1 Our Compass

To raise a compliance concern, contact the Ericsson Compliance Line

2 Our Compass
A message from
our President & CEO
Dear colleagues,
At Ericsson, we want to create connections that
make the unimaginable possible. It’s an inspirational
purpose we have set for ourselves, working towards
our vision of a world where limitless connectivity
improves lives, redefines business and pioneers
a sustainable future.
Our technology reaches far and wide, connecting
people and enterprises. The opportunity we have
is exciting, but it comes with a big responsibility.
How we conduct our business matters. Simply put, we
must always conduct our business ethically – we have
zero-tolerance for anything else.
Ethics are the moral principles that guide a
person’s actions. We are each expected to bring
ethical thinking into every interaction, decision and
transaction we undertake in the course of our work.
As long as we do so in good faith, we should not be
afraid of making those decisions or taking actions.
Similar to sports, winning against competitors is
everything in business. But we only win playing by
the rules, fair and square. Not following the rules is
cheating, and we have no tolerance for that.
In 2021, we have added integrity to our existing
values of respect, perseverance and professionalism,
to emphasize the importance we place on taking
ethical and responsible decisions. We have also
updated our Code of Business Ethics to reinforce our
Ericsson values and five focus areas. I encourage you
to think of the Code as Our Compass, a tool which will
help you set your ethical course and make the right
decisions.
Our Compass outlines Ericsson’s ethical expectations
and equips us to navigate the dilemmas we each
face in our work. It also points us to additional
resources, including where to find advice and support
whenever we need it. Senior management has a special
obligation to foster a culture of integrity, but following
our Compass is every individual’s responsibility.
When doing work for Ericsson, we need to think
carefully before we act. Ask yourself: does the action
feel like the right thing to do? Is it in the best interest
of Ericsson? Is it legal and ethical? How would I feel if
my action appeared on the front page of a newspaper?
As you answer these questions, use common sense
and refer to our Compass to understand which rules
may apply. If you have any doubts about the purpose,
principles or perception of your action, pause and seek
help from your manager. If your manager tells you to
proceed but you are still uncertain, seek guidance from
your compliance officer or contact the Compliance
Consultation Desk.
Also, if you see anything that you believe is not
right, speak up. Remember, you will always be
protected when you raise concerns in good faith.
Turning a blind eye is never acceptable. Actually,
I would like to raise the bar: I expect you all to speak
up if you see something. In a company of our size,
there is always a risk that a person tries to cheat,
we must all pull together to avoid that.
This lack of speak up culture was a lesson we learned
the hard way. In 2019, Ericsson concluded a settlement
with U.S. authorities for conduct that violated anti-
corruption laws. The fine we paid is money that was
taken away from forward looking investments. Just
imagine what USD 1b could have done if invested in
our world-class R&D. Those violations were also serious
breaches of our Code of Business Ethics. We now have
a valuable opportunity to learn from this experience
and prevent any recurrence. We want to make ethically
based decisions to make us a better company.
I ask you to read our Compass, understand it, ask
questions and raise concerns. By following our Compass,
we can earn and sustain the trust of society, our
customers and colleagues — trust that is fundamental
to our company’s success over the long term.
We imagine possible. We are Ericsson.
Börje Ekholm
President & CEO
June 2021
3 Our Compass

Use our
Compass

Our Compass is your guide to Ericsson’s ethical

principles and expectations. It’s aligned to our values
of professionalism, respect and perseverance, which
enable us to lead with integrity. By referring to it often,
you can be confident that your actions and decisions
are in line with Ericsson’s requirements for ethical
business conduct.
4 Our Compass

The requirements and guidelines described in our

Compass flow from six core ethical expectations,
which we all must know and follow

Our Code, our Compass Our business Our engagement

01 We build trust by making informed, 03 We do business with integrity 05 We respect human rights and
ethical decisions and seeking and transparency, and we are we make a positive social and
support whenever we are unsure. a law-abiding, responsible environmental impact in the
corporate citizen. communities where we work.

Our people Our assets We speak up

02 We maintain a safe, respectful, 04 We protect our company’s 06 We speak up whenever we have

inclusive and supportive work- reputation, assets and ethical concerns and we do not
place where harassment and intellectual property. tolerate any form of retaliation
discrimination have no place. against those who raise such concerns.
5 Our Compass

Every time you act for

Ericsson, remember the 3 Ps

P1
What is the
purpose of
my action?
• Is there a legitimate business
reason for this action?
• Is the action in Ericsson’s
best interests?
• What risks could this action
carry? How can I mitigate them?
P2
What principles
should guide
my action?
• Is the action legal and
consistent with our Compass
and steering documents?
• Is the action ethical and
in line with our values?
P3
How will
my action
be perceived?
• How would my action look
if it appeared on the front
page of a newspaper?
• Will my action impact
Ericsson’s reputation?
6 Our Compass

Our Code, our Compass Our physical assets and intellectual property
Table of 1.1 Be informed on Ericsson’s ethical expectations 08 4.1 Protect confidential information and intellectual property 23

Contents 1.2 Know your responsibilities when working for Ericsson 09 4.2 Use company information and assets responsibly 24

1.3 Raise compliance concerns 10 4.3 Protect personal data 25

4.4 Maintain proper financial controls and prevent fraud 26

Our people and workplace

4.5 Communicate responsibly 27

2.1 Treat everyone respectfully, inclusively and with dignity 12

2.2 Provide just and favorable working conditions and promote trade union rights 13 Our social and environmental engagement
2.3 Encourage health, safety and well-being 14 5.1 Promote the right to privacy and freedom of expression 29

2.4 Prohibit and prevent forced labor, human trafficking and child labor 15 5.2 Uphold our commitment to environmental sustainability 30

5.3 Empower and support local communities 31

Our business, customers and suppliers

3.1 Conduct business with integrity – and zero tolerance for corruption 17

3.2 Act in Ericsson’s best interest 18

3.3 Compete on the merits 19

3.4 Engage only with third parties who share our commitment to integrity 20

3.5 Respect international trade and anti-money laundering laws 21

To raise a compliance concern, contact the Ericsson Compliance Line

7 Our Compass

Our Code
Our people Our Code, We are committed to
conducting our business
Our business
Our assets our Compass ethically and responsibly
Our engagement – always.

