Ethical Operating Principles
At Luotea, we are committed to doing the right thing and our goal is to ensure that no serious...
Principles and Policies
Luotea’s policies and principles encompass environmental, ethical, and social aspects that the Group adheres to both in its own operations and in the services it provides to customers.
Environmental Policy
This policy describes the goals, responsibilities, and organization of Luotea Oyj's (hereinafter Luotea) environmental policy.
Our environmental policy covers both our own operations and the services we provide for our customers. It describes our key environmental goals, responsibilities, and organization. We comply with the legislation applicable to our operations. Since 2024, we have reported on our activities in accordance with the CSRD sustainability reporting standard. In addition, our operations are certified and meet the requirements of the ISO 14001 standard.
KEY OBJECTIVES
Luotea's strategy is to create more value with the circular economy for our customers, personnel, and society in a broader sense. We create solutions to mitigate climate change, promote the circular economy, and preserve biodiversity. We are committed to promoting the goals of the Paris Climate Agreement and the EU Biodiversity Strategy.
We strive to minimize the environmental impact of our operations. Our long-term climate goal is to achieve net zero by 2045 and to implement a determined transition away from fossil fuels.
PRINCIPLES
Climate Change Mitigation
We are committed to achieving net-zero targets by 2045 and encourage our partners to set their own climate goals and reduce dependence on fossil raw materials.
We reduce greenhouse gas emissions from our own operations and value chain by increasing the use of renewable fuels in vehicles and machinery, improving the energy efficiency of properties, and developing our operations in line with our climate objectives. Purchased products and services account for Luotea’s most significant emissions.
We provide our customers with solutions for climate change mitigation and reporting.
Adaptation to Climate Change
The impacts of climate change on our market are already visible. In the Nordic countries, the most significant climate-related risks for building stock are the increasing frequency of heavy rainfall and flooding, as well as heatwaves and extreme dryness. These can be addressed through technical and nature-based solutions: improving climate control, cooling, and shading, as well as enhancing local stormwater infiltration and using green infrastructure to provide shading.
We offer solutions to our clients for stormwater management, climate control, and lifecycle resilience of properties. In this way, we ensure that our clients’ businesses can adapt to climate change.
Sustainable Use of Raw Materials
We promote the sustainable use of natural resources by preventing waste, managing the recovery of materials to be recycled and reused and by replacing fossil fuels with bio-based raw materials. We aim to actively promote the operating conditions for a circular economy.
Preserving Biodiversity
We safeguard biodiversity by using chemicals responsibly both indoors and outdoors on properties. We aim to increase circular economy solutions at client sites, protecting nutrient cycles and groundwater.
We create solutions to restore land areas, promote biodiversity in the built environment, and prevent biodiversity loss. We identify and remove invasive species, restore and expand green areas, and create nesting sites for wildlife.
Supply Chain
We require our suppliers to take proactive steps to promote environmental responsibility. We encourage them to monitor and improve their operations, particularly addressing negative environmental impacts, and to set targets for reducing emissions.
Since 2022, we have also calculated the carbon footprint of our supply chain, which is significant for Luotea.
Continuous Improvement
Luotea’s Board and management are committed to achieving our sustainability goals and continuously improving responsibility practices. We recognize the negative environmental impacts of our operations and work to develop and enhance our practices together with employees, clients, and the supply chain.
We engage in open dialogue with our stakeholders, including clients, authorities, and local actors. We monitor the environmental impacts of our operations and communicate them transparently.
RESPONSIBILITIES AND ORGANISATION
The environmental policy applies to all employees and all sectors of Luotea. It is approved by the CEO and the Group Management team of Luotea Plc.
The environmental policy is owned by Luotea's Senior Vice President, Corporate Relations and Sustainability. Responsibility for implementing the policy lies with all Luotea employees. Luotea’s divisions and units are responsible for the implementation of the policy and the necessary allocation of resources in their respective operations.
ENTRY INTO FORCE
This policy has been approved by Luotea's Group Management Team in December 2025 and comes into effect immediately. The policy is updated every two years. The next update will take place in 2027.
HR Policy
This policy describes the purpose, responsibilities and organization of the personnel policy of the Luotea Group (“Luotea”).
Luotea complies with national legislation, collective labor agreements, internationally recognized human rights and comply with the core principles of the International Labour Organisation (ILO). Our work community is based on equality, we do not use child labor, and we have zero tolerance for any form of discrimination.
Our personnel policy is based on Luotea’s strategy and the principles of sustainability, operations and management. Good personnel experience consists of the implementation of these principles.
The aim of the policy is to ensure that Luoteas’s staff, who are aware of the objectives and strategy, are competent and committed, form the basis for achieving a good and sustainable financial result.
Our personnel policy consists of the key principles of the Luotea Group in the areas of personnel management.
Our operating principles “Code of Conduct” defines how all Luotea employees act and work together. Our operating principles set expectations for the responsible and ethical behavior of Luotea employees and help Lutea employees make the right decisions in their daily work. Our operations are based on nine principles: We comply with the laws, rules and regulations, our actions are honest and transparent, we act in the interest of the company, we respect human rights, we respect each other and our common workplace, we work safely, we take care of our environmental obligations in an uncompromising manner, we require our suppliers to act responsibly, we intervene in cases of misconduct.
Management
The results of Luotea are generated through the employees.
At Luotea, we are committed to working together according to our leadership principles, which include caring and appreciation, co-operation and responsible renewal. The aim of the leadership principles is to create a better tomorrow at Luotea.
Remuneration
The aim of all remuneration at Luotea is to promote good performance and to motivate personnel to engage in long-term efforts to promote the achievement of the company’s goals. Remuneration is one factor through which the company strives to ensure the availability of skilled and motivated people for all positions at all levels of the organization. Remuneration solutions are based on strategy and business objectives and are supported by regular review of the base salary, L&T-level and business-specific performance bonuses as well as personnel benefits.
Competence
Competent personnel are a common key factor in Luotea’s competitive advantage and positive customer experiences. Our goal is to provide our customers with the best personnel to assist them.
The purpose of competence management is to ensure that Luotea has the necessary competencies at its disposal today and in the future. Competence management is based on Luotea’s strategy. The assessment of individual competencies is part of this process, as it supports the selection of effective competence development actions.
At Luotea, competence refers to an individual’s ability, knowledge and skill to act professionally in different situations in Luotea’s operating environments. At the Luotea level, competence refers to the organization’s ability to implement its strategy.
The need for competence development is assessed and planned in development discussions together with the supervisor. The main responsibility for developing competence lies with the employees themselves, supervisors support the development of the competence of their team members. We develop the competence of our supervisors to ensure responsible management and supervisory work.
Equality and non-discrimination
Promoting diversity is one of the key themes of Luotea’s sustainability program. Lutoea is committed to promoting equality and non-discrimination. Luotea companies draw up equality and non-discrimination plans in accordance with national legislation.
Our goal at Luotea is to foster an increasingly diverse work community that accepts and respects differences. At Luotea, we believe that our extensive diversity work strengthens the personnel experience of every Luotea employee. We pull together to develop our culture and operating methods so that everyone finds it easy to join our organization and enjoys being part of our work community.
