Code of Conduct and our values

1. Introduction

Humana's vision is "Everyone is entitled to a good life". To live up to this, we must be a reliable, safe and stable care company with high quality and safety in everything we do. It also means that we must work in an ethical and responsible manner and contribute to long-term sustainability for society.

The Code of Conduct is based on Humana's core values, which safeguard the equal value of all people. It clarifies our values, provides guidelines for desired behaviours and explains requirements and expectations for all employees to act ethically and responsibly. Together we have worked out the values Commitment, Joy and Responsibility. The words themselves are beautiful, but it's how we live them that really matters.

2. Scope

This Code of Conduct covers all parts of and all employees within the Humana Group. The responsibility arising from the Code of Conduct applies in relation to all employees, customers, clients, relatives, suppliers, investors and other partners. For suppliers, this Code of Conduct is supplemented by the "Code of Conduct for suppliers".

3. Main principles

Humana cherishes a sustainable relationship with and between each individual in our company and we believe in mutual respect.

Humana shall comply with laws, ordinances and regulation in the countries where we operate. We regard these as minimum requirements.

In terms of human rights and labour law, in addition to legislation, Humana shall also follow international frameworks, such as the UN's Guiding Principles on Business and Human Rights, the OECD's Guidelines for Multinational Companies on Responsible Business, and the ILO's Declaration on Basic Principles and Rights on the workplace.

Humana shall apply collective agreements for all employees.

4. We treat everyone with respect and dignity

Everyone at Humana shall be treated with respect and dignity. No one may be discriminated against or harassed because of:

• gender
• transgender identity or expression
• ethnicity
• skin colour
• religion or other belief
• political view
• social or cultural background
• disability
• sexual orientation
• age

Equal treatment is a matter of course and we strive for diversity, equity and inclusion. Harassment, bullying, threats, oppression or other offensive treatment must not occur at Humana. Nor should anyone be discriminated against because of political involvement.

5. We protect children's rights

Humana shall work to ensure that all decisions and all work concerning the children in our operations are carried out in accordance with the UN Convention on the Rights of the Child.

This means, among other things, that:

• All children shall be seen as their own individuals and met with respect for their own person, conditions, needs, will and interests.
• All children shall have the same rights and opportunities regardless of gender, social class, ethnic background, disability or place of residence.
• Every child shall have the right to express their opinions and to have them respected.
• Every child shall be given the opportunity to participate in the planning of their care or intervention.

6. We protect vulnerable groups

We look after particularly vulnerable groups in society, to which many of our customers and clients count, and we shall safeguard their rights and needs. We shall also be an inclusive workplace that strives to offer jobs with Humana to people who are otherwise far from the labour market. We identify and deal with any negative effects that Humana may cause to vulnerable groups by having a systematic dialogue with, above all, our customers, clients and their relatives, but also with our employees.

7. We protect the individual's privacy and protect personal data

Humana handles large amounts of personal data, and a significant part is of particularly sensitive nature. The individual's right to privacy and control over their personal data is a human right that all employees within Humana shall protect and respect when working with personal data.

This means that we must always comply with current legislation on confidentiality and protection of personal data, which includes all sensitive and confidential information about Humana's customers, clients and employees. We also treat the registration, archiving and use of data about customers, clients and employees confidentially and in accordance with current legislation.

8. Our employees are welcome to influence

Humana strives for an environment where our employees are involved and have the opportunity to influence the business and their work. We shall have a democratic approach to issues concerning employees' ability to influence and we shall ensure that dissent is respected. Freedom of speech, the right to form or join a trade union and to be protected as a whistleblower are all self-evident freedoms and rights for Humana's employees.

9. Our work environment shall be safe, healthy and sustainable

Humana's work environment shall be safe, healthy and sustainable, both from a physical, psychological and social point of view, and be in compliance with laws and agreements. We shall work systematically and preventively to constantly improve the working environment and health.

We shall have competent leaders who can create a good working environment where our employees thrive and feel good. We shall also offer skills development and our terms of employment shall be market-based and in accordance with collective agreements.

10. Whistleblowers are protected

All persons who, in a work-related context, have had access to or obtained information about work-related misconduct can report this through Humana's whistleblower function. This means that a person in this circle can choose to report something anonymously and that an independent function handles the matter. Provided that the reporting person, at the time of reporting the work-related misconduct, had reasonable grounds to believe that the information about the misconduct was true, the person is protected by immunity from liability for breach of confidentiality and prohibition against obstruction and retaliation.

Humana's whistleblower function can be accessed via Humana's external websites and is available in Humana’s respective languages.

11. Our information shall be honest and transparent

Information from Humana shall be open and accessible, within the rules that apply to listed companies. Marketing and contacts with customers and clients must be honest and not promise anything that does not correspond to reality.