1.1 Be informed on Ericsson’s ethical expectations 08

1.2 Know your responsibilities when working for Ericsson 09

1.3 Raise compliance concerns 10

01 To raise a compliance concern, contact the Ericsson Compliance Line

8 Our Compass 1.1

Our Code
Our people
Be informed on Ericsson’s
Our business ethical expectations
Our assets
Our engagement

Our Compass sets out our You can always talk to your line manager or the relevant function
(for example, the People Function or Group Function Legal Affairs
company’s expectations for & Compliance). They are all here to help. You can also reach out
to the Compliance Office directly or through the Compliance
how we conduct business. Consultation Desk to obtain compliance advice or relevant
approvals, or if you have any questions related to our Compass.
The Code of Business Ethics is our Compass. It is rooted
in Ericsson’s core values of professionalism, respect and
perseverance, and assists us in conducting our business with
integrity.

Our Compass applies to all Ericsson employees, any person

working for Ericsson over whom Ericsson controls the day-to-day
work, and members of the Board of Directors of all entities directly
or indirectly controlled by Telefonaktiebolaget LM Ericsson. Our
third parties, such as suppliers and partners, are also expected
to adhere to the values contained in our Compass by committing
to our Code of Conduct for Business Partners.

We are all required to follow applicable laws, regulations and

standards and adhere to Ericsson’s Group Steering Documents
and Local Steering Documents (collectively known as our
“steering documents”). If any of the requirements in our Compass
differ from legal requirements, you should always apply the more
demanding standard.

Violations of our Compass may lead to disciplinary action, up

Learn more to and including termination – regardless of your position in
the company. At the same time, we understand that people
Useful links sometimes make honest mistakes despite good intentions.
If that happens, be accountable and transparent. Speak up
• Our company story if you have a question or concern or if you have made a mistake.
• Ericsson on the Move webpage
• EGMS Application

To raise a compliance concern, contact the Ericsson Compliance Line

9 Our Compass 1.2

Our Code
Our people
Know your responsibilities
Our business when working for Ericsson
Our assets
Our engagement

We act with honesty • Not destroy or alter records

and integrity at all times. • Raise a compliance concern if you know

Each of us is responsible for acting with
integrity when we conduct business as
representatives of Ericsson.
You are expected to:
• Be respectful, professional,
honest and transparent
of, or suspect, violations of the law, our
Compass or steering documents
If you’re a manager, member of the Executive
Team or member of the Board of Directors,
you have an especially important role. You
are responsible for driving a culture of
integrity and compliance.
Leaders are also expected to:

• Not ask or allow another person or • Encourage your team members to

third party to do something that an ask questions and talk to them about
Ericsson employee is not allowed to do challenging ethical situations

Learn more
Steering documents
• Group Directive, Audit, Assessment
and Certification of Ericsson Group
Management System (EGMS)
Useful links
• Audits, Assessments,
Certificates and Accreditation
• Always act with integrity, even if it
means losing a business opportunity
• Be mindful of ethical risks which may be
elevated in certain markets and business
models, and take steps to mitigate them
• Cooperate and be forthcoming in any
investigations, audits or assessments
conducted by Ericsson or a legitimate
outside party (such as law enforcement
or an investigator retained by Ericsson)
• Ensure direct reports are properly trained
and know how to comply with our Compass
and steering documents
• Avoid putting pressure on your team
at the risk of implicitly encouraging
unethical conduct
• Report potential misconduct and
support your team members when
they raise concerns

To raise a compliance concern, contact the Ericsson Compliance Line

10 Our Compass 1.3

Our Code
Our people
Raise compliance concerns
Our business
Our assets
Our engagement

We speak up if something We are all expected to alert the company

Learn more
Steering documents
• Group Directive, Raising Compliance Concerns
• Group Instruction, Allegation Management
doesn’t seem right.
It is important to raise concerns promptly
whenever you suspect that a violation of
our Compass may have occurred.
If something doesn’t seem right:
• Talk to your line manager or the
superior of your manager
• Talk to someone in the People Function
or Group Function Legal Affairs &
Compliance, or
• Contact the Ericsson Compliance Line.
(When using the Ericsson Compliance Line,
you have the option to remain anonymous,
where permitted by local law.)
The Ericsson Compliance Line is hosted by
an independent third party, which handles
all reports securely and confidentially.
The Ericsson Compliance Line is available
24/7 to all internal and external stakeholders
in 63 languages.
to any suspected breaches of our Compass.
People who raise a genuine concern will
always be protected; we do not tolerate
retaliation in any form. If you’re a line
manager or other trusted person and someone
raises a compliance concern to you, you must
report it to Group Function Legal Affairs &
Compliance or to the Ericsson Compliance
Line. Although it may be necessary to speak
with the reporter to better understand the
nature of their concern before you report it,
you must not start your own investigation.
You always have the right to raise concerns
with your trade union or works council
representatives – but you are still expected
to report potential violations of our Compass
through the proper Ericsson channels.
What happens after I report a compliance concern?
Your concern will be assessed by the Allegation Management Office.
If the concern relates to a potential violation of our Compass, it will be
investigated by Corporate Investigations or other relevant function. If a
violation is found to have occurred, actions will be taken to hold people
accountable and improve our processes to prevent future breaches. When
sharing information about reported compliance concerns, the Allegation
Management Office and Corporate Investigations will respect privacy laws,
confidentiality and the rights of the individuals involved. Information about
the allegation management process that is not confidential may be shared
with those who reported a concern, where appropriate.
If your concern involves a senior member of Group Function Legal Af-
fairs & Compliance, please refer to the Reporting Compliance Concerns
webpage for guidance.