Safety and well-being at work
We promote the safety, work ability and well-being of our personnel through proactive work and management of work ability. Our goal is to have zero accidents. We use effective proactive measures—such as risk assessments, safety observations, safety walks and safety talks—to improve our safety as well as the safety of our customers and other stakeholders, while also eliminating risk factors.
We increase our employees’ awareness of occupational safety and risks starting from induction training and through online training and clear guidelines as well as by providing regular information on instructions, procedures and operating models. Our systematic efforts on this front are aimed at making our employees realize that everyone can contribute to occupational safety. Luotea’s occupational safety activities are coordinated under an ISO 45001 certified management system as well as the Group’s occupational safety management principles.
We take care of our employees’ work ability throughout the life cycle of the employment relationship. At Luotea, work ability management is aimed at increasing employees’ well-being, identifying problems at an early stage and focusing on their prevention.
Recruitment
We are constantly developing and measuring our recruitment methods, applicants’ experience and supervisors’ recruitment skills.
In recruitment, we are committed to equality, non-discrimination and making choices based on the things that predict success at work. Our personnel selections emphasize suitability for the task, motivation, competence and training.
In addition, we support internal career paths. Our goal is to create versatile and long-term employment relationships during which our employees can grow and develop.
Responsibilities and organization
The personnel policy is approved by Luotea’s Group Management Team.
Luotea’s HR unit is responsible for the personnel policy.
The personnel policy covers the operations of Luotea’s companies in all operating countries. Luotea’s personnel must adhere to the policy. Luotea’s companies and units take care of the implementation of the policy and the necessary resources in their own operations.
Entry into force
Approved by Luotea’s Group Management Team in December 2025.
Human Rights Policy
This policy outlines the purpose, directives, responsibilities, and organization of the Luotea Group (hereafter Luotea) human rights policy. This human rights policy applies to the entire Luotea Group's workforce and value chain, including our suppliers and clients.
KEY TARGETS
Luotea's goal is to be a safe, fair, equal, and equitable workplace. We commit to respect all internationally recognized human rights as well as national legislation and to avoid causing negative human rights impacts by acting conscientiously within our operating environment.
Luotea may have both direct and indirect impacts on different groups' human rights. We have identified that Luotea's operations have particularly significant impacts on the realization of human rights for three groups: our own personnel, the supply chain, and clients. We commit to identify and assess human rights impacts and risks in these groups and to address any issues that arise.
PRINCIPLES
We comply with laws, international agreements, rights, and principles in all our operations.
Luotea respects the human rights defined in the United Nations Declaration of Human Rights and the rights of employees determined by the International Labour Organization (ILO), the OECD Guidelines, and the United Nations Guiding Principles on Business and Human Rights. We are committed to support the UN Global Compact initiative and its principles concerning human rights and labor rights. We also adhere to national laws, agreements, and other obligations.
We consider human rights in Luotea's guiding policies and principles and instruct our staff and supply chain to act accordingly. We expect our supply chain to comply with these same statutes, agreements, policies, and principles as per the requirements of Luotea's Supplier Code of Conduct. Luotea may conduct audits, through third parties or us, to verify compliance.
We do not tolerate human trafficking, forced labor, the use of child labor contrary to children's rights, or any form of modern slavery in our operations or supply chains. We do not expose young employees to work that is likely to harm their education, health, safety, or mental development.
Guiding requirements for our operations
Decent working conditions are right for everyone
Luotea complies with the laws and applicable collective agreements in its operations for example on working hours, minimum wages, and working conditions. Employees also have the right to sick leave, annual leave, and parental leave as stipulated by national laws and labor agreements. Luotea expects the same from its supply chain.
Luotea promotes a healthy work-life balance and flexible working practices whenever possible.
Ensuring Luotea is a safe place to work every day
Our target is to think and act safely to prevent all workplace accidents. Our goal is also to ensure that every Luotea employee and those in our supply chain have a safe and healthy work environment, allowing us to return home safely every day. We promote workplace safety by providing orientation training and proactive, consistent measures to ensure and improve safety.
Handling personal data lawfully and respecting privacy
At Luotea, we handle the personal data of our personnel, clients, and possibly other stakeholders in accordance with applicable legislation, respecting their right to privacy. We ensure that our activities respect the privacy of our staff and stakeholder representatives.
We do not discriminate, and each person has a right to be themselves
Luotea has a zero-tolerance policy for all forms of bullying, harassment, inappropriate behavior, and discrimination within our operations and supply chain. We do not discriminate based on gender, pregnancy, childbirth, gender identity, gender expression, age, origin, nationality, language, religion, belief, opinion, political activity, trade union activity, family relations, health status, disability, sexual orientation, or any other personal characteristic. Race, ethnicity, skin color, and national or social origin are also prohibited grounds for discrimination.
We set our own targets related to promoting an equal and equitable work community in our equality and equity plans and regularly monitor their progress.
We respect freedom of association throughout our chain
We respect our employees’ freedom of association and right to bargain collectively. We understand that freedom of association means the choice to organize or not to organize professionally. These are equally strong fundamental rights, and we respect one another's decisions regarding freedom of association.
Addressing misconduct and implementing necessary corrective actions
Any Luotea employee, member of the supply chain, client, or individual associated with our stakeholder groups can report any suspicions of misconduct or behavior contrary to ethical principles through a Whistleblowing channel.
All reports are treated with care, thoroughly investigated, and transparently reported in such a way that does not lead to negative consequences for the whistleblower. If we find direct human rights violations in our operations, we strive to prevent broader effects through corrective measures and, where possible, rectify any damage caused. By thoroughly assessing our practices and implementing subsequent corrective measures, we ensure that such incidents do not recur.
We also promptly investigate any human rights abuses in our procurement. We agree on corrective actions in collaboration with our partners, and their implementation is monitored, among other ways, through supplier audits. The preference is not to terminate cooperation but to work together to improve operations. Boycotting is not a primary solution as it can worsen the situation for the most vulnerable employees. We terminate collaborations if corrective actions are not undertaken.
Collaborating with stakeholders on human rights work and listening to them
We and our stakeholders, including our personnel, suppliers, clients, investors, unions, and human rights activists, share common goals for a better future and the advancement of human rights.
We engage in open, constructive discussions on promoting human rights with our stakeholders.
We listen to and meet with our stakeholders to learn and work on human rights together. We respect the views of our stakeholders on human rights promotion and consider them when developing our operations.
Identifying and assessing our human rights risks and reporting transparently on our human rights work
We have identified potential and actual human rights risks and impacts in our staff, supply chain, and clients, considering particularly vulnerable groups through human rights risk assessments. Our assessment considers the severity and probability of human rights risks.
We conduct regular human rights risk assessments and report on our human rights impacts and risks both internally and publicly as part of our sustainability reporting.
We implement the principles stated in this human rights policy to our staff and value chain through communication and training.
RESPONSIBILITIES AND ORGANIZATION
The human rights policy is approved by Luotea's Board of Directors. Luotea's management team is committed to respecting and promoting human rights.
Responsibility for human rights policy lies with the HR Director of the Luotea Group. The policy covers all Luotea Group companies and sectors in all countries of operation and applies to all staff. We require our subcontractors and other external labor suppliers to comply with the principles outlined in this Luotea human rights policy.
