Code of Conduct

Adopted 2025-10-23

For NPG it is important that the activities within the association are conducted in a way that clearly remains within the framework of competition law. The purpose of competition law is to stimulate free competition, which NPG fully supports. NPG has therefore in October 2025
has adopted the following code of conduct, previously the code of conduct adopted by Teknikföretagens Branschgrupper AB has been followed.

NPG shall observe the code and ensure that it is followed by members affiliated with NPG within the association's activities.

The Code of Conduct aims to provide clear rules for NPG and its members. Violations of the Code may result in NPG terminating the cooperation with the member concerned with immediate effect. Another consequence is that NPG and its member companies, at the initiative of the Swedish Competition Authority, may be ordered by the court to pay a so-called competition fine. Such a fine may amount to exceptionally high amounts.

The following rules must always be observed within NPG within the association's activities:

Basic working method

• Meetings with boards, committees, working groups and other collaborative bodies may only take place after the participants have been invited in writing. An email also counts as a written invitation. The invitation to the meeting must include an agenda.
• Minutes shall be taken of each meeting referred to in paragraph 1 above. The minutes shall be sent to all members of the forum concerned. They shall be kept in an organised manner for at least 10 years.
• Consultations and discussions within a board, committee, working group or other collaborative body shall, if the topics are market-related, be limited to the official meeting at which minutes are kept.
• During consultations, as referred to in paragraph 3 above, the participants may not agree that a particular topic will be discussed during the meeting without minutes being taken. In such cases, the chairman of the meeting shall stop further discussion.
• At every meeting of a board, committee, working group or other collaborative body during which market-related topics are discussed, at least one representative/official from NPG shall participate. This representative/official shall be alert to topics that are sensitive from the point of view of competition law. If there is any doubt, the topic may not be discussed until an expert in competition law has been consulted and his/her advice indicates that the topic can be discussed without problems or that the framework for the discussion has been clarified.

A. Prohibited substances

The following topics are prohibited at meetings of boards, committees, working groups and other collaborative bodies affiliated with NPG, especially if information exchange on these topics takes place between companies that are competitors:

• Sales prices, tariffs, (planned) price adjustments, recommended prices, discounts, price increases and other price-related topics regarding the products or services of the member companies;
• Market segmentation, for example by allocating a specific geographical area, specific customers or specific groups of customers to specific member companies;
• Restrictions on production or sales;
• Consultation in advance regarding responses to requests for quotations from potential customers.
• Exchange of market information concerning individual member companies, i.e. information on production, turnover, sales, investments, divestments, R&D costs and other information insofar as it is related to specific products or services or categories thereof and may be considered commercially sensitive;
• Publication of average prices or price ranges within the industry;
• Exclusivity for specific member companies to represent producers and importers;
• Boycott of specific suppliers or customers;
• Other topics that may lead to anti-competitive coordination of the market behavior of member companies;
• Prior consultation between competitors regarding responses to requests for tenders, whether from a public or private buyer;
• Agreements between all competitors to add a fee to the bids to compensate the companies that do not win the bidding competition for their bidding costs.

B. Substances that may pose a problem

The following topics may, under certain circumstances, pose a competition law problem, particularly in a highly concentrated, oligopolistic market, i.e. a market with few players. The topics may therefore only be discussed after consultation with a competition law expert:

• General delivery provisions. If the provisions relate to sensitive competition parameters such as prices, tariffs, methods of indexing, charges for specific costs, or if the use of the provisions is mandatory, the competition authorities may object;
• Restrictions on participation in trade fairs. In general, all companies should be free to participate in any trade fairs they wish and companies may not be asked to boycott trade fairs. Restrictions on the freedom to participate are only permitted under specific conditions. The fact that member companies negotiate jointly to obtain better prices or other conditions from a trade fair organisation does not constitute a competition law problem;
• Special requirements for membership in a trade association. As long as the supplier's membership does not play a decisive role for potential customers in their choice of products and services, it is unobjectionable under competition law. However, as soon as customers consider such membership to be significant, the requirements for membership in the trade association must meet objective criteria;
• It is in principle permissible for the NPG to collect commercial information about individual companies and make this information available to member companies in aggregated form. Under no circumstances should it be possible to extract information about individual companies from the aggregated information. The national competition authorities in some EU countries only allow such statistical systems if the information collected is sufficiently old, e.g. includes data that is at least one year old, and/or if the information has been made publicly available.

C. Substances that do not pose a problem

The following topics are largely core business for NPG. Discussions and consultations on these topics do not normally pose any problems under competition law, provided that topics listed under point A. above are not affected:

• General cyclical economic data and business climate data, provided that discussions on these topics do not relate to the actions of any individual company. Discussions on these topics focus on the macro level and do not affect the market behavior of individual companies.
• Lobbying activities relating to common interests within the industry and which concentrate on legislation and other general issues that may affect the industry;
• Labor law and social issues. These issues are not affected by competition law.
• Legal issues. These issues are by definition of a general nature, as they affect all companies' business to the same extent;
• Standardization issues, if (I) the standardization process is transparent and open to all parties who wish to participate, (II) there is no compulsion to comply with the standard, (III) access to the standard is provided on fair, reasonable and non-discriminatory terms and conditions and (IV) discussions in connection with the standardization process are limited to technical aspects. Standardization aims at product compatibility and technological development which will normally be to the benefit of the end user;
• Safety and health issues. NPG has an interest in promoting safety and health with respect to the industry's products;
• Environmental issues. NPG has an interest in promoting environmental considerations in the use of the industry's products.

Application of the Code and Rules of Conduct

Doubts may sometimes arise as to whether a procedure, particularly those referred to under b) above, is compatible with the Competition Act's prohibition of anti-competitive agreements and concerted practices. The question that should then be asked is what purpose the act has and what effects it has. The procedure is prohibited if the purpose is anti-competitive. The same applies if the effect of the procedure is anti-competitive even if the procedure does not have that purpose. An anti-competitive effect exists if the independent conduct of the undertakings concerned on the market is jeopardised.

If it is not obvious, based on the above criteria, that the procedure is legal, the person responsible for the activity should stop the ongoing activity and seek advice from competition law experts.