Useful links

• Reporting Compliance Concerns webpage

To raise a compliance concern, contact the Ericsson Compliance Line

11 Our Compass

Our Code
Our people Our people We are committed to fostering an inclusive and
supportive workplace where you can reach your
Our business
Our assets and workplace full potential. We respect the dignity of every human
Our engagement being and work in accordance with all internationally
recognized human rights including those outlined
in the International Bill of Human Rights and the
International Labor Organization’s Declaration on
Fundamental Principles and Rights at Work.

2.1 Treat everyone respectfully, inclusively and with dignity 12

2.2 Provide just and favorable working conditions and promote trade union rights 13

2.3 Encourage health, safety and well-being 14

02
2.4 Prohibit and prevent forced labor, human trafficking and child labor 15

To raise a compliance concern, contact the Ericsson Compliance Line

12 Our Compass 2.1

Our Code
Our people
Treat everyone respectfully,
Our business inclusively and with dignity
Our assets
Our engagement

We foster a work environment We know that diversity makes us

based on respect.
Treating our colleagues with respect, dignity
and inclusion brings out the best in everyone,
and it’s the right thing to do. At Ericsson, there
is simply no room for harassment, threats,
bullying or violence against anyone,
regardless of their position or seniority.
Ericsson prohibits all forms of harassment,
threats and acts of violence, including:
stronger as a company. Having a diverse
and inclusive workplace helps ensure that we At Ericsson, we prohibit all forms of discrimination, even if local law
attract the best global talent, foster innovation would permit it. We do not discriminate based on factors such as race,
and bring greater value to our customers. color, gender, language, religion, political affiliation, national or social
We want everyone to feel valued and included. origin, pregnancy or parental status, disability, marital status, age,
sexual orientation, gender identity and/or expression, transgender
We must all contribute to ensuring Ericsson status, health status, trade union membership or any other characteristic.
is a place where each individual can grow
and feel empowered – regardless of factors
such as their personal background, cognitive
perspectives or disability.
You are expected to:

• Physical, oral or written harassment • Recruit, reward and promote

directed at employees or any third party people based on merit
in the line of work (whether at the office,
outside the office or online) • Prevent nepotism or
discriminatory practices
• Bullying, intimidation, hostility,
humiliation, discrimination or • Avoid any conduct that could make
psychological mistreatment an employee feel excluded or unwelcome.
Learn more This applies within or outside working
• Offensive or disparaging remarks, hours, inside or outside Ericsson premises
jokes, images or name-calling and during external events or business
Steering documents travel
• Unwanted attention or physical
• Group Policy, People
contact or other invasions of privacy
or personal space
Useful links
• Behavior intended to disturb or
• Check with local People function
for local steering documents
prevent normal work activities

To raise a compliance concern, contact the Ericsson Compliance Line

13 Our Compass 2.2

Our Code
Our people
Provide just and favorable working
Our business conditions and promote trade union rights
Our assets
Our engagement

We uphold everyone’s We also promote your rights when it

right to fair and favorable
working conditions and
the right to form and join
trade unions and bargain
collectively.
comes to forming or joining independent
trade unions as well as collective bargaining.
In places where local laws restrict these
rights, Ericsson seeks other ways of having
a meaningful dialogue with employees. This
includes alternative, independent and freely
elected forms of employee representation
such as employee committees or councils.

As a responsible employer, we respect You must respect all colleagues’ freedom

your rights to just and favorable working
conditions regardless of your position.
This includes:
• Receiving a written document in a
language you understand, outlining
the basic terms and conditions of your
employment
• Fair and reasonable pay and terms,
which guarantee your rights and, at a
minimum, include a living wage or pay
Learn more in line with industry standards, whichever
is higher (deductions from fixed salaries
or wages as a disciplinary measure are
Steering documents
not permitted for hours worked)
• Group Policy, People
• The right to rest and leisure to support
a healthy work-life balance, including
Useful links working hours that comply with all
• Check with local People function
applicable laws and industry standards
for local steering documents
of association and right to collective
bargaining, and you must not unlawfully
limit these rights. You are not permitted
to treat anyone differently based on their
choice to join – or not join – a trade union
or similar organization and trade union
representatives must be able to communicate
effectively with employees.
A normal work week should not be
more than 48 hours. Hours worked
above and beyond a normal work
week must be voluntary unless a
collective bargaining agreement
allows for extra time under certain
conditions or in exceptional
circumstances. Such circumstances
include short-time business demands
and emergencies. Additionally,
except for exceptional circumstances,
you have the right to at least one day
off in every seven-day period.
What is a living wage?
Having a living wage means
receiving a rate of payment from
work that is high enough to
maintain a decent standard of
living. For a worker to have a living
wage, they would need to be able
to cover their costs for food, water,
housing, essential healthcare,
transportation, etc.

