Corporate Citizenship and Sustainable Business Practices

Focus Area #3

Good governance and ethical business practices are the foundation for all of Bittium’s activities. The company’s businesses are subject to strict regulation. Trust is one of Bittium’s values and a cornerstone of the company’s DNA. Our customers can count on us to respect the confidentiality of our customer relationships. For its broad network of partners and stakeholders, Bittium wants to be a partner with which dialog is easy and solution-oriented.

At Bittium, sustainable corporate citizenship means that sustainable business practices are strengthened throughout the value chain, with positive impact created in society at both the local and global level.

Bittium is a reliable local partner and employer, which engages in active and open dialogue with its stakeholders, acts in accordance with its harmonized operating principles, creates added value for its shareholders, and seeks working methods and solutions that promote sustainable development. Bittium develops its stakeholder relationships in a fair and sustainable manner, with the aim of being transparent in all its communication.

Bittium participated in several research and development projects in 2023. The most significant of these was Seamless and Secure Connectivity, which is a Leading Company project funded by Business Finland. The four-year project led by Bittium will last until 2026. Its goal is to enable trustworthy, secure, and resilient end-to-end connectivity architectures and products including life-cycle services in various domains.

Since 2023, Bittium has been a Board member of ITEA, which is part of the EU’s EUREKA framework. The ITEA cluster has an industry-driven focus on software RD&I, particularly in the areas of smart mobility, health care, smart cities, energy, manufacturing, engineering, safety, and information security.

In March 2023, Bittium deployed a whistleblowing channel that satisfies the requirements of the Whistleblowing Directive. The company has specific processes for monitoring and handling whistleblower reports to ensure that they are investigated quickly and confidentially, protecting the identity of the whistleblower. No reports were received via the whistleblowing channel during the year.

Objectives and Their Achievements in 2023

In 2023, the key perspectives in the focus area of Corporate Citizenship and Sustainable Business Practices were reducing the risk of unethical conduct, supply chain sustainability, anti-corruption and the development of stakeholder cooperation.

Bittium published its new strategy in the latter half of 2023. Consequently, the decision was made to postpone the updating of the Code of Conduct to 2024, at which time all of the company’s policies will be reviewed in relation to the new business model. The existing Code of Conduct is used in contract negotiations with manufacturing partners and component suppliers.

The company’s new employees are familiarized with the Code of Conduct during their first month with the company (target: 100%). Self-study materials on the Code of Conduct will be updated when the Code of Conduct itself is updated in 2024.

The company’s anti-corruption training package was updated in 2023 and will be deployed in 2024.

Preparations were made for the implementation of a stakeholder survey in 2023, but the decision was made to conduct the survey in 2024 as part of Bittium’s double materiality analysis. Stakeholder cooperation measures are described in more detail below.

Developing Stakeholder Cooperation

Bittium’s operations affect multiple stakeholders, with the company’s key stakeholders being shareholders, customers, employees, partners and other suppliers as well as the public sector. Developing even more open dialog between stakeholders supports the development of Bittium’s operations, products and solutions, while it helps find solutions for societal challenges. In the fall of 2023, Bittium organized a Capital Markets Day targeted at investors and analysts. This coincided with the publication of the company’s new strategy and business model. Approximately 40 people attended the event in person, with another 374 in attendance online. The recording of the event had been viewed 786 times by the end of 2023.

Bittium organized a Partner Days event for its partners in the Medical business segment. At the event, Bittium launched a partner program aimed at increasing and strengthening dialog with partners and engaging the commitment of partners so that they are even more integrated into Bittium’s product distribution chain. The next Partner Days event will be organized in early 2024 in the Defense & Security business segment.

From the perspective of Bittium’s customers, export control constitutes an important part of operations and a precondition for successful cooperation with the authorities as well as customers. Bittium promotes the sustainable export of Finnish technology by closely monitoring the changing legislation in the various market areas and by complying with legal provisions. The changed geopolitical situation has increased the number of export license applications filed by Bittium. Export control procedures have been further specified in cooperation with the authorities.

After the COVID-19 pandemic, Bittium has been able to resume visits to educational institutions, which are important to the company. The visits support the work of schools and educational institutions and future competence development.

Compliance with Requirements, Good Governance and Anti-corruption Measures

Bittium has customers in both the public and the private sector. The business environment involves constant changes in legislation and regulation, as well as increasing requirements from the stakeholders concerning sustainable operations and risk management. Bittium is committed to acting in accordance with legislation and regulations and adhering to ethical business practices in all its operations. Bittium has zero tolerance of bribery and corruption. The company aims to ensure ethical business practices and compliance with the corporate culture and increase awareness of sustainable business practices through training. Bittium’s corporate culture is based on openness and commitment to common values.

