The Nera Group Code of Business Ethics and Conduct
1. Forward
Backed by more than 45 years of experience, and with a global footprint across Asia Pacific, Europe, Middle East and Africa, Nera Telecommunications Ltd (“NeraTel”) and its subsidiaries (collectively the “Nera Group”) empowers communities for the future.
Our forte is in the business of connecting people, and focusing on what is important to our customers and their businesses, as we continue to leverage technology to help our customers position for growth in an ever-evolving landscape.
Together with our highly qualified and competent team of engineers and professionals, we are dedicated to driving an ethical business culture within the Nera Group, to ensure that business is conducted with utmost integrity, transparency, and ethical standards.
2. Nera Group’s Core Values
Our six values encapsulate the spirit and attitude of every Nera employee (fondly referred to as “Nerator”). They are what inspire, guide and drive us to go beyond for our customers and each other, ensuring the same high ethical standards are practiced wherever we operate.
Respect
We foster an inclusive and welcoming work environment for all, treating everyone around us with courtesy, dignity and empathy.
Integrity
Being transparent, truthful, fair and accountable in our actions and behaviour, even when no one is watching.
Customer focus
We put our customers at the heart of every business decision.
Relentless Passion
Our unyielding dedication to our work comes from within and is what motivates and drives us in the face of any setbacks that may arise.
Teamwork
We cooperate, communicate and support one other in our solidarity in delivering on our promises with diligence and efficiency.
Professional Excellence
Our highly trained and competent team takes pride in their work and in delivering quality results every time.
3. About the Code
At Nera Group, we are committed to conducting our business with the utmost integrity, transparency, and ethical standards. This Code of Business Ethics and Conduct (the “Code”) is built upon the Nera Group policies that are available to all Nerators through the Nera Group Legal & Compliance intranet. It sets out the standards that the Nera Group expects of our employees in upholding its values and commitment to conduct business ethically, and all Nerators are expected to comply.
Nerators, regardless of their position or location within the Nera Group, are expected to comply with this Code and the Nera Group policies. We also expect all third parties, such as our customers, suppliers, vendors, partners and contractors, to act in a manner that upholds the principles of this Code when conducting business with the Nera Group.
The Nera Group complies with all applicable laws and regulations. We commit to be familiar with, and comply with our duties and responsibilities, in respect of all applicable laws and regulations in the jurisdictions which the Nera Group operates in. This includes all applicable laws of certain jurisdictions that extend beyond national geographical borders, which may apply even if the relevant act or omission takes place overseas.
We strictly prohibit any and all forms of retaliation against any Nerator who has in good faith reported, or who is assisting in good faith in any investigation or process in relation to, a violation or suspected violation of the law, this Code or other corporate policies and procedures.
4. Our Commitment
Through our Nera Group policies, this Code sets out the principles of ethical business conduct through the following fundamental areas:
Anti-Bribery and Corruption
The Nera Group prohibits any form of bribery or corruption, including the giving or receiving of gifts, entertainment, or facilitation payments intended to gain an unfair business advantage. When dealing with third parties, we avoid any conflict of interest and are vigilant about the integrity of those parties. We must disclose any potential conflicts of interest, as well as any gifts and entertainment, and comply with the Nera Group procedures on declarations and approvals. Should any suspicions of bribery or corruption arise, we must report them immediately.
Anti-Trust
The Nera Group emphasises on the importance of fairness and integrity in conducting its business, and adheres to applicable competition laws and regulations. We do not engage in any anti-competitive behaviours such as information sharing, bid-rigging, price-fixing and market-sharing.
Data Protection and Privacy
All Nerators play an important role in ensuring the protection of personal data. We are committed to safeguard personal data through compliance with applicable data protection and privacy laws. In the collection of personal data, we ensure the individuals are notified of the purposes for which their personal data is collected, used and disclosed, and ensure that their consent is obtained for such purpose. We protect the individuals’ personal data through accuracy checks, security measures and limitations on data retention and transfer. More specific details are set out in our privacy policy available on our Nera Group website.
Insider Trading
As a listed company on the Singapore Stock Exchange, we are committed to prevent insider trading through guidance to Nerators on the buying and selling of NeraTel’s securities on the Singapore Stock Exchange. We observe restrictions from trading during specific periods prior to financial announcements and advise Nerators against short-term trading. We adopt best practices to prevent insider trading, including the importance of maintaining confidentiality and limiting access to information on a need-to-know basis.
Mutual Respect
Nerators are our most important assets. We require all Nerators to treat others with respect and fairness, regardless of their background or position. We are an equal opportunity employer and conduct our business free from discrimination, harassment or any form of unfair treatment in the workplace.
Information Technology and Security
At Nera Group, we recognise the importance of using technology tools, as well as electronic media and services responsibly. Our Nera Group policies emphasises the need to ensure and maintain the confidentiality, integrity and availability of information assets as well as personal data. We constantly review our security measures and standards to ensure our information assets and personal data are protected.
Compliance with Trade Laws
The Nera Group complies with all international and regional trade laws and regulations, and we do not engage in any form of illegal trade practices. In our conduct of international trade, we observe all export controls laws and sanction laws. We do not engage in any activities involving sanctioned individuals, companies, countries or territories.
Health, Safety and Environment
The health and safety of Nerators are one of our top concerns. We take steps to ensure that the work environment is safe and healthy for all Nerators. We protect Nerators through compliance with health and safety regulations and conduct risk assessments before carrying out works. We are committed to carry out our business sustainably and reduce our carbon footprint.
5. How We Uphold Our Commitment
All Nerators, including our senior management, receive regular training on the Code and Nera Group policies to ensure a deep understanding of our ethical standards. The Code and all Nera Group policies are made available to Nerators for reference and guidance from time to time.
At Nera Group, we remain vigilant and alert to any possible violations of the Code, Nera Group policies and applicable laws and regulations, and will promptly report any suspected violations. Our Whistle-Blowing Policy can be accessed on our Nera Group website, providing an appropriate channel for Nerators and external stakeholders to report violations, while ensuring confidentiality of and protection for those who report concerns.
We believe that all Nerators must be held accountable for their actions and omissions. Our Nera Group policies outlines the disciplinary actions that Nerators may be subject to when they act in contrary to the Code, our Nera Group policies, and applicable laws and regulations. We take any acts of violations seriously and will not hesitate to undertake these disciplinary actions against Nerators who are found to be in violation thereof.
We continuously assess and update our policies to align with evolving legal requirements and best practices in ethical corporate conduct.
5. Conclusion
Our Code is a testament to our commitment to ethical business practices. At Nera Group, we believe that by adhering to this Code, we not only fulfil our legal obligations but also contribute to a better business environment for our stakeholders and the communities we serve.
Thank you for partnering with us in maintaining a culture of integrity and trust.
For any inquiries or to report a concern related to our Code, please contact us through the provided channels on our website.
Last Updated: February 2025