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Code of Conduct

Midagon's Ethical Principles

CEO's foreword

Midagon’s ethical principles are based on the laws and regulations that apply to all of us. However, we want to aim higher and do business in a fair and responsible way, taking into account our people, clients, other stakeholders, the environment and society as a whole. 
 
Our shared values, client and employee promise support and guide our work. We are dedicated to our clients' success and operate transparently and honestly. For us, redefining consulting means helping solve our clients’ most complex challenges to truly make a difference in their business – without compromising our people's well-being or healthy work-life balance. 
 
This Code of Conduct includes the ethical principles we expect our people, business partners and suppliers to familiarise themselves with and follow in their daily work. It provides tools and support for exercising our company values in practice, preventing issues and problems and taking action if violations occur. 

Ilkka Töyrylä
Group CEO

About this Code of Conduct

Midagon is a transformation company that bases its operations on experience, objectivity and integrity. Midagon acts responsibly, ethically and according to laws and regulations as well as the commitments it has made to its clients, employees and other stakeholders. Midagon expects its employees, business partners and suppliers to read, understand, and comply with this Code of Conduct, speak up and voice concerns if they suspect any misconduct and ask for advice when uncertain about the right thing to do. 
 
By agreeing to work with or for Midagon, the employee, business partner or supplier confirms that they and their potential affiliates comply with this Code of Conduct. The business partner or supplier shall ensure that its suppliers, subcontractors, consultants and business partners comply with the principles of this Code of Conduct. 

Ways of Working

Midagon works as one team. Midagon expects everyone to respect and support their colleagues, suppliers and clients. 
 
Midagon’s employees and suppliers are expected to follow our clients’ and Midagon’s guidelines in their projects and daily work. Our employees and suppliers are expected to approach client projects with a positive attitude and to help clients to succeed in their business transformations. 

Integrity & Values

The following are Midagon’s shared company values. These values are to be followed in all situations. 

  • Client success: We are dedicated to helping our clients succeed in their critical and challenging transformations. As independent and objective advisors, we have no hidden ties or partnerships that compromise our solution and vendor-neutral position. With our collective expertise and experience, we proactively help clients to ensure their success from strategy to action. We say what we do and do what we say. We wrap our sleeves and get to work. We are down to earth. 

  • Together: We support each other and share our knowledge. We learn, develop and grow as individuals, teams and a company. We work as one team with the client. Our work is based on honesty, integrity and trust. We are responsive, helpful and easy to approach. We treat everyone equally and respectfully as individuals with unique skills, passions and interests. 

  • Quality of life: We support the quality of life of our people and provide a healthy work-life balance as its basis. We foster independence, flexibility and responsibility. We build a humane, positive and relaxed culture. We build possibilities for people to grow, succeed and enjoy life. 

Honesty and integrity are expected from Midagon’s personnel, business partners and suppliers. As a company, we serve our clients with full transparency and expect the same from our suppliers. 
 
Midagon’s employees and suppliers shall be aware of, and follow the applicable laws and regulations in the countries where they operate. This includes adhering to regulatory best practices. If laws or other directives are unclear, the employee or supplier is expected to contact Midagon’s leadership team. Midagon’s employees and suppliers are expected to be good citizens wherever they operate.  

Human rights

Midagon is committed to respecting internationally acknowledged human rights and aims to take effective measures to avoid adverse human rights impacts which could directly or indirectly be associated with our operations. Midagon expects its employees, business partners and suppliers to respect human rights in their operations and to aim to do their part to contribute to the realisation of these rights. 
 
Even if not directly applicable to Midagon’s business, Midagon does not accept the use of child labour, any form of forced or compulsory labour or other human rights violations. Midagon neither accepts discrimination, harassment, violence, mental coercion or verbal threats. Midagon follows applicable employment legislation and respects the freedom of association, the right to collective bargaining and the right to freedom of opinion and expression, as defined in the ILO conventions. 