Luotea's sectors and units are responsible for the implementation of the policy and for allocating the necessary resources within their operations.
EFFECTIVE DATE
This policy was approved by the Luotea’s Group Management Team in December 2025 and is effective immediately.
The policy is reviewed every two years. The next update is due in 2027.
Key principles and guidelines related to the policy:
- Luotea's Code of Conduct
- Luotea Supplier Code of Conduct
- Luotea’s Personnel Policy
- Luotea's Occupational Safety Policy
- Luotea's Data Protection Policy
- Luotea's Quality Policy
- Company-specific diversity plans of Luotea companies
- Luotea's guidelines for preventing suspected harassment, inappropriate behavior, discrimination, and bullying at work
- Luotea's Whistleblowing channel guidelines
- Luotea's occupational safety action program
Anti-corruption and anti-bribery Policy
This policy describes the Luotea Group's (hereinafter referred to as "Luotea") ground rules for the prevention of corruption and bribery. The policy applies to all Luotea Group personnel and other parties involved in the conduct of Luotea’s business (e.g. consultants).
KEY OBJECTIVES
Luotea’s business is conducted ethically, honestly and openly. This creates the foundation for successful business and builds trust between employees, customers, partners and public officials.
We comply with the applicable legislation in all our operations. Luotea is committed to anti-corruption and anti-bribery operating principles in accordance with the UN Convention.
Luotea prohibits all forms of bribery and corruption. We operate responsibly and always compete fairly. We do not offer, give, accept or request anything of value from any third party for corrupt purposes with the intention of obtaining or giving an inappropriate business or personal benefit. These matters must be kept in mind particularly in sales operations, business management and procurement, although the policy applies to everyone who works at Luotea.
Luotea’s incentive schemes are designed in such a way that they do not give employees incentives to act illegally or unethically. We never compromise on legal compliance and our ethical operating practices to achieve our business objectives.
The aim of this policy is to support the prevention and detection of prohibited corruption and bribery. With this policy, we increase awareness of what forms of hospitality we consider acceptable and what types of conduct we do not allow at Luotea.
We strive to ensure that any partners acting in the name of Luotea or on behalf of Luotea, such as consultants and the participants of our value chain, also commit to compliance with this policy to prevent corruption and bribery in their respective operations. More detailed guidelines concerning suppliers are documented in Luotea’s Supplier Code of Conduct.
KEY CONCEPTS
Bribe
A payment, gift, favor or other benefit that is offered, received or requested in exchange for an improper advantage. Receiving or giving bribes is prohibited because the underlying motivation is the pursuit of an improper advantage. Bribes are often misrepresented as, for example, sales and marketing expenses, travel or entertainment expenses, service fees, depreciation, consultancy fees, commissions, discounts or miscellaneous expenses so that they can be concealed in accounting. Such conduct is illegal.
Gift
A gift is any tangible or intangible benefit that has direct or indirect financial value for the recipient. A gift is always one-off and does not recur regularly during the year. Luotea has established maximum amounts for acceptable gifts that Luotea employees can give to, and receive from, suppliers on a one-off basis and at the annual level. The applicable maximum amounts are specified in the guidelines concerning gifts and hospitality in procurement. No gifts may be received in competitive bidding situations or during other cooperation or contract negotiations. Receiving an acceptable one-off gift of low value from a supplier does not constitute bribery.
Conflict of interest
A situation where an employee’s personal interests conflict with their work duties or Luotea’s interests. The same applies to dual roles where the same person is a decision-maker and beneficiary in different organizations between which there is monitoring or procurement.
Entertainment or hospitality
Training or networking events, meals, beverages, entertainment events or, for example, free travel that are offered or received free of charge. Permitted entertainment is low in monetary value and provided without obligations or expectations. Such entertainment or hospitality does not constitute bribery. Luotea has established maximum amounts for acceptable entertainment and hospitality that Luotea employees can receive from suppliers on a one-off basis and at the annual level. The applicable maximum amounts are specified in the guidelines concerning gifts and hospitality in procurement.
Corruption
Abuse of power with the purpose of obtaining an improper advantage for oneself or another person or company. Corrupt conduct is often deliberately misleading, not transparent. Such conduct is illegal and therefore prohibited at Luotea. Bribery, for example, is one form of corruption.
Kickback
A form of negotiated bribery in which the recipient of a bribe is paid a commission for services or favors rendered. Such conduct is prohibited at Luotea and, in many cases, illegal.
Sponsorship
An investment of mutual benefit in an event, person or concept to promote Luotea's brand, business and services. Sponsorship does not constitute bribery.
Public official
In this policy, "public officials" refer to people working in central and local government as well as officials of public institutions.
PRINCIPLES
We act in the interests of Luotea
Luotea employees must avoid business transactions and situations with customers, partners and public officials that cause, or may cause, a conflict between Luotea's interests and the employee’s personal interests. When carrying out work duties, employees must always act in the interests of Luotea. Personal interests or views must not influence business transactions carried out on behalf of Luotea.
If a situation involves a possible or actual conflict of interest, the person in question must notify Luotea of the matter, for example through their supervisor. A prohibited conflict of interest may exist if a Luotea employee concludes an agreement on behalf of Luotea with a company owned by a family member, for example.
Bribery is prohibited
Offering, requesting and accepting bribes is strictly prohibited at Luotea.
Accepting a bribe in business activities and bribing a public official or Member of Parliament are criminal offences under the Criminal Code, for which the punishment may be imprisonment or a fine. Both giving and receiving a bribe are punishable offences under the Criminal Code. Crimes of bribery also involve a serious risk of damage to Luotea’s reputation.
Hospitality extended to customers and partners must be reasonable and in accordance with good practice
Acceptable hospitality does not constitute prohibited corruption or bribery. Acceptable hospitality can be extended to customers or partners occasionally to deepen or promote business and cooperation, for example. Suitable gifts to customers and partners include, for example, reasonably priced and ordinary business gifts bearing the Luotea logo.
Acceptable hospitality can be given openly in the presence of others and is given without obligations or expectations. Acceptable hospitality is in line with good practice, reasonable and holds up to public scrutiny. Conclusion of acceptable hospitality could be to offer a Luotea customer an ordinary and reasonably priced workplace lunch at the conclusion of a sales discussion. If a person refuses an acceptable gift or hospitality given by Luotea, that decision must be respected.
No gifts or hospitality may be given in competitive bidding situations or during other cooperation or contract negotiations.
Prohibited conduct with customers and partners
We do not give customers or business partners hospitality, favors or gifts in the form of money or in the form of benefits that are comparable to money. Examples of prohibited hospitality in the form of money could be a gift card or Luotea making a monetary donation to a charity to which the customer is connected, at the customer’s request, as a condition for the conclusion of a sales agreement.
If gifts or entertainment given by an Luotea employee to a customer or business partner are excessive or inappropriate in nature or timing, given secretly and not openly, or intended to influence business decisions or to obtain something in return for Luotea, they are, as a rule, considered to be prohibited bribes.
An example of conduct prohibited by law would be Luotea agreeing not to participate in a competitive bidding process in exchange for monetary compensation given by a competitor. From Luotea’s perspective, this would constitute acceptance of a prohibited bribe. Moreover, dividing the market with a competitor in the manner described above is prohibited under competition law. We comply with competition law in our operations and always compete fairly.
