse workforce and expects
environment, which fosters a supportive energy and hiring managers to observe applicable laws against
encourages individual growth and strong teams. discrimination. Employment decisions like hiring,
Unwelcome conduct that creates an intimidating, pay, title, promotion, discipline, termination, or
offensive or hostile work environment has no place working conditions should be based on a person’s
here. Instead, we encourage and expect mutual re- ability or performance, not on irrelevant personal
spect – among colleagues and between our company factors.
and our business partners.

For You, This Means:

For You, This Means:
Do not practice discrimination; instead,
l
Treat all individuals with respect.
l evaluate candidates based on talent, skill,
and experience.
Never bully, intimidate or threaten another
l
person. Speak up if you see discrimination, or believe you
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have been unfairly discriminated against.
Avoid behavior that someone else could
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reasonably find offensive or inappropriate.

Object to harassment or other inappropriate

l What is discrimination?
conduct, whether it is targeted at you or
someone else. For purposes of this Code, discrimination happens
when qualified individuals are penalized at work due to
unrelated personal factors like:

What is harassment? l
gender, gender identity, or expression

l
age
For purposes of this Code, harassment means any
conduct or comments that create, encourage, or permit
l
nationality, race, ethnicity, skin color, or
cultural background
an offensive or intimidating work environment.
l
religion or beliefs
This includes verbal or physical harassment, bullying,
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disability, genetics, or health information,
sexual harassment, power harassment, racism,
including pregnancy
inappropriate humor, or other actions that offend or
cause distress. l
sexual orientation

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union affiliation

Any position requirements and employment related de-

cisions must be based on a legitimate business reason.

PRACTICING DIVERSITY AND INCLUSION…

…builds trust, by rewarding people based on their and hire the best, most qualified candidates
contribution and reinforcing an atmosphere of
respect …strengthens our working environment by helping
to bring out the best in people
…drives our performance, by ensuring we attract

5
S A F E A N D H E A LT H Y E N V I R O N M E N TA L C O M P L I A N C E
WORKPLACE
At the Volvo Group, we ensure that our business op-
We believe accidents, incidents, injuries, near miss- erations are in compliance with applicable environ-
es, work-related illnesses, and unsafe conditions are mental protection legislation as well as applicable
often preventable. By prioritizing compliance with internal requirements.
safety requirements in planning and operations,
we ensure our work environment meets applicable
health and safety laws and requirements.
For You, This Means:

Follow the environmental laws and company

l
For You, This Means: requirements that apply to your job.

Take all required precautions when handling or

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Take responsibility for your own safety and the
l
transporting hazardous materials, dangerous
safety of others around you – correct or report
parts, or waste, including during loading, unload-
hazards and address any unsafe behavior.
ing, or storage. If you are not familiar with these
Know and follow all safety requirements, including
l requirements, ask your manager for direction.
the use of personal protective equipment. Never
Use and dispose of chemicals and other materi-
l
take shortcuts or ignore required safety practices.
als properly, and report any spills, discharges, or
If you are a manager, ensure employees are
l environmental concerns.
properly trained and equipped for their jobs.

Don’t use or possess illegal drugs at work. Don’t

l
work while intoxicated or under the What are hazardous materials or
influence of drugs or alcohol. dangerous parts?

For purposes of this Code, we mean any chemicals,

materials, or waste that could present health risks or
are corrosive, flammable, or explosive.
M I N I M I Z I N G H E A LT H A N D S A F E T Y
R I S K S…. This includes batteries, airbags, aerosols, gasoline,
and diesel, and also certain paints, solvents, adhe-
…reduces work interruptions caused by safety incidents
sives, or surface treatments.
or accidents

…drives trust, engagement and performance by allow-

ing employees to focus on their jobs, without worry for
their well-being

6
 Volvo Group Code of Conduct: We Respect One Another

F R E E D O M O F A S S O C I AT I O N M O D E R N S L AV E RY A N D
CHILD LABOR
The Volvo Group respects the right of all employees
to form and join an association to represent their The Volvo Group does not tolerate any forms of
interests as employees, to organize, and to bargain modern slavery, including forced, bonded or com-
collectively or individually. We also respect any em- pulsory labor, or human trafficking. We respect chil-
ployee’s choice to refrain from joining a union. dren’s right to personal development and education,
and we do not use child labor.

