Anti slavery policy
Collectia A/S conducts business under the applicable laws and regulations in the countries in which we operate. We want to contribute to and promote good business practices, ethical responsibility, a healthy environment and respect for human rights.
For the purposes of this policy, "Collectia A/S or Collectia Group" means Collectia A/S, parent and subsidiary companies of Collectia A/S CVR number 20015381
The impact of this program:
There are several purposes of this regulatory compliance program:
- The program will 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 act on suspicions of illegal acts or behaviors that are contrary to our values.
- The program must describe methods to investigate any suspicion of illegal acts and misconduct.
- The program is designed to minimize the risk of an employee violating the law or the requirements that society has justifiably imposed on us.
- The program is designed to require our closest external business partners to comply with rules and requirements and to enable us to terminate contracts with external parties if their conduct does not comply with the requirements set.
How to define decent and honest behavior?
Decency and honesty means treating 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 properly accounted for.
- No employee may submit false documentation for invoicing purposes.
- We do not engage in money laundering or contribute to non-transparent transactions.
- No changes may be made to final documents without this being explicitly stated.
If there is any doubt about the correctness of an action, advice should be sought from the company's CFO or your immediate superior.
Anti-corruption guidelines
The Code of Conduct sets out the responsibilities of staff 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 mismanagement.
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 act or decision taken by a business partner or official when acting in an official capacity.
Payment facilitation: Small payments to civil servants with the aim of speeding up or facilitating the performance by the public servant of a routine action by the public authority.
Gifts and entertainment: Anything of value, including extraordinary discounts, loans, cash, preferential terms for any product or service, services, prizes, transportation, use of company cars or holiday facilities, shares or other securities, participation in stock offers, tickets to shows or sporting events, or gift vouchers. 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 act of the authorities: An act normally or frequently performed by an official in the course of his or her ordinary official duties. Examples include: obtaining permits, licenses or other official documents to qualify a person to conduct business in a particular area; processing visas from the authorities; providing police protection; collecting and delivering mail or telephone services; and similar acts.
Unnecessary: Something that is not earned or justified under one's normal duties or that is excessively lavish given the circumstances.
It is customary and generally accepted practice in many business relationships to offer and accept gifts and entertain business partners. However, it is illegal to bribe a business partner or official.
A bribe can take many forms: giving something of value - whether it is an honorarium, a substantial gift, lavish entertainment, cash or benefits in kind - can constitute a bribe if the gift is given knowingly to influence the recipient's behavior in order to obtain a business advantage. Giving something of value is improper and illegal if the gift, money, etc. is an attempt to persuade the business partner or official to behave or refrain from behaving in accordance with his or her job function - or in a way that gives improper advantage to the person or company offering the bribe.
A bribe is improper 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 superior if you suspect that an employee, agent or distributor is involved in bribery, either directly or indirectly.
Any employee may be exposed to a conflict of interest. It is important to protect both Collectia Group and all employees from the occurrence or suspicion that an action has been influenced by irrelevant personal considerations.
A conflict of interest always makes the employee unsuitable to act on behalf of Collectia Group. If an employee finds himself or herself in such a situation - either actually or apparently - it must be disclosed to the immediate superior, who is responsible for managing 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 an enterprise owned by an employee
- Decisions affecting the employee's financial situation or that of a close relative, e.g. concerning 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 benefits for the employee
- Employment of 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 Executive Director or the Chief Financial Officer.
In some countries, accelerated payments are allowed under local law and tradition. However, such payments are not allowed under this policy.
Relationships with suppliers and customers must be based solely on sound business decisions and fair dealing. Offering and accepting a modest gift and inviting business partners to a restaurant and accepting such invitations can strengthen good relations and thus business, but gifts and entertainment can also create a conflict of interest.
An employee of Collectia Group must never offer or give a gift, entertainment or anything of value if it is
- Illegal(t)
- Known to be against the rules of the recipient's organization
- Cash or cash equivalents
- Inappropriate, sexually oriented or otherwise contrary to Collectia Group's corporate values
- Given in return for something promised, given or done by the recipients or as part of an agreement to do anything in return for the gift or entertainment.
Receiving gifts and entertainment of a significant size or extravagant entertainment from suppliers is not permitted because this might be or could be seen as an attempt to influence the business decisions of Collectia Group employees. 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. An employee of Collectia Group must never:
- Receiving a gift or entertainment that may be illegal or result in breaking the law
- Receive a gift in the form of cash or equivalent liquid assets (such as gift vouchers, loans, shares, stock options); or
- Receive or ask for something if the Collectia employee receives it in return 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.
Whenever 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 kept.
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 act that facilitates money laundering or finances terrorist or criminal activities by complying with all applicable requirements under anti-money laundering legislation, including Danish and EU sanctions regulations and U.S. Internal Revenue Service sanctions regulations for the control of foreign assets.
Money laundering is generally defined as engaging in acts undertaken to conceal or disguise the truth about the proceeds of crime in a way that makes the proceeds appear to be of legitimate origin or from legitimate assets.
It is the Company's policy to prohibit and prevent money laundering and any act that facilitates money laundering or finances terrorist or criminal acts by complying with all applicable requirements under the Anti-Money Laundering Law (AML) and its implemented regulations.
