Anti slavery policy
Collectia A/S conducts business under the applicable laws and regulations in the countries where we operate. We want to contribute to and promote good business practices, ethical responsibility, a healthy environment and respect for human rights.
In this policy, "Collectia A/S or Collectia Group" means Collectia A/S, parent and subsidiaries of Collectia A/S cvr number 20015381
The impact of this program:
There are several purposes for this regulatory compliance program:
- The program should show the outside world and our employees that we stand for and want to be known for decent and honest business practices.
- The program is designed to encourage and empower our employees to take action when they suspect illegal actions or behavior that goes against our values.
- The program must describe methods to investigate any suspected illegal actions and misconduct.
- The program must minimize the risk of an employee violating the law or the requirements that society has rightfully imposed on us.
- The program shall require our closest external business partners to comply with rules and requirements and enable us to terminate contracts entered into with external parties if their behavior does not comply with the set requirements.
How is decent and honest behavior defined?
Decency and honesty means that we treat our customers with integrity in the following way:
- We do our best to protect confidential information. We never reveal trade secrets or anything that could potentially harm a customer.
- We are able to document all services received or provided.
- All services and payments must be booked correctly.
- No employee may present false documentation for invoicing.
- We neither participate in money laundering nor contribute to transactions that are not transparent.
- No changes may be made to final documents without this being explicitly stated.
If there is any doubt about the correctness of an action, seek advice from the company's CFO or your immediate manager.
Anti-corruption guidelines
The Code of Conduct sets out the responsibilities of employees within Collectia Group to ensure guidance with regard to bribery and conflicts of interest. The purpose is to provide guidelines to all staff to protect Collectia Group from the consequences of mishandling.
Bribery: Promising, offering or giving, indirectly or directly, an undue advantage to a business partner or official in order to obtain or retain business, obtain an undue or improper advantage or influence an action or decision taken by a business partner or official when acting in an official or governmental capacity.
Payment facilitation: Small payments to public officials for the purpose of speeding up or facilitating the public official's performance of a routine government action.
Gifts and entertainment: Anything of value, including extraordinary discounts, loans, cash, favorable terms for any product or service, services, prizes, transportation, use of company cars or vacation facilities, stocks or other securities, participation in stock offerings, tickets to shows or sporting events or gift cards. These are just some of the potentially endless examples.
Official: Any official, employee or person acting in an official capacity or on behalf of an authority, including any entity controlled by the authorities.
Routine government action: An action usually or frequently performed by an official in the course of his or her regular official duties. Examples include: obtaining permits, licenses, or other official documents to qualify a person to do business in a particular area; processing government visas; securing police protection; picking up and delivering mail or telephone services; and similar actions.
Unnecessary: Something that is not earned or justified in the course of one's normal duties, or is overly lavish given the circumstances.
It is customary and generally accepted practice in many business relationships to offer and receive gifts and entertain business partners. However, it is illegal to bribe a business partner or official.
A bribe can take many forms: Giving anything of value - whether it is a fee, a substantial gift, lavish entertainment, cash or benefits in kind - can constitute a bribe if it is given deliberately to influence the recipient's behavior in order to gain business advantage. Giving anything of value is wrong and illegal if the gift, money, etc. is an attempt to persuade the business partner or official to behave or not to behave in accordance with his or her job function - or in a way that gives the person or company offering the bribe improper advantages.
A bribe is wrong and illegal whether given directly or indirectly. Indirect bribes include payments made through third parties working on behalf of Collectia Group. Always inform your immediate supervisor if you suspect that an employee, agent or distributor is involved in bribery, either directly or indirectly.
Any employee can be exposed to a conflict of interest. It is important to protect both Collectia Group and all employees from the appearance or suspicion that an action has been influenced by irrelevant personal considerations.
A conflict of interest always makes the employee unfit to act on behalf of Collectia Group. If an employee is in such a situation - either real or apparent - it must be reported to the immediate supervisor, who is responsible for handling the situation without involving the person who has a conflict of interest.
The list of potential conflict of interest includes, but is not limited to, issues such as:
- Contracts with a company owned by an employee
- Decisions that affect the employee's financial situation or that of a close relative, e.g. regarding business with a company in which the employee has a financial interest
- Decisions that otherwise affect the interests of an employee's close relatives
- Loans and other employee benefits
- Hiring close relatives of the employee.
In general, a close relative or an employee should not have any business dealings with the employee, with persons working in the employee's department, or with persons reporting to the employee. Exceptions must be approved by the CEO or CFO.
In some countries, payment facilitation is allowed according to local law and tradition. However, such payments are not permitted under this policy.