Hospitality must not be extended to family members or related parties. It is also prohibited to hire a family member of a customer or partner at Luotea if the underlying motivation of the recruitment decision is the pursuit of improper advantage.
Public officials and political activities
As a rule, we do not give any gifts or hospitality from Luotea to public officials, as such actions could be interpreted by outsiders as attempts to influence the actions of the public official, even if that is not the case.
In connection with customer service or cooperation meetings, a public official can be offered ordinary and reasonably priced coffee and snacks. However, it is important to avoid creating the impression or perception that the purpose of hospitality is to influence the public official or their decision-making. If a person refuses an acceptable gift or hospitality given by Luotea, that decision must be respected. Hospitality offered to the representatives of a public authority must never be replaced by money.
At Luotea, we do not make political donations to parties or candidates. We also do not support political parties or candidates by purchasing goods or services from them for consideration. Luotea employees may, with the permission of a member of the Group Executive Board, participate in seminars organized by political parties, provided that such participation is professionally justified and the seminar program consists directly of subject matter that is relevant to Luotea’s business operations, and the seminar is of ordinary cost or free of charge.
Reporting prohibited conduct
If an employee observes or suspects prohibited conduct at Luotea, such as corruption, bribery or conflicts of interest, they must report them to their supervisor, the HR function or the legal department. The report can also be submitted through Luotea’s whistleblowing channel. Reports via the whistleblowing channel can also be submitted anonymously. A link and instructions for the whistleblowing channel are provided on company intra and the company website.
Employees are encouraged to speak up if they suspect a violation of the Code of Conduct or the Supplier Code of Conduct, or if they become aware of misconduct, particularly in cases where they are offered a bribe or asked to give a bribe, or if they suspect that a particular event involves bribery.
Luotea investigates all suspected incidents of misconduct. Any person reporting, in good faith, their suspicions within the scope of whistleblower legislation and participating in the investigation of any suspected misconduct will not suffer any negative consequences as a result, such as being subsequently discriminated against or being at risk of being put in a disadvantageous position. Luotea takes disciplinary action against anyone who is found to have taken any prohibited retaliatory measures.
RESPONSIBILITIES AND ORGANISATION
Luotea’s anti-corruption and anti-bribery policy is approved by the Group Executive Board. The responsibility for Luotea’s anti-corruption and anti-bribery policy lies with Luotea Group’s Senior Vice President, Legal Affairs. The policy covers all Luotea Group companies and divisions and applies to all personnel in all the Group's operating countries.
ENTRY INTO FORCE
This policy has been approved by Luotea's Group Management Team in December 2025 and it enters into force immediately.
The policy will be updated every two years at a minimum. The next update will take place in 2027.
Key principles and guidelines related to the policy:
- Luotea’s Code Of Conduct
- Luotea Supplier Code of Conduct
- Instructions for Luotea's whistleblowing channel
- Luotea’s guidelines on gifts and hospitality in procurement.
Communications Policy
Luotea’s communications support the company in its efforts to implement its business strategy, achieve its objectives and build its reputation among key stakeholder groups. This policy defines the communications principles, channels and responsibilities.
Principles of communications
Our communications are geared towards openness and bilateral interaction. We engage in continuous dialogue with our stakeholder groups and develop our operations based on this interaction.
In our investor communications, we comply with Finnish legislation and the regulations and guidelines of NASDAQ OMX Helsinki and the Financial Supervisory Authority. Our disclosure policy specifies the operating principles and methods we use in our communications with the capital markets.
Luotea’s crisis communications seek to minimize the negative impacts of unexpected, sudden situations on the company. In crisis communications, we follow our crisis communications process.
In Finland, Luotea’s corporate communications department co-ordinates all media contacts and agrees on guidelines for comments with the selected spokespeople. In our other business countries, contacts from the media are forwarded to the communications responsible or the Country Manager.
Company-wide position statements and major news announcements are made public by the President & CEO or his designated spokesperson. Only the President & CEO, CFO and Head of Investor Relations may make public statements concerning the company’s financial position.
Unit managers and experts can make statements concerning their own area of responsibility. They must agree on guidelines for their comments with Luotea’s corporate communications department.
The company does not comment on confidential or incomplete business transactions or on its competitors.
We have specified permit procedures for sponsored advertising and sponsorships with a view to ensuring consistent visibility in line with our brand at selected sites.
Communications responsibilities
Luotea’s corporate communications department is responsible for company-level guidelines, development and channels. It provides expert assistance and communications training. In addition, we also make outlays on developing our supervisors’ communications capabilities and opportunities.
Luotea's corporate communications department coordinates the communication of Group-wide topics and develops internal communications channels. Responsibility for communicating division specific topics lies with the Marketing Managers of each division.
The CFO and the company’s IR staff are responsible for investor communications. The division’s Marketing Managers hold the main responsibility for customer communications. When organizing customer events, we follow a separate permit procedure, which aims to ensure the appropriateness and fairness of events.
Major channels
In Finland, the primary channels for internal communications are the intranet,
e-newsletters and internal info meetings.
The most important channel for external communications is our Internet site. We publish all communications materials for external stakeholders on the site without delay.
We have drafted separate guidelines for the use of Luotea's social media channels.
Occupational Safety Policy
This Policy describes the objectives, responsibilities and organization of the Occupational Safety Policy of Luotea Plc (hereinafter referred to as "Luotea").
Our Occupational Safety Policy covers both our own operations and our supplier network. It describes our key occupational safety objectives, responsibilities and organization. We comply with the legislation applicable to our operations as well as orders and regulations issued by the authorities. Our operations are also certified and meet the requirements of the ISO 45001 standard. Occupational safety objectives are included in the objectives of the L&T sustainability program.
KEY OBJECTIVES
The goal of our occupational safety operations is to guarantee a safe workplace for all personnel. We are committed to the idea of zero accidents, and we believe that all accidents and damage can be prevented. In the event of any action or conduct in violation of the applicable legislation, orders issued by the authorities or instructions, we take immediate action in accordance with mutually agreed upon rules.
PRINCIPLES
Preventing accidents through proactive occupational safety work
We survey the hazards and risks of our services and various tasks in advance to eliminate or minimize the risks. We encourage our personnel to actively engage in proactive safety efforts, such as making safety observations, conducting Safety Walks and participating in occupational safety sessions. We investigate all accidents and take corrective action, including occupational accidents involving our subcontractors and leased employees in Luotea’s tasks.
Common ground rules, common goals
To secure our operations, we have sufficient resources as well as harmonized processes, tools and instructions. Our management has a strong commitment to the continuous development of occupational safety by providing the necessary resources, maintaining an awareness of their organization’s level of occupational safety and actively setting an example. We monitor and report on occupational safety progress in a transparent and public way to all stakeholders.
Occupational safety as an integral part of daily management
The responsibility for occupational safety lies with the line organization. Occupational safety is an integral aspect of day-to-day management at all levels of line organization. However, it is the right and duty of each Luotea employee to monitor and make observations to improve the safety of the working environment. We guarantee our personnel sufficient induction, occupational safety training and personal protective equipment for safe work. When we work in the customers’ premises, we take into account the customer’s safety targets and instructions as well as the safety of shared workplaces in our operations.