To raise a compliance concern, contact the Ericsson Compliance Line

14 Our Compass 2.3

Our Code
Our people
Ensure health, safety
Our business and well-being
Our assets
Our engagement

We work together to ensure

a safe and healthy work
environment for all.
We are committed to providing a work
environment that promotes and protects
everyone’s health, safety and well-being.
To achieve our goal of zero work-related
fatalities, injuries and illnesses, we all need
to work together. Ericsson Care is our holistic
health, safety and well-being program for our
employees, suppliers and anyone working
for us to achieve this target. Ericsson Care
focuses on safety risks and well-being that
encompasses physical, emotional, financial,
and social well-being.
Learn more
Steering documents
You are expected to:
• Adopt safe behaviors by taking assigned
safety training courses and using personal What should I do if I’m concerned
for my – or a colleague’s – safety,
protective equipment when appropriate or
health or well-being?
required by the site rules
You have the right to speak up
• Identify and mitigate health and safety
and stop working if there is a
risks related to our activities
reasonable concern about your
or your colleague’s health, safety
• Proactively help to create an environment
or well-being. If the situation is
that promotes physical and emotional
not corrected, you should reach
well-being
out to your local health and safety
representative or report it in the
• Not work under the influence of alcohol.
Global Incident Reporting Tool.
In addition, illegal substance abuse is
prohibited while performing work for
Ericsson
• Not work under the influence of medication
if doing so could jeopardize anyone’s health
or safety

• Group Policy, Health, Safety and Well-being • Report any health and safety incidents via
• Group Directive, Occupational
Health and Safety
the Global Incident Reporting Tool so we can
prevent recurrences

Useful links

• Health & Well-being webpage

To raise a compliance concern, contact the Ericsson Compliance Line

15 Our Compass 2.4

Our Code
Our people
Prohibit and prevent forced labor,
Our business human trafficking and child labor
Our assets
Our engagement

We work here because we have

freely chosen to do so, and we
support the rights of children.
At Ericsson, any form of slavery exploitation – including
human trafficking and forced, coerced, bonded or compulsory
labor – is strictly prohibited. All work performed for Ericsson
must be voluntary, consensual and free from coercion or
threats. We are all free to leave our employment or assignment
after giving reasonable notice according to applicable law.
You shall never accept to leave deposits of money or identity
papers with Ericsson or a recruitment agency.
You are prohibited from purchasing, or allowing others to
purchase for you, sexual services – or other services of a
sexual nature – while on company-sponsored trips or in
connection with company business, regardless of local
legislation.
What is the minimum age of employment?
The International Labor Organization (ILO)
defines the minimum age for employment as the
age at which someone would complete compulsory
schooling – or 15 years and older – unless an explicit
ILO exemption is provided. In addition, young
workers (under 18 but over the minimum age for
employment) cannot be employed for hazardous
work or work that is inconsistent with their
personal development. This includes working
at heights, working with dangerous machinery
or hazardous substances, working for long hours
or working overnight.

We uphold and defend the rights of children. We firmly

prohibit child labor and apply precautionary principles to
avoid causing harm to children throughout our operations.
An individual’s age must be verified and documented during
the hiring process to ensure that they are of appropriate
working age.

You must not ask prospective employees to pay recruitment fees or other service-related costs.
This applies whether or not a recruiting agency is used.

To raise a compliance concern, contact the Ericsson Compliance Line

16 Our Compass

Our Code
Our people Our business, We are committed to doing business
in every market with integrity and
Our business
Our assets customers and transparency and being a responsible
Our engagement
suppliers corporate citizen.

3.1 Conduct business with integrity – and zero tolerance for corruption 17

3.2 Act in Ericsson’s best interest 18

3.3 Compete on the merits 19

03
3.4 Engage only with third parties who share our commitment to integrity 20

3.5 Respect international trade and anti-money laundering laws 21

To raise a compliance concern, contact the Ericsson Compliance Line

17 Our Compass 3.1
Our Code
Our people
Conduct business with integrity
Our business – and zero tolerance for corruption
Our assets
Our engagement
We win business by doing
business with integrity.
Reputation and trust are hard-won and easily
lost. At Ericsson, we advocate our industry and
regulatory positions to governments based on
facts, and never seek to improperly influence
actions by public officials. Offering or giving
any benefit to a public official, colleague,
customer or other third party as a way to gain
an undue advantage is called bribery, and it is
strictly prohibited. You must also not demand
or accept any such benefits from anyone.
We have no tolerance for any form of bribery
or corruption. In addition, Ericsson will not
make contributions, directly or indirectly, to
Learn more political parties or individual politicians except
to support voluntary employee contributions
Steering documents permitted under local law and supported by
public reporting regulations.
• Group Policy, Government
& Industry Relations
• Group Directive, Anti-Corruption
• Group Directive, Partnering
• Group Directive, Third Party Management
• Group Instruction, Gifts, Entertainment
& Hospitality - Third Party Benefits
Useful links
• Anti-Corruption Compliance webpage
• Gifts, entertainment and hospitality webpage
You are expected to:
• Ensure that any gifts, entertainment,
hospitality, sponsorships, donations and
employment opportunities are compliant
with our steering documents and the law
Who qualifies as a public official?
• Never provide any personal benefits to
individuals, such as cash, cash equivalents,
loans, vacations or similar benefits Members, employees
or representatives of:
• Be diligent when providing anything to
public officials (or their family members) • Governments – whether
and remember that pre-approvals and national, regional or local
more restrictive rules apply
• State-owned or state-
• Obtain the necessary approvals and controlled companies
document them
• The military, police and courts
• Never make a payment to expedite or
secure a routine governmental action, such • Political parties and candidates
as the issuance of a visa, permit or license
• Public international organizations
• Not use personal funds or someone else’s (for example, the United Nations
funds to do something that you couldn’t or the World Bank)
do with corporate funds, for example
purchasing illegal gifts such as ivory, • Royal families
narcotics or sexual services
• Consult Government & Industry Relations or
Group Function Legal Affairs & Compliance
prior to meeting with government officials
To raise a compliance concern, contact the Ericsson Compliance Line
18 Our Compass 3.2