For You, This Means:

For You, This Means:
You are free to seek guidance and support in all
l
employment related questions from the recog- Ensure that we do not use or support modern
l
nized unions and employee representative bodies. slavery, including by suppliers or other business
partners. If you are a manager, ensure that your em-
If you are a manager, do not interfere with employ-
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ployees have freely chosen their jobs and are free to
ees’ decisions related to union representation or
leave under their terms of employment and law.
membership.
If you hire, observe the minimum employment
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age in your country. Never hire children under 15,
WORKING HOURS AND even if it is permitted by local law.
C O M P E N S AT I O N Do not use young workers (ages 15-18) for work
l
The Volvo Group complies with applicable laws that is hazardous or poses risks to their individual
and agreements on working and resting hours and development or their physical or mental health.
compensation and benefits.

What is Modern l
Withholding wages
For You, This Means: Slavery? l
Lack of official
employment status
The terms and conditions of your employment,
l Human trafficking involves
including your rights and your obligations, should recruiting, harboring or trans- l
Abusive working conditions
be made clear to you. porting people into a situation l
Physical and
of exploitation through the sexual violence
Your working time should not extend beyond the
l use of violence, deception
allowed maximum, and you should receive time or coercion and forcing them
l
Debt bondage, i.e.
off for proper rest and paid holidays or vacations. to work against their will.
loans that have to be
repaid before the
Your terms of employment and compensation
l employee can end
Forced labor is any work
should meet applicable minimum wages and his/her contract
or service that people are
other legal requirements, including collective
forced to do against their l
Recruitment fees, i.e.
bargaining agreements.
will, under threat of punish- a person has paid a
ment and for which the recruitment firm for the
person did not volunteer. job and must work until
the debt is repaid
What are examples of
signs to look out for? l
Restrictions of move-
ment, e.g. employees
l
Confiscation of identity not allowed to leave
papers, passports, or company premises
education certificates

7
 We Earn
Business
Fairly and
Lawfully
PRODUCT COMPLIANCE THIS IS KEY
Volvo Group products are designed, manufactured, Occasionally, a request from the market may conflict
marketed, and sold to comply with applicable legal with our obligations under applicable legal requirements.
requirements and our internal quality and safety
standards. Compliance is essential to build trust in Under such circumstances, we must continue to honor
our products leading to success for us and for our all legal requirements that pertain to the design,
customers. manufacture, sale, performance, and marketing of our
products and services.

For You, This Means:

Comply with all legal and regulatory requirements

l Do not tamper with tests or test results.
l
as well as internal standards, including those
Don’t take shortcuts or make decisions that compro-
l
related to emissions, safety, hazardous materials
mise product compliance – regardless of the likeli-
or parts, and noise.
hood of detection by authorities or management.
If you design new products or change existing
l
Present our products and services accurately. En-
l
products, ensure they meet regulatory and legal
sure any statements are substantiated and don’t
standards at product introduction and for as long
provide misleading information, including about
as required.
safety or environmental attributes.

8
 Volvo Group Code of Conduct: We Earn Business Fairly and Lawfully

FA I R C O M P E T I T I O N
We trust that our products and services will succeed Who are competitors?
in a competitive marketplace and a fair market ben-
Our competitors include any independent company
efits us. We compete on the merit of our products
that competes or could compete with the Volvo
and services and do not take actions that are illegal
Group in a particular market.
under the competition laws, such as colluding with
competitors. We treat our suppliers in a profes- This includes original equipment manufacturers
sional manner and choose suppliers on the basis of (OEMs), but it also includes other companies we do
objective criteria. Because this is a complex area, business with, such as suppliers, private dealers, or
it’s critical to know what’s required and also consult Volvo Group customers who are also competitors in
with Legal & Compliance as needed. the end market.