12. We shall act ethically and responsibly in all business relationships

Humana's operations shall be characterized by high ethical standards, sound business practice, awareness of our responsibilities and impartiality. We shall live up to the agreements and agreements we have signed. They shall be respected according to its spirit, not just according to its letter.

We shall treat our competitors in a correct manner and at the same time make use of our competitive advantages. There must be no price collusion, cartel formation or abuse of market position.

We do not accept any form of corruption. Instead, we work actively to promote actions and behaviors that are permeated by our values. Our employees must never give or accept bribes or any unauthorized compensation in any form. Every employee must always avoid risks of bribery and other inappropriate influence in their relationship with customers, suppliers and other external contacts. It is not permitted to request or promise anything in connection with gifts. Representation and gifts must be open, moderate and have a natural connection with the business relationship.

If anyone suspects or knows that bribery or corruption is taking place within Humana, they must report this to the nearest manager or via the company's deviation or whistleblower system. Humana acts if suspicions or occurrences of bribery and corruption arise.

Humana is neutral in party-political matters and never lends the company's name to political parties.

13. Risk of conflicts of interest shall be managed

It is important that all employees handle personal and financial interests in a way that does not conflict with Humana's business operations. Each employee is obliged to:

• inform their manager if the employee has another business or sideline that may pose a risk of conflict of interest.
• manage personal and financial interests so that they do not conflict or may be perceived as conflicting with Humana's business operations.
• report to their manager if the relationship with an external party constitutes conflict of interest, for example if the employee is friends with a proposed supplier. Then the process must be adjusted to take the potential conflict of interest into account.

Employees may not exploit the relationship with business partners for personal gain. Business partners can be, for example, customers, suppliers and other stakeholders.

14. Risk assessment and reporting for the protection of human rights

Humana shall ensure that risk assessments and routines for deviation reporting and management work in all our operations. These help us to identify, assess, manage and mitigate risks or effects of restrictions on human rights. We shall also report on how we handle the impact on human rights.

15. Sustainability is the goal of our business

Working with sustainability is the core of Humana's operations and a prerequisite for being able to achieve our Group goals.

15.1 Sustainability is about taking social responsibility

Humana's greatest contribution to a sustainable society is through providing health care and care where the health, protection and safety, non-discrimination and personal integrity of our customers and clients are our highest priority. We also take social responsibility by being a responsible employer who works for good working conditions, a good working environment, skills development and the promotion of diversity, inclusion and equity for our employees.

15.2 Sustainability is about taking responsibility for the environment

Humana shall have environmental work in place that ensures that we minimize our direct and indirect negative impact on the environment, without sacrificing our main task. The work must be based on gradual improvement and we shall always strive to use resources as wisely and efficiently as possible and work actively to reduce our climate footprint.

15.3 Sustainability is about taking financial responsibility

Sustainability is also about finances. The long-term strategy needs to be consistent with the Group's sense of responsibility towards both customers and shareholders. This will boost customer satisfaction as well as profitability.

16. Roles and responsibilities for implementation of the Code of Conduct

Everyone within Humana has a responsibility to ensure that the Code of Conduct not only exists but is also complied with. This applies to both employees, managers, Group Executive Management and the Board of Directors.
In connection with employment, each new employee acknowledges that he or she has read and will comply with the Code of Conduct.

17. Continuous improvements and possible deviations

All employees are encouraged to highlight good ideas and suggestions for improvements to Humana's operations and to draw attention to any deviations or shortcomings, this also applies in relation to the Code of Conduct. There are both deviation management systems, accessed via Humana's intranet, and feedback and complaint systems accessed via Humana's external websites.

Humana's employees and others who have or had a work-related relationship with Humana can also report serious misconduct through Humana's whistleblower function.
Employees who are unsure of how Humana's Code of Conduct should be interpreted are welcome to contact the group's Head of Quality and Compliance. Violations of this policy shall be reported to the Head of Quality and Compliance.

Humana does not accept actions that conflict with the Code of Conduct. They can result in disciplinary measures, which can also mean employment law consequences and a police report.

18. Follow-up and evaluation of the Code of Conduct

Humana's Group CEO is ultimately responsible for following up on the Code of Conduct and that the outcome is reported to the board at least annually. The Group CEO is responsible for ensuring that the Code of Conduct is reviewed at least annually and, if necessary, updated.

The board of Humana AB shall approve the Code of Conduct at least annually.

19. Other relevant governing documents and instructions

The areas of the Code of Conduct are covered in more detail in other policies and governing documents. In addition, each country within Humana is responsible for ensuring that there are relevant governing documents and routines regulating the operational work with the above areas within each country's organisation.

The Code of Conduct was approved by the Board of Directors of Humana AB on 16 May 2024.

Translated from Swedish. In case of any discrepancies between the Swedish text and the English translation, the Swedish text shall prevail.