Our Code
Our people
Act in Ericsson’s best interest
Our business
Our assets
Our engagement

We act swiftly and Examples of potential conflicts of interest:

transparently to disclose • Doing business with third parties that

Learn more
Steering documents
• Group Policy, Legal Affairs and Compliance
• Group Directive, Board positions
and Ownership interests
• Group Instruction, Conflict
of Interest Disclosure
• Group Instruction, Gifts, Entertainment
& Hospitality - Third Party Benefits
Useful links
• Conflict of Interest webpage
• Compliance Consultation Desk webpage
anything that may be a
conflict of interest.
In our work for Ericsson, situations can
arise where our professional judgment could
be seen to be impaired by other competing
interests related to relationships and roles
we maintain outside of Ericsson. This is
called a conflict of interest, and it is not
inherently wrong. However, we each have
a responsibility to put Ericsson’s legitimate
business interests first. Whenever we become
aware of a potential conflict of interest,
we don’t ignore it; we ensure that it is
properly disclosed and handled.
You are expected to:
• Avoid conflicts of interest
when manageable
• Disclose all situations, transactions
and relationships that could lead to or
be perceived as a conflict of interest via
the Compliance Consultation Desk.
Compliance Office and People Function
will help you manage the situation
employ or are owned by your family
members, friends or former Ericsson
colleagues
• Hiring or supervising anyone with
whom you have a personal relationship
• Working in your free time for Ericsson
customers or suppliers
• Working outside Ericsson or taking
on engagements or directorships that
interfere with your job performance,
require you to use Ericsson’s information
or assets or would create intellectual
property
• Engaging on behalf of Ericsson with
customers, suppliers or other external
stakeholders of a company in which
you have ownership or other significant
financial interest
Is it a potential conflict of interest
if I refer someone for a position
within Ericsson?
It depends. You may refer friends,
family members or others for open
positions – and you may receive
rewards if the referred individual
is hired through the Employee
Referral Program. If the position
is within your function, you should
disclose the potential conflict of
interest to your People Business
Partner at the time of the referral
as well as to your line manager and
the Compliance Consultation Desk
– so steps can be taken to avoid any
appearance of bias or favoritism
during the hiring process.

To raise a compliance concern, contact the Ericsson Compliance Line

19 Our Compass 3.3

Our Code
Our people
Compete on the merits
Our business
Our assets
Our engagement

We compete on the merits You are expected to:

of our technologies and • Not discuss or exchange competitively What is competitively sensitive information?
sensitive information with competitors
offerings. either directly or indirectly through third Any information that could influence a commercial decision of
parties Ericsson or a competitor. This could include details of prices, costs,
margins, offers or quantities, and allocations of product, markets
Competition laws – also known as antitrust
• Not fix or control distributors’ resale prices and territories.
or anti-monopoly laws – exist to protect
consumers and ensure that businesses have
• Check with Group Function Legal Affairs &
a fair opportunity to compete in the market-
Compliance before negotiating exclusivity
place. They prohibit, for example, practices
or non-compete agreements or hiring
that fix prices, allocate customers or markets
restrictions with third parties
between competitors or restrict market
competition. These laws also prohibit the
• Contact Group Function Legal Affairs &
abuse of a dominant market position.
Compliance if you have concerns in relation
to any competition matters

Learn more

Steering documents

• Group Policy, Antitrust law

Useful links

• Antitrust Compliance Guide webpage

• Compliance Consultation Desk webpage

To raise a compliance concern, contact the Ericsson Compliance Line

20 Our Compass 3.4

Our Code
Our people
Engage only with third parties who
Our business share our commitment to integrity
Our assets
Our engagement

We only work with third You are expected to:

parties who abide by the • Work only with qualified, approved third
parties that go through our responsible
same standards of integrity sourcing processes, including our enhanced
that we demand of ourselves. Third Party Management (TPM) process

• Ensure that our third parties sign and

Working with third parties can present
significant risks that we must carefully
navigate – so that the values we stand for
aren’t compromised. At Ericsson, we only
engage with suppliers and other partners
who share our high standards in relation
to integrity, human rights, health and safety
and the environment.
commit to our Ericsson Code of Conduct
for Business Partners or equivalent
• Actively monitor the performance of our
third parties for compliance with the Code
of Conduct for Business Partners and any
other conditions upon which an approval
decision was made

• Never use a third party to do something

that Ericsson employees are not allowed
to do themselves

Learn more

Steering documents
A Politically Exposed Person (PEP) is someone who holds
• Group Directive, Third Party Management
• Group Directive, Anti-Corruption (or formerly held) a prominent public position or a family member
• Group Directive, Partnering or close associate of such a person. PEPs present a higher risk of
being involved in corruption because of their position and influence.
Be especially diligent when working with PEPs.
Useful links

• Ericsson Responsible sourcing page

To raise a compliance concern, contact the Ericsson Compliance Line

21 Our Compass 3.5

Our Code
Our people
Respect international trade
Our business and anti-money laundering laws
Our assets
Our engagement