Supply chain involved in health and safety work
We expect our suppliers to commit to Luotea’s safety practices and take the initiative to promote occupational safety. It is possible for both subcontractors and leased employees to report their safety observations to the Luotea safety system.
Continuous development of occupational safety
Luotea’s Board of Directors and management are committed to the achievement of our sustainability targets and the continuous development of sustainability. We are continuously developing and improving occupational safety together with all the personnel groups and on all levels of the organization. Our occupational safety activities are transparent: information and materials are open to all personnel, and they encourage people to learn from each other. We also require Luotea’s contractual partners to make a commitment to the continuous development of occupational safety.
RESPONSIBILITIES AND ORGANISATION
The Occupational Safety Policy applies to all personnel and all Luotea's divisions. It is approved by Luotea Plc’s President and CEO and the Group Executive Board.
The Occupational Safety Policy is owned by the Property and Risk Management Director at Luotea. The responsibility for implementing the Policy lies with all Luotea employees. Luotea's divisions and units are responsible for the implementation of the Policy and the allocation of the necessary resources in their respective operations.
ENTRY INTO FORCE
This Policy has been approved by Luotea's Group Management Team in December 2025 and it enters into force immediately.
The Policy is updated every two years. The next update will take place in 2027.
Quality Policy
This Policy describes the objectives, responsibilities and organization of the Quality Policy of Luotea plc (hereinafter referred to as "Luotea").
Luotea’s mission is to make the circular economy a reality in a sustainable and high-quality way. Our Quality Policy covers both our own operations and the services we provide for our customers. It describes our key quality objectives, responsibilities and organization.
We comply with the legislation applicable to our operations as well as orders and regulations issued by the authorities. Our operations are also certified and meet the requirements of the ISO 9001 standard. Quality objectives are included in the objectives of the Luotea sustainability program.
KEY OBJECTIVES
Luotea's strategy is to support our customers’ sustainability, create excellent customer experience and develop the best services in our industry. We carry out good administration in our own operations. We act appropriately and transparently throughout the value chain.
Our quality premises have been developed together with customers and Luotea personnel:
- We keep our word.
- We make your life easier.
- We help you succeed.
We live up to our promises both in our work with customers and in our own operations. Our goal is for the Net Promoter Score, NPS of our services, to be above 50 by 2026.
PRINCIPLES
Customer experience and employee satisfaction as indicators of the quality of operations
We measure customer satisfaction with the Net Promoter Score (NPS) of the services as part of Luotea’s strategic objectives. The NPS results are also available to all our personnel in a transparent way. Our success as a quality Employer is reflected in the Employee Net Promoter Score eNPS. The target setting for both indicators is included in the Luotea sustainability and stakeholder targets.
Service quality indicators and targets are defined together with the customer
Luotea offers a very wide range of services. The divisions and business lines have quality indicators in place to monitor and develop the service quality of the business in question in cooperation with our customers. Quality is monitored regularly with our customers in accordance with our cooperation models.
Quality is part of the work of all Luotea employees
We recognize that good quality and customer experience starts with us all. Every Luotea employee has the right and duty to highlight the overall aspects of quality development. We strive to support the continuous development of our personnel by providing them with the necessary training in addition to adequate induction.
While we do everything we can to avoid mistakes, we recognize that they can sometimes happen. We are committed to taking responsibility for our errors and correcting them appropriately. Luotea uses an electronic complaint processing system that is shared by the entire Group. We record all complaints in the system and handle them according to uniform instructions.
Audits ensure continuous development and improvement
We conduct both external and internal audits of our management systems on an annual basis in accordance with our audit plan. We record all findings and suggestions for improvement from these audits in the Luotea system, which also records their handling and corrective actions with the schedules and person in charge.
We want to be transparent in our own operations and therefore, as part of our customers’ supply chain, we also participate annually in customer audits and various voluntary third-party assessments.
Supply chain
When selecting a supplier, we put emphasis on the quality and reliability of the supplier’s operations, as well as ethical operating principles in addition to cost efficiency. When assessing suppliers, we use e.g. self-assessment. For the most significant suppliers, we monitor operations using separately set indicators. We also conduct risk-based supplier audits.
Continuous development of operations
Luotea’s Board of Directors and management are committed to continuous improvement of operations and the quality management system and create the conditions for achieving quality objectives. We continuously develop and improve the quality of our operations together with our personnel and customers.
RESPONSIBILITIES AND ORGANISATION
The Quality Policy applies to all personnel and all Luotea's divisions. It is approved by Luotea plc’s President and CEO and the Group Executive Board.
The Quality Policy is owned by the Property and Risk Management Director at Luotea. The responsibility for implementing the Policy lies with all Luotea employees. Luotea's divisions and units are responsible for the implementation of the Policy and the allocation of the necessary resources in their respective operations.
ENTRY INTO FORCE
This Policy has been approved by Luotea's Group Management Team in December 2025 and it enters into force immediately.
The Quality Policy is updated every two years. The next update will take place in 2027.
Procurement Principles
Luotea’s procurement focuses on subcontracting external labor and services, as well as acquiring equipment, fuels, technical trade products, and various materials. Our procurement is based on sustainability, safety, reliability, and cost-efficiency. We consider the entire life cycle of products and services, as well as the environmental and societal impacts of our operations. We act responsibly and expect the same from all our suppliers and partners.
Compliance with legislation
We comply with all applicable national legislation, regulatory requirements, and both national and international agreements in our operations, and we expect the same from our suppliers. We monitor compliance with collective agreements, environmental, labor, and occupational safety laws, as well as financial regulations, and adhere to local contractor liability laws when using labor.
Our cooperation must not involve bribery or hospitality or gifts that could influence decision-making in business relationships.
Quality requirements
Our suppliers must meet the performance and operational standards we set for each product group. Where necessary, we verify compliance with technical and functional requirements through tests and trials, and, if needed, supplier audits.
To ensure high-quality products and services, we review information related to competitiveness and financial management when selecting a significant new supplier. We also conduct a written survey and check creditworthiness. If we identify issues during supplier selection that require further clarification, we send a more detailed inquiry to the supplier.
We monitor supplier quality and performance in a manner appropriate for each product group. We expect suppliers to maintain good and reliable practices and strong delivery reliability. We ensure delivery reliability and quality, as well as the adequacy of corrective measures, through regular monitoring and product-group-specific metrics.
Environmental requirements
We require our contractual partners and suppliers of goods and services to comply with applicable environmental laws, regulatory requirements, and permits, and to operate in an environmentally responsible manner.
We encourage suppliers to use environmental management systems and reduce negative environmental impacts from their operations. Additionally, we recommend setting greenhouse gas emission reduction targets for their activities.
Social requirements
We require suppliers to comply with local industry collective agreements, national labor laws, and ILO conventions, according to the provisions that best safeguard workers’ rights.
Luotea also expects suppliers to adhere to the principles of the UN Global Compact initiative in their operations. Suppliers must commit to respecting internationally recognized human rights in all activities, promoting their realization, and ensuring healthy and safe working conditions for employees. If we identify risks during supplier pre-selection, operations, or in their operating environment that require further clarification, we request an explanation or verify the matter through a review or audit.