The management of Bittium Corporation is governed by the Articles of Association, Finnish law, and Bittium’s governance guidelines. Bittium publishes on an annual basis a corporate governance statement, as required by the Corporate Governance Code for listed companies published by the Securities Market Association. The statements and further information on the company’s governance are available on Bittium’s website.

The key objectives and requirements related to sustainable business practices, good governance, internal control, and risk management are specified in the operating principles and the Internal Control Framework, which includes instructions, guidelines, and principles for internal control and risk management, which are separately approved by the Board of Directors. Compliance processes are in place at every organization level in order to ensure compliance with the applicable laws, regulations, internal guidelines, ethical values, and sustainable business practices. The company’s management and businesses are responsible for monitoring the legislation and other regulation in their own areas and for communicating any changes to the organization. The members of the Management Group are responsible for arranging appropriate control and compliance training in their units. The company’s Chief Legal Officer coordinates the compliance processes in terms of adequacy and compliance.

Bittium expects that its employees and partners are committed to the company’s anti-corruption policy. Mandatory training on anti-corruption measures is provided for employees as part of the orientation training, with all new employees completing the related online self-study module in 2023. No irregularities were observed and no corruption cases were confirmed during the year.

Sustainable Purchasing

Bittium’s products contain a range of electronic, electromechanical and mechanical components. The sustainability of the purchasing chain is ensured, for instance, through material and component supplier requirements and material assessments.

The company’s service and product suppliers are required to undertake to ensure sustainable business practices and they must comply with Bittium’s Code of Conduct, Supplier Code of Conduct, and the Bittium Supplier Manual. The latest versions of these documents are available on Bittium’s website. The guidelines include the key policies, practices, and requirements for Bittium’s supply chain. The requirements are related, among other things, to business practices, anti-corruption measures, environmental issues, occupational safety, and human rights, including material-specific requirements. Compliance with the guidelines was assessed in 2022 through supplier self-evaluation and audits of critical suppliers.

Ensuring that all employees are committed to the principles of sustainable purchasing is an important part of ensuring the sustainability of the supply chain. Sustainable purchasing is a part of Bittium’s mandatory environmental training, which employees complete through self-study.

The vast majority of Bittium’s employees work in countries with progressive human rights legislation. The company’s approach to human rights issues is described in the Bittium Supplier Manual. During the year, no violations or significant nonconformities related to the use of child labor, forced labor, inappropriate disciplinary action, physical punishment, or health-related discriminatory practices were observed in Bittium’s or its subcontractors’ operations.

Suppliers are audited according to pre-defined criteria. Audits are carried out either as a self-assessment based on the Bittium Supplier Manual or as an audit conducted by Bittium. In 2023, Bittium focused on deepening its cooperation with critical manufacturing partners and component suppliers to identify common development areas. Bittium has worked on developing a supplier management tool in connection with these efforts.

Identifying the Origin of Minerals

Bittium’s products are made using minerals that may also come from countries that violate human rights or cause environmental destruction by mining such minerals. Bittium urges its suppliers to comply with the legislation on conflict minerals and the relevant recommended reporting practices. This ensures that the minerals used in Bittium’s products do not originate from conflict or risk zones.

Bittium continuously monitors any nonconformities related to conflict minerals with the help of updated requirements, external databases, and the product information management system. The company has also further specified its Responsible Minerals Policy. In 2023, Bittium did not receive any reports on suspicions concerning minerals from conflict areas.

Avoiding Counterfeit Materials

Counterfeit materials are any materials whose origin, age, composition, configuration, certification data, certification status or other feature is presented falsely and with misleading markings on the material, packaging, or container. Bittium is aware of the risks associated with counterfeit materials, both when purchasing materials as ready-to-use components and when using the previously mentioned raw materials. Bittium is committed to conducting the necessary assessments to avoid using counterfeit materials in its products. The purpose of efficient supplier reporting systems is to avoid the use of counterfeit materials. Supplier reporting methods focus on monitoring the various purchase process phases starting from the initial supplier selection. Bittium’s employees are trained to identify counterfeit materials. Regarding counterfeit materials, Bittium’s customers also expect that information is managed in real time to the maximum extent possible. By combining the data obtained through product information management and material information databases, Bittium is able to ensure for its customers up-to-date and appropriate information management. The relevant information is documented in the Product Lifecycle Management (PLM) system. No counterfeit materials were found in Bittium’s products in 2023.

Relevant Sustainable Development Goals by the UN

Bittium’s actions related to sustainable corporate citizenship, good governance, and anti-corruption measures promote, in particular, the sustainable development goals no. 8 (economic growth and employment), no. 12 (responsible consumption), no. 16 (peace and justice) and no. 17 (partnership). Sustainable purchasing, avoiding minerals from conflict areas, and counterfeit materials support goal no. 8 (economic growth and employment). Reporting on the planning, implementation, and results of sustainability actions in the annual sustainability report and the systematic planning of sustainability work and reliable reporting support the objective to ensure the sustainability of consumption and production methods.