When a supplier or customer is also a competitor, all

For You, This Means: restrictions described here apply, including restric-
tions on making agreements or sharing or receiving
Use only legitimate methods to gather information
l
certain information. Do not use the commercial rela-
about competitors.
tionship as a pretext to violate the competition laws.

Do not agree with a competitor on important is-

l
sues like price fixing, market sharing, or customer
allocation.

Comply with Volvo Group policies and processes if

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you participate in activities that involve contact with What is commercially sensitive
competitors, like trade association meetings, R&D information?
consortia, or industry standardization activities.
It includes:
Obtain any required pre-approvals before attending.
l
prices, surcharges, costs, margins, or discounts
Do not, on your own, decide to exchange commer-
l
l
terms of sale or profitability
cially sensitive information with competitors.
l
distribution, business plans, aftermarket strategies,
Unless provided for in Volvo Group policies and
l market forecasts, or product development plans
processes, don’t control or restrict the resale
Sharing, receiving, or exchanging this type of infor-
prices or terms set by an independent dealer,
mation could be prohibited even when it is informal,
supplier, or customer for our products.
such as in conversation with a former colleague or
friend who now works for a competitor. If you have
questions about whether a conversation is appropri-
ate, discuss it with Legal & Compliance in advance.

9
ANTI-CORRUPTION, INCLUD-
I N G G I F T S A N D E N T E R TA I N - What are facilitation payments?
MENT Volvo Group prohibits “facilitation payments” which
are unlawful payments made in order to expedite a
Bribery and corruption distort the market, interfere
service that you are entitled to.
with free competition, and violate laws that carry
significant penalties for the companies and individu-
As an example: let’s say a customs agent contacts
als involved. Volvo Group does not participate in or
you to let you know that some parts needed by your
endorse any corrupt practices, including offering or
customer are held up at the border – but he can move
accepting kickbacks, bribes, excessive gifts or hospi-
them through the process more quickly if you pay a
tality, or facilitation payments –directly or indirectly,
surcharge.
such as through a third party. We will not accept
suppliers, vendors or partners that offer bribes and
we will take necessary action if such actions are
uncovered.
C O M P E T I N G FA I R LY
For You, This Means: AND GUARDING AGAINST
B R I B E R Y ….
Understand Volvo Group’s rules on gifts and enter-
l
tainment and have a legitimate business reason for …builds trust, in the Volvo Group and in our
anything you offer. business

Don’t give or accept bribes or anything that could

l ..,protects fair markets and customer choice,
be considered a bribe, including cash, gift cards or which can be distorted when companies use
other cash equivalents, job opportunities, favors, bribery or collude with competitors to succeed
travel, promises to pay debts, or unlawful gifts and
…maintains Volvo Group’s competitive position,
entertainment.
by requiring the company to improve and in-
Do not use business partners or other third parties
l novate in order to succeed
to pay bribes.
…safeguards our reputation and builds trust
Know what’s allowed if you work with government
l with the market, by demonstrating that we
officials, recognizing that the rules are typically consistently operate with integrity
very strict.

Accurately record all payments and transactions in

l
Volvo Group’s books and records.

Conduct any required anti-corruption due diligence

l
when hiring or managing third party intermediaries.

Never accept anything from a supplier, business

l
partner, or anyone else if it might affect or
appear to affect your ability to be objective in your
business decisions.

If a supplier or business partner offers you

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inappropriate gifts and entertainment, please
raise the issue with your manager.

10
 Volvo Group Code of Conduct: We Earn Business Fairly and Lawfully

TRADE COMPLIANCE ANTI-MONEY LAUNDERING

(EXPORTS AND IMPORTS)
Money laundering allows criminals and others to
As a global company, we need to comply with in- disguise the source of funds obtained illegally. These
ternational trade rules, by which countries regulate funds may come from or support activities like hu-
the movement of products, technology, software, man trafficking, drug trafficking, terrorism, black-
and technical information across national borders. mail, or fraud. The Volvo Group does not facilitate
Violations can lead to criminal prosecution for the or support money laundering.
companies and individuals responsible, along with
bad publicity, delayed shipments, or even the loss of
For You, This Means:
import/export privileges.
Know your customer, understand the terms of
l
all transactions, and be alert for signs of money
For You, This Means:
laundering.
Investigate export license requirements before ex-
l
Report any suspicious transactions to the com-
l
porting a product or sharing technical information
pany, including third party payments, large cash
or software across national borders.
purchases, or the use of cash equivalents.
Follow our procedures to screen certain business
l
If you work for Volvo Financial Services, know
l
partners, including distributors, importers, deal-
and follow the additional requirements that
ers, and customers, as we may be prohibited from
apply to your job.
dealing with parties that are subject to sanctions.