Selection and monitoring of suppliers
We review our procurement principles with significant suppliers before starting cooperation. Our purchasing terms and agreements specify product-group-specific requirements for suppliers.
In supplier selection and monitoring, we use the following methods:
- Supplier questionnaire and self-assessment to determine the level of environmental, quality, and occupational safety management
- Review or supplier audit
- Information related to suppliers’ competitiveness and financial management
We choose appropriate methods for each case. These methods help ensure that our suppliers support the quality, responsibility, and continuous development of property services.
Violations
If we find that a supplier acts contrary to these principles, we request a corrective action plan and its implementation within a defined timeframe. If the supplier fails to make the required improvements, we terminate the cooperation. Luotea does not tolerate any misconduct and expects to be informed of all suspicions immediately through its reporting channel.
Approval of the principles
The procurement principles are owned by Luotea’s Supply Chain Director, and their content is approved by Luotea's Group Management Team.
These principles apply to the entire Luotea Group.
Guidelines on gifts and hospitality in procurement activities
Luotea plc’s (Luotea) general principles concerning bribery and corruption are documented in Luotea’s Code of Conduct. The principles apply to all Luotea employees. This policy on gifts and hospitality in procurement activities provides more detail on the practices and procedures outlined in the Code of Conduct as regards supplier cooperation.
This policy on gifts and hospitality in procurement activities applies to all Luotea employees who engage in purchasing or procurement activities in their work. The scope of the policy includes Luotea's Group management team and the management teams of the divisions.
Definitions
Gift
A gift is any tangible or intangible benefit that has direct or indirect financial value for the recipient. A gift is always one-off and does not recur regularly during the year.
Hospitality
Hospitality mainly refers to training or networking events, meals, beverages and other hospitality that is offered or received free of charge.
Examples of hospitality include supplier lunches and dinners, food and beverages served in connection with training and customer events, and free-of-charge travel and entertainment events, such as sporting and cultural events.
Procurement partner
Procurement partner refers to all Luotea's suppliers and other stakeholders in procurement.
Receiving or giving of gifts, hospitality or travel
General principles
Luotea employee may receive a gift valued at less than €50 or hospitality valued at less than €150 on a one-off basis from a supplier. The total annual value of gifts received from one supplier may not exceed €100. Corresponding limits are applied to the giving of supplier gifts regarding procurement and purchases.
No gifts or hospitality may be given or received in competitive bidding situations or during cooperation negotiations or contract negotiations.
Acceptable gifts and hospitality
- Can be received or given openly in the presence of others
- Are given without obligations or expectations
- Are in line with good business practices, reasonable and stand up to public scrutiny
- Are not in the form of money or a comparable benefit
- Are not intended for family members or related parties
- Are occasional and non-recurring
Supplier events, entertainment events and travel
Attending various events is allowed as long as the event supports Luotea's operations or strengthens supplier relationships. Hospitality must be acceptable and justified, and it may not lead to suspicions about the appropriateness of Luotea's activities.
Attendance at all events offered by partners, such as suppliers or subcontractors, is subject to the permission of the Chief Purchasing Officer or the Senior Vice President in charge of the division in question if attending the event involves travel or an overnight stay. In such cases, Luotea will pay for the participants’ travel and accommodation. The party that issues the invitation to the event must also participate in the event.
Events organized for partners, such as Supplier Days, must be carefully planned, support Luotea's operations and include business-related content. Multiple partners must be invited to attend such events at the same time.
In addition to compliance with this policy, all activities must adhere to Luotea's anti-bribery policy.
Approval process for gifts, hospitality and travel
If the value of a gift exceeds €50 or the value of hospitality exceeds €150, it requires the separate written approval of the division management or the Group's Chief Purchasing Officer. The highest approval level in the Group Management Team is the President and CEO.
Training on gifts, hospitality and travel
Luotea has identified a critical group that particularly engages in procurement activities at Luotea. The Luotea employees in the critical group are required to regularly complete the online course on the Code of Conduct and the online course on bribery and corruption. The coverage of training is monitored by Luotea's procurement management team and reported as part of Luotea's annual report.
Process for addressing suspected violations
Suspected violations can be reported via Luotea's whistleblowing channel. Whistleblower reports are handled in accordance with Luotea’s standardized procedure. Violations may have consequences for the Luotea employee in question, depending on the severity of the violation.
Responsibilities
The policy on gifts and hospitality in procurement activities applies to all employees and all Luotea's divisions. It was approved by Luotea plc's President and CEO and the Group Management Team in December 2025.
The responsibility for updating the policy and developing the monitoring of compliance with the policy lies with Luotea's Senior Vice President, Corporate Relations and Responsibility. The responsibility for putting the policy into action lies with all Luotea employees. Luotea's divisions and units are responsible for the implementation of the policy and the allocation of the necessary resources in their respective operations.
This policy applies to the following Luotea group companies:
- Luotea plc
- Luotea Kiinteistöhuolto Oy
- Luotea Kiinteistötekniikka Oy
- Luotea Siivous Oy
- Luotea FM Ab
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Luotea Services Ab
Data Protection Policy
Data Protection as a part of Luotea’s business
The data protection policy defines Luotea’s internally approved principles of data protection regarding the processing of personal data of customers, co-operation partners and other partners, employees and job applicants. With the data protection policy and the operation-specific data protection guidelines derived from the policy, we strive to ensure the lawful processing of personal data and the appropriate level of data protection. Taking care of data protection is a part of Luotea’s compliance activities and principles of responsible operations.
Contact the legal department if you have any questions concerning data protection.
Processing of personal data
Key definitions
Personal data refers to all kinds of information describing a person or his/her personal aspects that may be identified to concern him/her. Personal data is e.g. a person’s name, social security number, date of birth, address, telephone number, e-mail address, location data, picture, video, IP-address and cookie data, if the data can be connected to a person. Personal data is not considered to refer to information that cannot be used to identify a person. Such information may be, for example, various statistics.
Sensitive data refers to data describing a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, sexual orientation, health, illness or disability or a criminal act, punishment or other consequences due to crime.
Data subject refers to a person whose data has been saved in the personal data register and whose data is being processed.
Processing of personal data refers to any operations which are performed on personal data, whether or not by automated means. Processing of personal data is the collection, recording, organizing, structuring, storage, alteration, retrieval, use, transmission, disclosure, erasure or destruction of personal data.
Personal data register refers to any set of personal data collected for a specific purpose that is processed by automated means or is organized in paper format in such a way that the personal data is easily accessible without unreasonable costs. Separate notes do not usually form a personal data register, nor are a part of one. All data processed for the same purpose (e.g. customer relationship management) belong to the same register regardless of where and in which form they are stored.
Controller refers to a company or an organization that decides the methods and purposes of the processing and for whose use the personal data register is established. The controller is primarily responsible for that the personal data is processed according to the requirements of data protection legislation. For example, Luotea is the controller for the personal data of its employees, job applicants and the consumer customers, as well as the executives and contact person of its business customers and cooperation partners.
Processor refers to a party that participates in the processing of personal data on an agency, subcontractor or cooperative relationship basis, and that processes personal data on behalf of and for the controller. For example, marketing service providers, IT and cloud service providers or personnel service providers are processors, when they process personal data on behalf of Luotea.