Relationships with suppliers and customers should be based solely on sound business decisions and fair practices. Offering and receiving a modest gift and inviting business partners to a restaurant and receiving such invitations can strengthen good relationships and thus business, but gifts and entertainment can also create a conflict of interest.
A Collectia Group employee must never offer or give a gift, entertainment or anything of value if it is:
- Illegal(t)
- Known to be in violation of the rules of the recipient's organization
- Cash or cash equivalent
- Obnoxious, sexually oriented or otherwise contrary to Collectia Group's corporate values
- Given in exchange for something the recipients have promised, give or do or as part of an agreement to do anything in return for the gift or entertainment.
Accepting gifts and entertainment of a significant size or extravagant entertainment from suppliers is not permitted because this may be or may be seen as an attempt to influence Collectia Group employees' business decisions. Such gifts should be politely returned and invitations respectfully declined.
Certain types of gifts and entertainment should never be accepted because they are either genuinely or apparently wrong. A Collectia Group employee must never:
- Receiving a gift or entertainment that may be illegal or result in a violation of the law
- Receive a gift in the form of cash or equivalent liquid assets (such as gift cards, loans, shares, stock options); or
- Receive or ask for something if the Collectia employee receives it for something the employee has promised, given or done or as part of an agreement to do something in return for the gift or entertainment.
Every time a gift or entertainment is given to a business partner, this must be recorded in the accounts. The record must explicitly point out the type and purpose of the expense and the record must be preserved.
Guidelines and measures to prevent money laundering
This Code of Conduct sets out Collectia Group's policy on money laundering.
The purpose is to prohibit and actively prevent money laundering and any acts that facilitate money laundering or the financing of terrorist or criminal acts by complying with all applicable requirements under anti-money laundering laws, including Danish and EU sanctions regulations and US Treasury Department sanctions regulations for foreign asset controls.
Money laundering is generally defined as engaging in acts undertaken to cover up or conceal the truth about the proceeds of crime in a manner that makes the proceeds appear to be of legitimate origin or from legitimate assets.
It is Company policy to prohibit and prevent money laundering and any act that promotes money laundering or finances terrorist or criminal acts by complying with all applicable requirements under the Anti-Money Laundering Act (AML) and its implemented regulations.
Know Your Customer (KYC) - We properly identify new customers when they open an account. The minimum identification requirements for opening a new account are listed below: If a customer refuses or cannot provide the requested information, the account will not be created in our ERP system and the customer will not be able to purchase our services.
At Collectia Group, we require new customers to sign our ESG Code of Conduct/Code of Ethics as part of our enhanced credentialing procedures. Although this signature is not directly linked to money laundering, we assume that it somewhat prevents potential customers who intend to misuse Collectia Group for money laundering from being approved. The code of ethics that new customers must adhere to is as follows:
- Customer's product/service must not be illegal or contrary to the public interest
- The customer must not use child labor
- The customer sells genuine products/services that are clear to the customer
- The customer must pay its employees the agreed minimum wage
As Collectia Group is a debt collection company, we have also decided that we do not work with customers who charge excessive interest and fees. We consider excessive interest rates and fees to be excessive:
- the legal limits and
- our own assessment of what is a reasonable total compensation for interest and fees, taking into account the size of the loan, the loan term, the credit check our customer performs and the customer's general reputation.
The latter condition is based on an assessment by our senior management team in Collectia Group. The assessment of interest and fees is performed in relation to all new customers before we engage with such new customers.
Minimum identification requirements (KYC) - Commercial accounts.
According to our ERP system, CollectIT, there are a number of data items that are required for all new customers. The most important information is as follows:
- Name
- Complete billing address (street name and number, postal code)
- Phone number, contact person, email
- CVR number
- Bank account details
Minimum identification requirements - Consumer, business or company.
According to international anti-money laundering legislation, Collectia A/S does not accept cash payments of DKK 20,000 or more as payment, even if the payment is made as a single payment or if the payment is divided into several small payments linked to the same customer. Collectia A/S accepts regular cash payments as long as each transaction is below DKK 20,000. Collectia A/S does not accept that a customer deliberately divides a transaction totaling DKK 20,000 or more into several small orders/transactions to keep the amount below the set limit. All transactions over 20,000 DKK must be made via a bank transfer.
We use a professional ERP system that is integrated with our Active Directory. This means that any authorized person has access to the system and they can only enter functions within their assigned security area. Bank interface uses two-factor authentication.
Guidelines in relation to suppliers
Our suppliers must comply with the standards set forth in this program. The program must be included as an appendix when renewing current agreements or entering into future agreements.
Suppliers must guarantee that they do not use child labor or forced labor as part of their production and that the production otherwise complies with the laws of the country where the supplier lives.