Know Your Customer (KYC) - We duly identify new customers when they open an account. The minimum identification requirements to open a new account are listed below: If a customer refuses or is unable to 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 clients to sign our ESG Code of Conduct as part of our enhanced credentialing procedures. Although this signature is not directly linked to money laundering, we assume that it goes some way to preventing potential clients who intend to misuse Collectia Group for money laundering purposes from being approved. The Code of Ethics to which new clients must adhere reads as follows:
- The 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
Furthermore, as Collectia Group is a debt collection company, we have decided that we do not work with customers who charge excessive interest rates and fees. We consider excessive interest and fees to exceed:
- the legal limits; and
- our own assessment of what is a fair total compensation for interest and fees, taking into account the size of the loan, the loan period, the credit check carried out by our customer 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 carried out in relation to all new customers before we enter into a cooperation with such new customers.
Minimum identification requirements (KYC) - Commercial accounts.
According to our ERP system, CollectIT, there are a number of data records that are required for all new customers. The most important information is as follows:
- Name
- Complete billing address (street name and number, postal code)
- Telephone number, contact person, e-mail
- CVR number
- Bank account details
Minimum identification requirements - Consumer, business or company.
In accordance with 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 that are linked to the same customer. Collectia A/S accepts regular cash payments as long as each transaction is under 20,000 DKK. Collectia A/S does not accept that a customer deliberately splits a transaction totaling DKK 20,000 or more into several small orders/transactions to keep the amount below the set limit. All transactions above 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 access functions within their assigned security area. The banking interface uses two-factor authentication.
Guidelines in relation to suppliers
Our suppliers must comply with the standards set out in this program. The program must be included as an annex when renewing current agreements or when entering into future agreements.
Suppliers must guarantee that they do not use child or forced labor as part of their production and that production otherwise complies with the laws of the country where the supplier is based.
The Procurement 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 the sale of our products.
Agreements concluded with our business partners (new agreements or after revision of long-term agreements) must include provisions on
- Acts or omissions contrary to the requirements set out in this program shall constitute a breach of contract of the agreement
- Business Partners are obliged to inform Collectia A/S of incidents that potentially constitute a breach of the requirements.
In the event of a breach of contract, Collectia A/S will cancel the business cooperation with the Business Partner in question.
The CFO/Head of Trade Agreement Enforcement shall carry out an annual 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 provided for in the agreement concluded.
The Senior Trade Agreement Enforcement Officer must carry out a risk assessment of trade with suppliers/distributors in specific countries and territories on an annual basis - or in case of changes in current circumstances.
Implementation
The company's CFO is responsible for implementing and maintaining the program.
The CFO may delegate responsibility for day-to-day follow-up and maintenance.
A dedicated Senior Trade Agreement Enforcement Officer may be appointed who is responsible for communicating this program to new staff in relation to any follow-up for compliance with the program and for reviewing the program and the underlying policies.
All staff, regardless of their function, may contact the Director of Finance/Senior Trade Agreement Enforcement Officer directly on issues described in this program.
Contact details: Updated contact details of the Chief Financial Officer/Chief Trade Enforcement Officer are available on our intranet.
As an employee of Collectia A/S, you must read and understand the guidelines that are relevant to your field of work
It is your duty to inform the Chief Financial Officer/Chief Trade Enforcement Officer or your immediate superior if you receive information indicating that one or more of your colleagues are acting in breach of the established guidelines.
Examples of infringements that you need to report are
- Receiving or offering bribes.
- Misuse of public funds.
- Discriminatory behavior by management or colleagues.
- Provision of deficient services, attempts to conceal the deficiencies.
- Incorrect reporting of time spent or prices of goods sold.
- Other "disloyalty" towards customers or business partners.
- Requests from superiors for unfair conduct - even if such a request was refused.
Every employee is responsible for doing his or her job honestly.
Everyone is obliged to seek advice from their immediate superior if there is any doubt about correct conduct.
Any employee who does not comply with the rules of the policy or fails to report abuse can expect to face disciplinary sanctions.
Any employee who reports incidents receives protection and this applies to those who act in accordance with our requests.
All reports submitted in good faith are taken seriously and investigated The Director of Finance/Senior Trade Enforcement Officer has a duty of confidentiality towards all persons other than senior management. Requests for anonymity are honored to the extent permitted by law.
The program should be communicated at staff meetings and at the induction of a new employee.
The program must be available on our intranet and sent electronically to all staff.
The guidelines affecting suppliers, distributors and agents must be reviewed with the parties concerned when the relevant agreements are concluded 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.
New risk assessments must be carried out each 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 duties of the CFO/senior trade agreement enforcement officer in case of suspected non-compliance:
- Notification of the Executive Board
- Notification of the external auditor, if necessary
The Executive Board shall, within 48 hours of receipt of the notification, set up an inquiry group 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 consultancy.
- Protection of a whistle-blower.
- Showing respect for and protecting the "suspect".
- Preventive measures: Preventing the unfair and undesirable activity
- Completion of the survey.
- Reporting.
The Executive Board shall inform the Management Board of any significant incident or report of incidents that may affect the reputation of the undertaking.
In the event of significant incidents subject to the program, the CFO/CCO shall make a recommendation to the Executive Board that the program or the requirements/guidelines be amended.
The CFO/Senior Trade Agreement Enforcement Officer shall, depending on the circumstances, initiate or train his/her core staff to avoid recurrence.
The CFO/Senior Trade Agreement Enforcement Officer is responsible for documenting our efforts and level of compliance by keeping all relevant documentation such as
- Control lists.
- Written report.
- Description of measures adopted.
The policy and any amendment to the policy must be adopted by the Board of Directors of Collectia A/S.
Approved by the Governing Board, February 2021.