Principles for processing personal data
Luotea’s data protection policy and guidelines as well as the data protection legislation are complied with when processing personal data. We at L&T comply with the following principles in all our processing of personal data:
Planning the processing of personal data
The processing of personal data is planned in advance and Luotea’s data protection policy and guidelines as well as the data protection legislation are complied with when planning the collection of personal data. For example, when developing and planning software and services that include or rely on the processing of personal data, or when planning new means of processing, the party responsible for the project or change shall, in a documented way, make sure that the privacy of the data subject is appropriately protected, taking into account the personal data collected and the need for protection.
The legal department assists, if needed, with the appropriate documentation of the project and with the planning of the lifespan of personal data.
Lawfulness, fairness and transparency
We will ensure that the processing of personal data is lawful, fair and transparent for the data subject. We will inform the data subjects i.a. of what personal data is collected from them, for what purpose, where the data is collected from and to whom the data is disclosed. A privacy notice will be drafted for each personal data register, and we will make sure that the data subject is informed of the processing of personal data in a timely manner. The information concerning Luotea’s existing personal data registers and their privacy notices are found at Silta.
Personal data is never collected or processed without an appropriate legal basis. Legal bases for processing are i.a. the consent given by the data subject, Luotea’s legal obligations, the legitimate interests of Luotea or the performance of a contract to which the data subject is a party.
Respecting the rights of the data subject
We will ensure that we inform data subjects appropriately and in a timely manner of the processing of their personal data and the data subjects’ rights concerning the processing of personal data. The rights of the data subject include i.a. the right to inspect the data, the right to demand the rectification and/or deletion of data, the right to data portability and the right to restrict the processing of personal data.
The data subject has a right to inspect what data of him/her has been collected and stored in the personal data register of Luotea. The data subject may also demand the rectification of incorrect data or the deletion of personal data regarding him/her.
In our operations, we will ensure that the rights of the data subjects will be taken care of and that the requests are responded to without delay.
Purpose limitation
We collect personal data only for specific purposes defined in advance and we do not use the data for other purposes. The intended purposes are defined when planning the collection of personal data and they are described in the privacy notices.
Minimizing data
We collect and process only adequate and relevant personal data that is necessary for the purposes described. The collected data must be limited to what is necessary for the purposes for which they are processed. Especially the collection and processing of sensitive information is kept as restricted as possible.
Up-to-dateness of data and correcting errors
We will not process erroneous or outdated personal data. We strive to ensure that the personal data which, in relation to its purposes is erroneous or inaccurate, is updated or erased without delay. We try to verify the correctness and up-to-dateness of the data by checking the data with the data subject him/herself or other reliable sources (such as the Population Register Centre).
Retention periods and deletion of data
We store the personal data only for as long as it is necessary considering the purpose of the data processing. Before we start processing the data we determine retention periods for the collected data or criteria according to which the retention period is determined. When the data no longer is necessary for the purpose, we delete or archive personal data. The retention periods for the personal data being processed by L&T are documented in privacy notices.
Data security and confidentiality
We strive to ensure the appropriate data security of personal data by for example, protecting the data from unauthorized and unlawful processing and destruction of data by using the appropriate technical and organizational measures. Technical and organizational measures shall mean various security measures which are used to ensure the security of personal data in electric and paper form. Such measures may be for example personnel training and guidelines, non-disclosure commitments, access control, supervision of use, information system data security and technical restrictions, auditing, inspection and supervision systems, data encryption, anonymization and pseudonymizing of data.
We restrict access to personal data in electric or paper form only to those persons who need to process the personal data due to their duties.
The main responsibilities and duties as well as the minimum requirements for data security are described in Luotea’s data security policy and guidelines related thereto.
Liability of the controller and accountability
We assess regularly the processes concerning personal data processing and the related risks, with special attention to the implementation of the rights of the data subjects, and we make sure that the measures taken are sufficient to ensure data protection. We make sure that the data protection documentation is appropriate and up to date, so that we, for example, in case of a supervisory authority inspection, are able to prove that we comply with data protection obligations in our operations.
Processing data on behalf of Luotea and data processing agreements
When transferring personal data to third parties, we always clarify in advance the grounds for the transferal. If the third party (for example a service provider, cooperation partner, subcontractor or IT provider) processes personal data on Luotea’s behalf, the transfer in question is an outsourcing of personal data processing. For example, purchasing data processing services or cloud services from a service provider is considered as an outsourcing of data processing. In this case, we will make a written agreement concerning the services and processing of personal data, in which we agree on how the service provider (the processor) processes personal data on behalf of and for Luotea (the controller). In outsourcing data processing the primary responsibility concerning the processing operations remains with Luotea and therefore we will ensure that the agreement will contain provisions concerning the extent of the assignment and the requirements concerning data protection and data security. The service provider, as a contractor, shall not have the right to process the data for purposes of its own or connect the data with its own data registers. The service provider is given the right to process the data only to the extent required by the assignment and following the guidelines of Luotea (the controller). The service provider is responsible for the processing of data pursuant to the service agreement between the contracting parties.
The processor’s data processing activities shall be agreed on in writing. Therefore, Luotea has drafted an annex concerning the data processing, which may be attached to the service (or similar) agreement between Luotea and the service provider. The content and scope of the data processing agreement depend on the type of data processed, the scope of the processing activities and the risk assessment. If necessary, please contact the legal department.
Data transfer outside the EU/EEA
It is allowed to transfer the personal data from one country to another within the EU and the EEA. Even then we will ensure that the general principles of data processing are adhered to.
It might be necessary to transfer personal data outside of the EU or the EEA for example when transferring personal data within Luotea from one group company to another or to an external service provider. Examples of data transfers are when a server, where personal data is stored, is situated outside of the EU or the EEA or when a service provider or Luotea group company is outside of the EU or the EEA and has technical access to a server in the EU area that stores personal data (e.g. due to maintenance or repairs).
Personal data may not be transferred outside of the EU or the EEA without the prior consent of the legal department. When transferring personal data outside of the EU or the EEA we, in addition to the general principles regarding data processing, also ensure that an adequate level of data protection is guaranteed in the target country. Depending on the target country for the transfer, an adequate level of protection may be guaranteed by entering into an agreement with the transferee by using the standard contractual clauses adopted by the EU Commission.
Data security and personal data breaches
We strive to protect the data from data breaches, i.e. accidental or unlawful destruction, deletion, alteration, unauthorized disclosure or access to the data. Luotea has defined a process that will be adhered to concerning data breaches. Everyone is obligated to notify us of any noted data breaches in Luotea’s operations without delay in accordance with a separate guideline concerning data breaches.
We will regularly assess the risks related to data processing in our operations and act to minimize perceived risks, considering the newest technology and costs of implementation related to the risks of data processing and the nature of the personal data being protected. In this way we can ensure the adequate level of security.
We will take care of the protection of the data during its lifespan in all phases of the processing, starting from the collection of data and ending with its destruction. The security of the processing requires the ability to ensure the continued confidentiality, completeness, usability and fault tolerance of the systems and services as well as the ability to recover the accessibility of the data and access to the data if a physical or technical fault occurs. Protecting the data requires regular supervision and keeping track of the processing of personal data.