The purchasing department has prepared a declaration to be signed by all relevant suppliers whereby such suppliers commit to comply with ILO Conventions No. 182 and No. 138 on child labor.
Distributors and agents must not engage in bribery or illegal competition in connection with the sale of our products.
Agreements concluded with our business partners (new agreements or after revision of long-term agreements) shall contain provisions on:
- Acts or omissions contrary to the requirements set forth in this program constitute a breach of contract
- Business partners are obliged to inform Collectia A/S of incidents that potentially constitute a violation of the requirements.
In case of a breach of contract, Collectia A/S will cancel the business cooperation with the business partner in question.
The CFO/Senior Trade Enforcement Officer shall annually conduct a risk assessment of our business partners to assess whether these guidelines should be imposed on one or more companies in particular, or whether such companies should be subject to a possible control to the extent permitted by the agreement entered into.
On an annual basis - or when circumstances change - the chief trade enforcement officer must conduct a risk assessment of trade with suppliers/distributors in specific countries and territories.
Implementation
The company's CFO is responsible for implementing and maintaining the program.
The CFO can delegate responsibility for daily follow-up and maintenance.
A dedicated senior trade enforcement officer may be appointed who is responsible for communicating this program to new employees in relation to any follow-up for compliance with the program and for reviewing the program and underlying policies.
All employees, regardless of function, may contact the CFO/Senior Trade Enforcement Officer directly regarding issues described in this program.
Contact details: Updated contact details of the CFO/Senior Trade Enforcement Officer are available on our intranet.
As an employee at Collectia A/S, you must read and understand the guidelines that are relevant to your field of expertise
It is your duty to notify the CFO/Senior Trade Enforcement Officer or your immediate superior if you receive information indicating that one or more of your colleagues is acting in violation of the established guidelines.
Examples of violations that you need to report are:
- Receiving or offering bribes.
- Misuse of public funds.
- Discriminatory behavior from management or colleagues.
- Providing defective services, trying to hide the defects.
- Incorrect reporting of time spent or prices of goods sold.
- Other "disloyalty" to customers or business partners.
- Requests from superiors for unreasonable behavior - even if such request was denied.
Every employee is responsible for doing their job in an honest manner.
Everyone is obligated to seek advice from their immediate supervisor if in doubt about proper behavior.
Any employee who fails to comply with the policy or fails to report abuse can expect to face disciplinary action.
Any employee who reports incidents is protected and this applies to those who act in accordance with our requests.
All reports submitted in good faith are taken seriously and investigated The Chief Financial Officer/Senior Trade Enforcement Officer has a duty of confidentiality to anyone other than senior management. Requests for anonymity will be honored to the extent permitted by law.
The program should be communicated in employee meetings and when introducing a new employee.
The program must be available on our intranet and sent electronically to all employees.
The guidelines affecting suppliers, distributors and agents must be reviewed with the parties concerned when the agreements in question are entered into or renewed.
Follow-up action, audit and control
It is the responsibility of senior management to assess whether the program is having the desired effect and to inform the board in such a way that the board determines the outcome of such assessment.
The conclusion of new contracts or the establishment of new business procedures is subject to a risk assessment, and all guidelines etc. must be revised as a consequence of this.
New risk assessments must be performed every time incidents are reported.
Campaigns should be launched regularly and at least every two years to raise awareness of the guidelines and encourage employees to submit their reports if necessary.
The CFO/Senior Commercial Enforcement Officer's duties in case of suspected non-compliance:
- Notification of the Executive Board
- Notifying the external auditor if necessary
Within 48 hours of receipt of the notification, the Executive Board shall establish an investigation team to follow up on the notification. Depending on the case at hand, the Executive Board shall also decide on its practical course of action, including:
- Interviews etc., their form and content.
- External consulting help.
- Protecting a whistle-blower.
- Showing respect for and protecting the "suspect".
- Preventive measures: Preventing the unfair and unwanted activity
- Completion of the survey.
- Reporting.
The Executive Management shall inform the Board of Directors of any significant incident or report of incidents that may affect the company's reputation.
In the event of significant incidents subject to the program, the CFO/Senior Trade Enforcement Officer shall make a recommendation to the Executive Board that the program or requirements/guidelines be amended.
The CFO/Senior Trade Enforcement Officer shall initiate or train his/her core staff, as appropriate, to avoid recurrence.
The CFO/Senior Trade Enforcement Officer is responsible for documenting our efforts and level of compliance by keeping all relevant documentation such as
- Control lists.
- Written notification.
- Description of adopted measures.
The policy and any changes to the policy must be adopted by the Board of Directors of Collectia A/S.
Approved by the Board of Directors, February 2021.