Know and follow the trade restrictions that apply

l
where you do business. These can be complex,
as rules vary by location and may change in
response to world events.

Observe all customs and export control require-

l
ments, including documentation related to clas-
sification, valuation, and country of origin.

If you are uncertain, please contact the Export

l
Control team at Group Trucks Operations or
Legal & Compliance.

11
 We Separate
Personal
Interests
from Business
Activities

12
 Volvo Group Code of Conduct: We Separate Personal Interests from Business Activities

CONFLICTS OF INTEREST
As employees of Volvo Group, we have an obligation Who are family members?
to work in the best interests of the company, and to
avoid or disclose situations where our private, finan- Our conflicts of interest rules can extend to anyone

cial, or other external interests conflict with our job you are related to or close to.

responsibilities. In some cases, just the appearance of

This includes e.g. your: spouse, partners, parents,
a conflict may damage our reputation or effectiveness.
siblings, relatives by marriage, children, grand-
children, and the children of partners.

For You, This Means:

Understand how to recognize conflicts of interest.

l
If you face a conflict, disclose it to your manager
and work with the company to resolve the issue. AV O I D I N G C O N F L I C T S O F
INTEREST…
Make business decisions in the company’s inter-
l
ests, and not to benefit yourself or your family. …drives performance by ensuring that we make
Potential conflicts that require disclosure can decisions in the best interests of our customers and
include: the business

– A close relationship with someone you super- …drives trust in our business by demonstrating that
vise or might hire we are an honest and reliable partner

– Running a side business that does business

…supports profitability and effectiveness by ensur-
with Volvo Group
ing we choose the suppliers and vendors who

– Taking a side job with a supplier, other busi- offer the greatest value

ness partner, or competitor, especially if you
work full-time at a Volvo Group company

– If a family member takes a job with a current

or potential customer, supplier or competitor,
especially if in a key decision making role Are you a manager?

– If you or a family member holds a significant You can contact HR or Legal & Compliance for
financial investment in a current or potential support in evaluating or handling any conflicts of
customer, supplier, or competitor interest that are disclosed to you.

Do not, on your own, arrange personal transac-

l
tions with suppliers or customers on terms that
are not available to the public, such as special
pricing, financing, or discounts.

13
POLITICAL ACTIVITIES
For the Volvo Group it is important to maintain a What are political activities?
continuous dialogue with authorities and policy
makers in order to be engaged in issues that could For purposes of this Code, “political activities” means a

impact Volvo Group and our customers’ business wide range of actions, some of which we list below.

and operations. These activities are specifically

Remember, you can always take action or make contri-
authorized by Group Communication and Sustain-
butions on your own, as an individual. But you can’t use
ability Affairs.
Volvo resources or imply company support of activities like:

The Volvo Group will observe neutrality with regard to

l
Running for office
political parties and candidates for public office. Nei-
ther the names nor the assets of Volvo Group compa- l
Campaigning or fundraising for a political candidate

nies shall be used to promote the interests of political l

Volunteering time or donating to a political party
parties or candidates for public office.
l
Lobbying

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Signing or organizing statements, petitions, or
For You, This Means: letters

l
Public advocacy or statements regarding
You may support causes of your choice, but do
l
political issues
not make political or charitable contributions using
company funds or in the company’s name.