Learn more
Steering documents
• Group Directive, Trade Compliance
• Group Directive, Customer Finance
• Group Directive, Third Party Management
• Group Directive, Sourcing
• Group Instruction, Trade Compliance
• Instruction, Recusal of U.S.
persons for sanctions purposes
We adhere to applicable laws
and regulations governing
international trade and anti-
money laundering.
The European Union (EU), United States
(U.S.) and other countries enforce trade and
sanctions laws; these include export and
customs controls, embargoes and sanctions.
Such laws impact the persons, countries and
entities with whom we can do business. They
also affect the hardware, software, services
and solutions we can sell.
You are expected to:
• Be aware of any sanctions, import or export
controls that might apply to your business
dealings on behalf of Ericsson before doing
such business and ensure that a license is
obtained when required
• Ensure that Ericsson’s sanctions screening
process is performed before onboarding
new third parties and regularly thereafter
We support free and fair trade and are
Money laundering is an illegal activity where someone attempts to hide the
true origins of money that was obtained through crime. Terrorist financing
committed to comply with applicable anti- is when funds are used to support terrorist activities. Ericsson does not allow
boycott regulations. Always seek advice from any activities resulting in money laundering or terrorist financing.
Group Function Legal Affairs & Compliance if
you are unsure of the legality of an action or if You are expected to:
you are asked to participate in a boycott.
• Never engage in a business transaction if you suspect
that it involves funds connected with criminal activity
• Adhere to all Ericsson responsible sourcing and due
diligence requirements
A “United States person” is a
U.S. citizen, green-card holder
or person physically located in
the U.S. If you are such person
you may be restricted from
participating in certain business
activities under U.S. sanctions
laws and you might need to
recuse yourself under certain
circumstances.

• Contact Trade Compliance within Group

Useful links Function Legal Affairs & Compliance
when in doubt
• GFLA Trade Compliance webpage
• Trade Compliance Global Operations webpage

To raise a compliance concern, contact the Ericsson Compliance Line

22 Our Compass

Our Code
Our people Our physical assets We are committed to protecting our
company’s assets and intellectual
Our business
Our assets and intellectual property as well as information and
Our engagement
property assets entrusted to us by our colleagues,
customers and third parties.

4.1 Protect confidential information and intellectual property 23

4.2 Use company information and assets responsibly 24

4.3 Protect personal data 25

04
4.4 Maintain proper financial controls and prevent fraud 26

4.5 Communicate responsibly 27

To raise a compliance concern, contact the Ericsson Compliance Line

23 Our Compass 4.1
Our Code
Our people
Protect confidential information
Our business and intellectual property
Our assets
Our engagement
We handle confidential
information and intellectual
property with great care.
At Ericsson, our technical and financial
information as well as our intellectual
property are critical to our success.
This includes research and development
information, patents, business and product
plans and strategies as well as customer
and supplier information. We must ensure
that such information is used for proper
and authorized purposes only.
You are expected to:
Learn more
• Not discuss confidential information
Steering documents in public places or on the internet
• Group Policy, Intellectual Property Rights
• Only access or share confidential
• Group Policy, Security
• Group Directive, Intellectual Property Rights information if there is a legitimate
• Group Directive, Handling of financial business reason to do so
information within Ericsson Operating Units
• Group Directive, Information Security
• Only store confidential information on
Management System
Ericsson-authorized devices and cloud
services
Useful links
• Accompany your visitors at Ericsson’s
• Reporting Security and Privacy Incidents
webpage offices and facilities
• Compliance Consultation Desk webpage
• Security at Ericsson
• Not take or use Ericsson confidential
information when you leave the company
Be sure to report all potential information security incidents
• Not attempt to improperly obtain
confidential information belonging
via the Security Incident Management System (SIMS).
to other companies or third parties
Each of us has a responsibility to watch out
for cybersecurity threats – such as malware or
phishing – and follow best practices to protect
Ericsson’s information and systems.
You are expected to:
I recently joined Ericsson and What steps do we need to take
• Keep your computer and mobile devices
have confidential information when onboarding a new supplier
updated to the latest software versions
and change your passwords about my former employer: who will need access to Ericsson’s
a competitor. Is it OK to discuss confidential and proprietary
• Not share user IDs (signums) their sales strategy? information?
or passwords
No. This information does not Any disclosure of confidential
• Use the software provided for securely belong to you and it’s not OK to and proprietary information to
use it for your own purposes or third parties requires the signing
connecting your laptop to Ericsson’s
for Ericsson’s. You could breach of a non-disclosure agreement
network when away from the office
the law or your own obligations (NDA) or similar provisions in a
• Never download or use unapproved to your former employer by contract. Contact your Sourcing
disclosing the information to Business Partner or Group Function
software or devices
Ericsson. Please contact the Legal Affairs & Compliance if you
Compliance Consultation Desk have any questions or need support.
• Encrypt emails containing any
confidential or personal information if you need further guidance
regarding potential conflicts
of interest.
To raise a compliance concern, contact the Ericsson Compliance Line
24 Our Compass 4.2

Our Code
Our people
Use company information
Our business and assets responsibly
Our assets
Our engagement

We do not engage in any form You are expected to:

of insider trading and we use
company assets for legitimate
purposes only.
Inside information is non-public and
material information about Ericsson or other
companies that would have a significant
effect on the price of financial instruments
and securities, such as shares, bonds or
derivatives, if disclosed. Using this information
or providing it to others to trade in financial
instruments and securities is illegal. It is called
insider trading, and it must be avoided without
exception.
• Not buy or sell financial instruments and
securities when having inside information
or tell others to do so
• Not share inside information with anyone All Ericsson employees are
including colleagues except on a strict recommended not to trade in Ericsson
need-to-know basis, as approved by financial instruments and securities
the project leader during a period of 30 days before the
publication of financial reports even if
• Check with Group Function Legal Affairs you do not possess inside information.
& Compliance before trading if you are
unsure if you are in possession of inside
information

Use Ericsson’s IT systems and

Learn more resources only for business-related
activities. You are responsible for
protecting company assets from
Steering documents misuse, waste, theft and loss.
• Group Policy, Insider Rules
This includes not using Ericsson’s
• Group Policy, Security IT resources for any activity that is
• Group Instruction, Handling illegal, harassing, sexually oriented,
of Inside Information defamatory, racially inflammatory,
in violation of human rights or related
to child sexual abuse.
Useful links

• Security at Ericsson

To raise a compliance concern, contact the Ericsson Compliance Line

25 Our Compass 4.3

Our Code
Our people
Protect personal data
Our business
Our assets
Our engagement

We process personal data • Share personal data only with people

(within and outside Ericsson) who are
responsibly and in accordance authorized to receive it
with data privacy laws. • Report any suspected data breaches
to the Security Incident Management
System (SIMS)
We protect personal data and support global
efforts to safeguard it. We adhere to global
privacy principles and applicable laws,
including the EU General Data Protection
Regulation (GDPR). We also have Binding
Corporate Rules and contractual agreements
which regulate how we process and share
data.