Responsibility & Sustainability

Midagon aims to increase the wealth and well-being of its stakeholders and society as a whole. Midagon acts responsibly by paying fair salaries and taxes, promoting employee ownership and advocating a healthy work-life balance. Midagon ensures that all of its employees are provided with employment documents that are freely agreed upon and which respect their legal and contractual rights. Midagon complies with good governance practices in decision-making and management. Our principles include openness in reporting and our governance methods, including authorisations, are stated in writing in our Corporate Governance guidelines. 
 
Midagon strives for sustainability in all of its operations. Midagon continually looks for ways to minimise waste and to reduce emissions from its operations and services. Midagon uses energy and material resources efficiently. Midagon’s suppliers are encouraged to have a systematic approach to protecting the environment. We also seek to lower the environmental footprint, compensate for emissions as well as improve resource efficiency, thus increasing responsibility in our daily operations as well as in our client assignments. Midagon supports social and environmental causes, which are decided case by case. 

Safety & Security

The safety of Midagon’s employees and other stakeholders is very important to us. Midagon’s employees and suppliers are expected to follow the valid safety guidelines of Midagon and its clients and to take practicable steps to prevent injuries. This includes health security. Midagon’s employees and suppliers are strongly encouraged to use Midagon’s and our clients’ offices, only when feeling healthy and not presenting symptoms of illness, such as flu or fever. Midagon’s employees or suppliers shall not be under the influence of alcohol or any other drug while working. 
 
Midagon’s employees have the responsibility to know the contents of the agreements that apply to their work. Midagon’s employees and suppliers shall safeguard Midagon’s and its clients’ intellectual property and data, including personal data, in accordance with all applicable laws, NDA’s and contracts. They shall ensure that the level of its information security is adequate to keep all such information confidential and secure. The minimum level of security is described in Midagon’s information security guidelines. 
 
Midagon respects everyone’s right to privacy. We process personal data in compliance with good data processing practices and applicable legislation. 

Objectivity & Non-Discrimination

Midagon does not tolerate discrimination based on gender, gender identity, age, religion, belief, marital status, sexual orientation, political opinion, national or ethnic origin, health, disability, or other similar characteristics. Midagon’s employees or suppliers shall not tolerate any form of harassment or discrimination. Midagon respects and ensures that no employee or supplier is subject to any physical, sexual, psychological or verbal harassment, abuse or other form of intimidation. 
 
Midagon values objectivity and trustworthiness. Midagon’s employees and suppliers shall avoid situations where personal interests conflict with those of Midagon or its clients. Employees and suppliers shall disclose to Midagon any conflict of interest or situations that could be perceived to be conflicting, for example, if an employee or his/her immediate family member:   

  • holds a material, financial or other interest in the client, supplier or other service provider 

  • holds a managerial position with the client or  

  • works for the client and such employment creates a conflict of interest or appearance thereof.  

 
A gift must not compromise the neutrality and objectivity of Midagon at client assignments nor affect internal decision-making. All gifts, entertainment and hospitality, must have a legitimate business purpose. They must be acceptable under the local laws, business practices and the client’s Code of Conduct. You should not take or give a gift or benefit which would be unsuitable for you to receive.   

Raising concerns

If you are concerned about what is considered appropriate conduct, or you suspect that this Code of Conduct is being violated, please contact Midagon's Group CPO Vesa Sahlman. 
 
Midagon reviews reports carefully, handles personal data appropriately and maintains the confidentiality of reports to the extent possible. Midagon does not tolerate retaliation against any person who, in good faith, reports suspected misconduct or participates in an investigation to resolve suspected misconduct.

A whistleblowing channel enabling the anonymous reporting of suspected misconduct is available at: www.midagon.com/whistleblowing.

Employees, business partners or suppliers who violate the law or this Code of Conduct are subject to appropriate disciplinary actions.

Detailed instructions are available in Midagon’s Personnel Handbook.