You may contribute your own time and resources,

l
but do not use working time, property, or any other
company resources to promote your personal
political interests.
THIS IS KEY
Nothing in this Section shall prohibit the operation within the
You may fundraise for political causes or
l
US of the VNA Holding Inc. Political Action Committee (called
promote political candidates, but do not do this
VG PAC). VG PAC is a legal, separate, segregated fund
while at work.
which collects voluntary donations from eligible employees to
make contributions to the campaigns of candidates for elected
public office. As long as you follow the rules of VG PAC, your
activities and donations relating to VG PAC are permitted.

14
 Volvo Group Code of Conduct: We Separate Personal Interests from Business Activities

INSIDER DEALING
While working at Volvo Group, you may come What is inside information?
across inside information that relates to the Volvo
Group or the Volvo share. Any time you have access Inside Information is non-public information which,

to inside information, you are subject to legal and if made public, would be likely to have a significant

regulatory duties and violation of these duties may effect on the Volvo share price or the price of any

constitute a criminal offense. other Volvo financial instruments.

Inside information can include:

For You, This Means: l

Unexpected significant changes in order books,
order intake or in delivery of products caused by,
Don’t use inside information by buying or selling,
l for instance, order cancellations
for your own account or for the account of a third
l
Acquisitions or divestitures of significant business
party, directly or indirectly, AB Volvo shares or
operations
related securities (insider dealing).
l
Insolvency of strategic suppliers
Don’t recommend or induce anyone else to en-
l
l
Major operational risks or disturbances in the
gage in insider dealing.
production system
Don’t make any unauthorized disclosure of inside
l l
Product quality problems or recalls
information.
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Unexpected considerable changes in
Follow our procedures on internal reporting of in-
l financial results
side information as well as notification of uninten- l
Innovative products or processes
tional disclosure.
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Legal disputes or government investigations

15
 We Safeguard
Company
Information
and Assets

16
 Volvo Group Code of Conduct: We Safeguard Company Information and Assets

C O N F I D E N T I A L I N F O R M AT I O N INTELLECTUAL PROPERTY
We all have an obligation to protect information Volvo Group’s intellectual property – such as tech-
that Volvo Group considers confidential. Theft or nical inventions, patents, copyrights, know-how,
unauthorized use or disclosure could significantly trade secrets, design and trademarks and related
hurt our business. This includes any non-public licenses – are highly valuable assets, but that value
information about our processes, products, innova- can be lost or compromised if these are misused
tion, and financial or strategic plans or position. or inappropriately disclosed. The Volvo Group will
take action to defend its intellectual property, and is
committed to respecting intellectual property that
For You, This Means: belongs to others.

Make sure you are authorized and have a proper

l
business purpose before disclosing confidential For You, This Means:
information to anyone outside the company.
Carefully protect any Volvo Group trade secrets,
l
Never post company confidential information on
l inventions, or designs and do not publish or
social media. Do not discuss confidential informa- disclose them unless you have been specifically
tion in public places or leave confidential material authorized to do so.
unattended, even in the office.
Respect and do not use material protected by
l
Protect the confidential information that suppliers,
l intellectual property that belongs to others without
business partners, and others share Volvo Group approval and third party permission.
with us.
If you have access to any confidential information
l
Please remember that your obligation to protect
l or intellectual property, handle it properly, safe-
confidential information may continue also after guard it from inappropriate disclosure, and use it
you have left the company. only in ways that are permitted. If the information
belongs to a third party, follow any agreements
with that party, including on use or disclosure.

Report any suspected or alleged unpermitted use

l
PROTECTION PROCEDURES of intellectual property of the Volvo Group or of a
third party in line with Volvo Group directives.
Practice these habits to help protect information about
our products, people, and customers:

l
Follow the requirements in the Volvo Group classi-
fication framework. Mark and handle information as
appropriate to its status as Open, Internal, Confi-
dential, and Strictly Confidential.

l
Do not give out information by phone or email in re-
sponse to unexpected requests, including employee
information, home addresses, phone numbers, or
travel plans.

l
Protect Confidential and Strictly Confidential infor-
mation when working off-site and do not store it at
home.