You are expected to:

Learn more
Steering documents
• Group Policy, Privacy
• Group Directive, Data Privacy Management
• Group Directive, Processor Binding
Corporate Rules relating Data Privacy
• Group Directive, Binding Corporate
Rules for Data Controller
• Group Instruction Product
Security and Privacy
• Collect and process personal data in
accordance with the law and Ericsson
steering documents
• Ensure that people from whom we obtain
personal data understand why it is being
collected and processed
• Use personal data only for legitimate
business purposes and approved uses
necessary for your job
What is “personal data”?
Personal data is information that
can be related to an identifiable
person. Examples include name,
address, phone number, IMEI
(International Mobile Equipment
Identity), IMSI (International
Mobile Subscriber Identity), email
and bank or credit card information.

Useful links

• Reporting Security and Privacy

Incidents webpage

To raise a compliance concern, contact the Ericsson Compliance Line

26 Our Compass 4.4
Our Code
Our people
Maintain proper financial
Our business controls and prevent fraud
Our assets
Our engagement
We record all financial
information diligently,
accurately and honestly.
We must all take steps to prevent fraud
and financial irregularities. We should
always ensure that the true nature and
extent of our business transactions are
recorded transparently and accurately.
Making false or misleading entries in our
records, or sidestepping internal controls,
are strictly prohibited and may be illegal.
You are expected to:
• Enter into written (never oral)
contracts with customers and third parties
Learn more
• Ensure our contracts reflect the
Steering documents
substance of the commercial transaction
• Group Directive, Ericsson Operating Model
• Group Directive, Travel & Expenses • Avoid giving unusual incentives or
• Group Directive, Financial Authorization agreeing to terms that are not in
• Group Directive, Signatory Powers
• Group Directive, Sourcing
Ericsson’s best interest
• Group Directive, Ericsson Sales Directive
• Group Instruction, Time Reporting • Follow signature and spending authority
for Employees and relevant approval processes
Useful links
• Ericsson Governance
• Record all financial transactions in
accordance with applicable rules and
Ericsson Accounting Directives and
Instructions
• Never authorize the payment of vague
or questionable expenses or third-party
invoices that are poorly documented or
incomplete
• Ensure expense reports are complete,
truthful and accurate
• Use corporate cards for legitimate
business expenses
• Provide all supporting documentation
needed to ensure accurate financial
statements
• check with Group Function Finance &
Common Functions or your local finance
support if you are not sure what to do or
have finance-related questions or concerns
Raise a concern if you
become aware of for example:
• Payments to or from a third party
in a country other than where the
service was provided
• Payments to a third party in a
country known as a “tax haven”
• Payments to or from third parties
different from those specified in
approved agreements
• False, misleading or incomplete
business records, including time
reporting records
• Pressures to make an inaccurate
entry in our accounts or to omit
relevant information
• Unrecorded funds or financial accounts
• Revenues or expenses that have been
unduly shifted between time periods
• Use corporate cards for legitimate
business expenses only
To raise a compliance concern, contact the Ericsson Compliance Line
27 Our Compass 4.5

Our Code
Our people
Communicate responsibly
Our business
Our assets
Our engagement

We speak on behalf of the company

only if authorized to do so and take
care when posting on social media.

Our reputation depends on the transparency, accuracy and

consistency of our public statements. That’s why we have
measures in place to ensure the right information goes out.
These measures apply to statements you make publicly on
social media or in articles, papers, speeches or other statements
relevant to Ericsson’s business. While we promote freedom
of expression, each of us is responsible and may be held
accountable for social media posts that are inconsistent
with our values and Compass.

You are expected to:

• Use good judgment and protect confidential

I’ve received an invitation to speak at an industry I’ve received a straightforward question about
information about Ericsson
conference. Do I need permission to speak? What the company from a friend. May I respond?
Learn more can I say about Ericsson or my work for the company?
• Make clear that your views are your own and
We love speaking about what we do at Ericsson,
that you do not speak for Ericsson (unless you
The first step is to get approval from your line but it all depends on what was asked. You cannot
Steering documents are authorized to do so)
manager and notify Marketing & Corporate share confidential information, but you are, of course,
• Group Policy, Communications Relations. Generally, when speaking at conferences, encouraged to share officially published information.
• Not post anything that would cause
• Group Directive, Spokesperson focus on your own area of responsibility and personal The key is to take a moment to think about this
• Group Directive, Investor Relations embarrassment or harm Ericsson’s
opinions and observations – do not share sensitive carefully before answering. You can ask your line
• Group Instruction, External Social Media reputation
and Security at Ericsson or confidential company information. manager if you need further guidance on what can
and cannot be discussed openly.

Useful links

• Security at Ericsson

To raise a compliance concern, contact the Ericsson Compliance Line

28 Our Compass

Our Code
Our people Our social and We are committed to respecting
human rights, reducing environmental
Our business
Our assets environmental impact and supporting socio-economic
Our engagement
engagement development across the communities
in which we work.