At Luotea, the employees are offered guidance and training concerning data security matters. All employees must know the security obligations concerning their duties and adhere to them. Each person is obligated to follow Luotea’s data security policy and guidelines.
Organization and responsibilities
Taking care of data protection is a vital and inseparable part of Luotea’s business activities.
The ultimate responsibility for the compliance of data protection legislation and this data protection policy rests with the managing director. The general counsel is responsible for the organizing of the compliance of data protection legislation and Luotea’s data protection policy and guidelines. Luotea’s IT management is responsible for the development and supervision of data security. The governance for data protection and data security is outlined in more detail in a separate governance model.
At Luotea, the employees are offered guidance and training concerning data protection matters. All employees must know the data protection obligations concerning their duties and adhere to them.
Consequences
Luotea is obliged to compensate the data subject for damage caused by unlawful processing of personal data. Violations of the data protection obligations may also result in fines imposed by the supervisory authorities, which may be up to EUR 20 million or 4% of Luotea's total global turnover. In addition, violations may lead to criminal liability.
Activities violating the data protection laws, this data protection policy or Luotea’s data protection guidelines are considered to compromise the data protection and may lead to consequences under labor law.
Approval of the data protection policy
The board of directors of Luotea Plc has approved this policy on xx.xx.2025.
Disclosure Policy
This disclosure policy lays down the operating principles and methods that Luotea Plc (Luotea) follows when communicating with the capital markets. The disclosure policy is approved by the company’s Board of Directors.
Goals and Principles of Investor Communications
Luotea’s shares are listed with Nasdaq Helsinki Ltd. In its information policy and investor communications, Luotea follows the applicable EU legislation, Finnish legislation, the rules of NASDAQ Helsinki, the regulations and guidelines of the European Securities and Markets Authority (ESMA) and the Financial Supervisory Authority, and Luotea’s internal guidelines.
The aim of Luotea’s investor communications is to convey correct, significant information to the capital markets that supports the correct price formation of the company’s shares and is simultaneously published to all market participants. The information to be published must be reliable, logical, credible and timely and must not be misleading.
All information is published in Finnish and in English.
Financial Reporting
Luotea’s financial year is one calendar year. Luotea publishes its financial statements release, half-year report and two interim reports in accordance with a schedule indicated before the end of the previous financial year. In addition, Luotea publishes its financial statements and report, and based on the Corporate Governance Code, a CR report and a remuneration statement.
Future Outlook
In its financial statements release, half-year report and interim reports, Luotea presents a verbal assessment of trends in net sales and profit for the current financial year. Luotea only provides assessments that concern the whole financial year.
Profit Warning
Luotea publishes a profit warning if it can reasonably assess that its future outlook has changed from previously published assessments and that the change is likely to have a major impact on the price of Luotea’s shares or other financial instruments. The change is assessed in relation to the most recently published economic survey.
It is mainly the Board of Directors that makes the decision to issue a profit warning. If the Board of Directors constituting a quorum cannot be summoned at sufficiently short notice, the Chairman of the Board or the President and CEO will decide on issuing a profit warning. They seek to talk to as many Board members as possible before publishing the release. The profit warning is issued as a stock exchange release that also includes the previously published future outlook. Issuing the profit warning cannot be postponed.
Stock Exchange Releases and Press Releases
With a stock exchange release, information is simultaneously issued to all market participants about facts, matters and conditions that Luotea believes are likely to have a major impact on the price of Luotea’s share and other financial instruments. Regulated information that is required to be published with a stock exchange release (such as business transactions made by the management using the company’s financial instruments, the notice to a General Meeting and decisions of the General Meeting, flagging notifications and changes in the Group Executive Board not concerning the President and CEO) is also published with a stock exchange release even if the information did not contain details affecting the price of the financial instruments.
For example, the following information may have a considerable impact on the price of Luotea’s shares and other financial instruments: major investments and acquisitions, significant redirection of business or a new cooperation arrangement, a pending important legal process or a decision awarded in this, and an important decision made by an authority or information concerning a joint venture.
As part of the aforementioned important arrangement or other event, the company prepares a case-specific assessment based on aspects and conditions related to each individual case and indicating whether the question is of insider information and whether the preconditions for postponing the publishing of information are met in that case. The assessment and, where necessary, the decision to set up an insider project and postponing the publishing of the information, are made by the Board of Directors or the President and CEO or a party authorized by them based on the recommendation of the CFO and the General Counsel. When the project is implemented, Luotea publishes the postponed information with a stock exchange release and submits a notification to the Financial Supervisory Authority about postponing the publishing of the information.
As an investor news release Luotea publishes significant events related to its business that do not meet the criteria for stock exchange disclosure but are considered to be of general interest to investors.
As a media release and on the company’s website, Luotea publishes news that does not meet the requirements of a stock exchange release but is deemed to have news value or to attract general interest among stakeholders.
In addition to the above, news not meeting the preconditions of a stock exchange release but which Luotea believes will have news value or arouse general interest among stakeholders, is published as a stock exchange release and on the company’s website.
All publications and financial reports are available on LT’s website for at least five years from their publishing.
Rumours, Market Speculation and Data Leakages; Crisis Communications
Luotea does not comment on market rumors, speculation presented by the media, share price trends, the actions of competitors or customers or analysts’ forecasts. The company does not comment on unpublished or ongoing business transactions either. If insider information, the publishing of which has been postponed, has leaked before it is published, its confidentiality can no longer be guaranteed or the preconditions for postponing the publishing of the information are not otherwise met, Luotea will immediately publish a stock exchange release about the matter.
In a situation where the rumor is evidently connected with insider information, whose publishing has been postponed, and is accurate enough to indicate that the confidentiality of the information can no longer be guaranteed, Luotea will publish a stock exchange release concerning the matter as soon as possible.
The company’s crisis communication guidelines are followed in case of a crisis.
Responsibilities and Spokespersons
Luotea’s President and CEO and CFO are responsible for contacts with investors, shareholders and analysts. Inquiries to the Board of Directors from capital market participants are directed to the Chairman of the Board. Where necessary, the Chairman either replies to them or directs them to the President and CEO.
Other persons are not entitled to give statements about the company’s finances. The contact details of responsible persons are found on the company’s investor pages.
Communications and contacts with the capital markets are coordinated by investor communications, which acts under the CFO. Depending on case, other representatives from the company can participate in the investor relations function.
Policies Followed in Investor and Analyst Meetings
Luotea arranges a briefing for analysts and investors in connection with publishing its financial statements release, half-year report and interim reports. Investors are also met in analyst and investor meetings, during analyst and investor visits to the company and in roadshows arranged by brokerage firms.
The discussions held at the meetings are based on previously published information or information generally available on the markets. The purpose of the discussions is to provide background information about Luotea and its business environment.
Silent Period
Meetings are not held, and Luotea representatives do not comment on the company’s financial position or future outlook during the period between the end of the reporting period and the publication of the financial results for that period. Exceptions to the quiet period rule include the Annual General Meeting held during the quiet period and the disclosure of significant business events via a stock exchange release during the quiet period. In these cases, communication must relate solely to the specific event in question.