17
PHYSICAL AND FINANCIAL D ATA P R I VA C Y
ASSETS
When we are entrusted with personal information
Volvo Group’s assets, including financial assets, about individuals, we safeguard it and take appro-
physical property, and company devices, systems, priate steps to protect it from misuse. We observe
and networks, are critical to our ongoing productiv- all applicable privacy laws when we collect, use, and
ity and business success. We must use these assets share personal information about individuals.
responsibly and protect them from theft, careless-
ness, and waste, whether that means protecting
access to company buildings, equipment, and tools
For You, This Means:
or using good judgment when spending company
Follow company guidelines when collecting,
l
funds.
storing, using, or sharing personal information
about individuals.
For You, This Means:
Do not access personal information stored on our
l
systems, except for business purposes that reflect
Don’t use company assets, like equipment or funds,
l
the scope for which the information was collected.
to personally benefit yourself or someone else.
Let your manager know if you have access to
l
Comply with local expense report procedures and
l
personal information about individuals that you
instructions, and do not claim private expenses as
don’t need.
business expenses.

Report any theft or misuse of company inventory,

l
cash, equipment, supplies, or other assets.

PROTECTION PROCEDURES

THIS IS KEY Politely challenge strangers who do not have ap-

propriate identification and notify building security
Private use of Volvo Group IT resources should be kept to a
Protect company laptops and other mobile devices
minimum. If you use company IT resources for personal use,
from theft or loss
your right to privacy may be limited.

Use strong passwords and do not share your indi-

To prevent misuse or illegal activity, Volvo Group monitors IT
vidual passwords
activity and may also install monitoring software, including for
child pornography, as well as web and spam filters.
Securely store any removable media, including
flash drives, CDs, or external drives

When working with Volvo Group information, use

only approved Company equipment and services

Use your company email account for all work com-

munications– do not use personal email accounts
to conduct company business

18
 Volvo Group Code of Conduct

We Communicate
Transparently
and Responsibly
ACCOUNTING AND REPORTING
R E P O R T I N G H O N E S T LY A N D
We want to report in a transparent, truthful, and
timely manner in order to convey a true view of the
A C C U R AT E LY …
Volvo Group’s performance. We report financial …drives performance by ensuring that senior manage-
transactions in accordance with generally accepted ment is making decisions on the basis of accurate and
accounting practices. We report truthfully on any up-to-date information
non-financial information that we have an obligation
to disclose. …builds trust by demonstrating to the market that we
are honest and reliable

For You, This Means: …protects against fraud and ensures that Volvo Group
funds are being used in support of the company’s
Be honest and accurate when you report or record
l strategic interests
information about our business.

If you submit or approve expenses, ensure they

l
accurately reflect the transaction and comply with
company policies and procedures.

Never misstate facts when recording a transaction

l
or enter information that you know is incorrect.

If you notice an error in a financial record, or suspect

l
fraud has occurred, report it immediately.

19
Speak Up!
If you know about something that doesn’t seem right, or which
violates this Code of Conduct, we want you to speak up.

Often times, early reporting can help resolve an issue quickly

and minimize harm.

HOW DO I RAISE A CONCERN? C A N I R E P O R T A N O N Y M O U S LY ?

To express a concern, you can: Yes, as long as anonymous reports are permitted by
local law.
Talk to your manager, or your manager’s
l
manager. However, we encourage you to identify yourself
when making a complaint. This allows the company
Talk to a relevant functional group, like HR,
l to obtain all facts, properly investigate your report,
Finance, or Legal & Compliance. and enter into a confidential dialogue
with you.
Access the Volvo Group Whistle at:
l
www.volvogroup.com under “About Us”
Even if you identify yourself, every effort will be
or on Violin.
made to keep your identity strictly confidential
Write a letter to the head of Corporate Audit, at:
l within the company.

Head of Corporate Audit

AB Volvo
Department AA14400, VGHQ6
405 08 Göteborg
W H AT H A P P E N S A F T E R I R A I S E
Sweden
A CONCERN?
Once you make a report, Volvo Group will investi-
gate the situation and take appropriate actions.

If you raise a concern in good faith, Volvo Group will

not tolerate any retaliation against you. This is true
regardless of the outcome of the investigation.

20
Volvo Group Code of Conduct

21
2019