5.1 Promote the right to privacy and freedom of expression 29

5.2 Uphold our commitment to environmental sustainability 30

5.3 Empower and support local communities 31

05 To raise a compliance concern, contact the Ericsson Compliance Line

29 Our Compass 5.1

Our Code
Our people
Promote the right to privacy
Our business and freedom of expression
Our assets
Our engagement

We respect the right to You are expected to:

privacy and freedom of • Respect, promote and support human

expression, as the two most
salient human rights related
to the technology we deliver.
rights through responsible decision-
making, including during product
development, the use and sales of our
technology, and in business relationships
with customers and suppliers

• Assess external requests and demands

We fundamentally believe that our hardware, that may impact the freedom of expression
software, services and solutions bring positive or right to privacy of individuals and ensure
change to people. At the same time, we such requests are legitimate, proportionate
work to mitigate and minimize the risk of and necessary before acting in response
potential misuse of our technology. We do
this by conducting due diligence in our sales • Consider the risks of misuse of our
engagements to assess, prevent and mitigate technology in business engagements,
potential negative impacts on human rights. follow the correct procedures to mitigate
such risks and raise a concern if such risks
We also advocate strongly for freedom are being ignored or not properly addressed
of expression and privacy protections.
This includes raising concerns about new
legislative, administrative, license or law
Learn more enforcement rules if they may negatively
impact individuals’ freedom to express their
views or protect others from intrusion.
Steering documents

• Group Policy, Sensitive Business

• Statement, Business and Human Rights

Useful links

• Ericsson respect for human rights webpage

To raise a compliance concern, contact the Ericsson Compliance Line

30 Our Compass
Our Code
Our people
Our business
Our assets
Our engagement
Learn more
Steering documents
• Group Policy, Sustainability
• Group Directive, Product Take-Back
Useful links
• Ericsson sustainability and
corporate responsibility webpage
• Ericsson and the Sustainable
Development Goals webpage
• Design for Environment webpage
• Ericsson requirements
on material declarations
• Ericsson List of Banned and
Restricted Substances
5.2
Uphold our commitment to
environmental sustainability
Our environmental
sustainability programs
make a difference for the
world around us and create
value for all stakeholders.
We use a science-based and triple bottom
line (economic-social-environmental)
approach to create positive impact for
stakeholders throughout our operations,
across our portfolio and in society.
We are committed to minimizing the negative
environmental impact of all our operations
and activities, and are on track to be carbon
neutral in our own operations by 2030. We
develop hardware, software, services and
solutions designed with life cycle and circular
economy perspectives in mind – striving for
high energy performance and sustainable
material and design choices. And we take
back and recycle decommissioned products
responsibly.
Environmental sustainability shall be an
integrated approach spanning all our units –
a mindset we all share as part of Ericsson’s
workforce.
You are expected to:
• Contribute to Ericsson’s ambitions and
targets related to the environmental
impact of our operations and activities
and our product sustainability
• Minimize business travel and consider
surface transportation before air travel
• Follow all environment-related
product requirements, guidelines
and recommendations
• Consider how you can perform your
work in a way that positively impacts
the environmental performance of our
customer offerings
• Report any risks or incidents with
potentially negative environmental
impact using the Global Incident
Reporting Tool
At Ericsson, we are actively engaging
in partnerships and developing hardware,
software, services and solutions that
support industries and societies in their
efforts to realize the UN Sustainable
Development Goals (SDGs).
To raise a compliance concern, contact the Ericsson Compliance Line
31 Our Compass 5.3
Our Code
Our people
Empower and support
Our business local communities
Our assets
Our engagement
We empower and support
local communities to drive
positive impact.
We practice good corporate citizenship by
providing sponsorships, donations and volun-
teers to support stakeholder engagement and
empower our local and regional communities.
We pay applicable local taxes in the countries
in which we operate.
We carefully assess sponsorships and
donations to confirm that they are consistent
with Ericsson’s strategy in terms of where
we think our support can have the greatest
impact. We also do our due diligence to
ensure they are free from any actual or
potential conflicts of interest – or have
Learn more
any association with improper payments.
Steering documents You are expected to:
• Group Policy, Finance • Request approvals for sponsorships
• Group Policy, Sponsorships and Donations
• Group Directive, Sponsorships and Donations
and donations falling under the
• Group Instruction, General Expenses Sponsorships and Donations Directive
via the Sponsorships and Donations
Request form
Useful links • Seek approvals for other sponsoring
• Sponsorships and Donations webpage activities and contributions via the
• Ericsson Response webpage Compliance Consultation Desk
• Ericsson employee volunteering framework
• Ensure due diligence is conducted as
required in accordance with steering
documents
• Disclose any connections between
sponsorships or donations and Ericsson’s Am I allowed to sponsor the
annual gala of a local charity
customers, suppliers, partners, public
– one that is chaired by a key
officials or Ericsson current or former
customer?
employees
It depends. If, for example,
We are proud of our Ericsson Volunteer
there is a significant business
Program. It allows employees to
volunteer their time to serve local opportunity pending with the
customer, there could be an
communities and make a positive impact
appearance that the customer’s
in society. All active Ericsson full-time and
business decisions had been,
part-time employees are eligible to participate.
or could be, influenced by the
sponsorship. In all cases, you
Before volunteering, you must approve the
should submit a request via the
terms and conditions within the program
Sponsorships and Donations
and adhere to the guidelines related to
request form so it can be
eligible volunteer activities – both Ericsson’s
and the receiving organization’s. evaluated – giving you peace
of mind either way.
To raise a compliance concern, contact the Ericsson Compliance Line
 ericsson.com/cobe
internal.ericsson.com/cobe