Brunswick Real Estate’s (“Brunswick”) focus on real estate investment
management brings a significant impact on climate and individual lives, and
therefore also a great responsibility. One way or another, buildings make a
difference to us all. At Brunswick we try to make sure it is a positive one. But we
cannot stop there. We aim to make a positive impact by considering sound business
ethics as well as environmental, social and governance aspects throughout all our
operations.
Cooperation with other parties is the very nature of our business. We prioritize
working with consultants, suppliers, capital partners and other business partners
(collectively our “Business Partners”) who share our values and who have
processes in place to ensure compliance with this Code of Conduct, in their own
daily operations as well as in their supply chain.
This Code of Conduct (the “Code”) is built on the principles of UN Global Compact
and describes our ethical principles and business standards. The Code shall be
revised annually, and the latest version shall be posted on the corporate website.
Brunswick will take action if anyone violates the Code, laws or regulations.
Potential incidents related to unlawful activities are naturally subject to immediate
actions. When applicable, reports will be made to the relevant authorities.
This Code of Conduct have been approved by the Executive Committee on the 1 st
of December 2025.
This Code is not only a compliance tool, but also a guide to living Brunswick’s
values in everyday decisions. It reflects our voluntary alignment with internationally
recognized frameworks and our ambition to set a high standard in responsible real
estate investment management.
1. Purpose
This Code outlines the ethical principles and standards that govern the conduct of
Brunswick. The Code is designed to guide Brunswick’s own business practices. In
line with our commitment to responsible and sustainable business, we also expect
our Business Partners to act consistently with the principles of this Code, as set
out in the introduction. To support this expectation, the Code will be appended to
Brunswick’s supplier agreements. Brunswick is committed to high standards of
ethics, integrity, and sustainability in accordance with international best practices.
This Code is a foundational document for building a responsible and transparent
organization. It reflects our commitment to accountability, fair treatment, and
continuous improvement, and applies across all countries where Brunswick
operates. All employees and representatives of Brunswick are responsible for
understanding, adhering and promoting awareness of this Code.
This Code is supported by regular training, internal guidance and processes for
reporting concerns or breaches.
2. Laws, regulations and business ethics
Brunswick shall comply with applicable laws, regulations and standards, as well as
any collective agreements relevant to its business activities, wherever business is
conducted. Business activities are to be conducted in accordance with good
business practice and shall thus promote fair competition, maintain high ethical
standards, as well as hold all relevant permits, licenses, and registrations.
If any employees or representatives of Brunswick are uncertain about the legal or
ethical implications of any action, they are encouraged to consult with the General
Counsel or Compliance Officer.
3. Anti-Corruption, Bribery and Money laundering
Brunswick maintains a zero-tolerance toward all forms of corruption, bribery,
money laundering, and unlawful restriction of competition. Brunswick is committed
to preventing the use of its operations for money laundering or terrorist financing.
This includes verifying ownership structures, financial integrity, and any indications
of involvement in corrupt or illicit activities. Such measures are essential to ensure
that Brunswick only collaborates with entities that share our standards of ethical
conduct and legal compliance.
- No gifts, hospitality, or other benefits may be offered, promised, given, or
accepted if they could improperly influence business decisions or create the
appearance of undue influence. This includes cash, entertainment of
disproportionate value, or any form of personal favors given with the
expectation of a return. - Any gifts or hospitality must be modest, appropriate, and directly related to
legitimate business purposes. They must never compromise, or appear to
compromise, the integrity of Brunswick or its business partners. - Employees are required to report any suspected or attempted bribery,
corruption, or related misconduct to General Counsel or Compliance officer
immediately.
4. Conflicts of Interest
All employees and representatives of Brunswick are expected to always act in the
best interests of the company. A conflict of interest may arise when an individual’s
personal, professional or financial interests, or those of close family members or
associates, could improperly influence, or appear to influence, their judgment,
objectivity, or decision-making in the course of their duties.
Conflicts of interest can take many forms. Common examples include:
- Holding a financial interest in, or receiving benefits from, a supplier,
customer, competitor, or potential Business Partner. - Engaging in outside employment or business activities that interfere with
responsibilities at Brunswick. - Participating in decisions or negotiations involving close friends, family
members, or other related parties. - Accepting gifts or hospitality that could reasonably be seen as
compromising professional independence.
Employees and representatives should actively avoid both actual and perceived
conflicts of interest. Where a potential conflict is identified, or could reasonably be
expected to arise, individuals are strongly encouraged to seek guidance from the
General Counsel or Compliance Officer. Open and early dialogue ensures that
concerns are properly assessed and managed in a transparent and constructive
manner.
All disclosed or identified conflicts will be evaluated and handled in accordance
with Brunswick’s Conflict of Interest Policy, which may include mitigation
measures, mandatory disclosures, recusal from decision-making or formal
approvals prior to proceeding.
5. Human rights
Brunswick is committed to respecting internationally recognized human rights, in
line with the UN Declaration, UN Guiding Principles, and ILO Conventions. We are
dedicated to treating all employees and Business Partners with fairness, dignity,
and equal value, and we actively work to prevent discrimination, harassment, and
threats based on any legally protected status.
Equal treatment is ensured in recruitment, compensation, training, promotion, and
termination. Brunswick also has zero tolerance for child labor, complies with
minimum age requirements, and never assigns hazardous or unsafe work to
employees under 18.
6. Working environment
Brunswick is committed to a safe, inclusive, and innovative workplace where
individuals and teams can thrive. We provide healthy working conditions in line with
laws and standards, respect employees’ rights to association and collective
bargaining, and ensure that information on health, safety, and workplace rights is
clear and accessible.
Any accidents, near misses, or safety incidents must be reported without delay.
We also recognize the importance of mental well-being and promote a culture of
openness, balance, and support to help employees manage stress, maintain health,
and seek help when needed.
7. Environment and climate
Brunswick recognizes the scientific evidence stating that human activity since the
industrial revolution has been accelerating climate change, leading to e.g. extreme
weather, rising sea levels, reduced biodiversity and extinction of species. The UN
Sustainable Development Goals works as a framework for our ESG initiatives.
Brunswick supports the reduction targets stated in the Paris Agreement and will
continuously work to reduce its operational greenhouse gas emissions to
contribute to the efforts limiting the global temperature increase.
At its core, Brunswick’s business model is about partnering up and co -investing
with investors from all around the world to build independent investment platforms.
Every investment platform has its own strategy and goals, matching the nature of
the different investments.
8. Taxation
Brunswick supports the OECD Guidelines on responsible business conduct in
taxation and is committed to contributing to public finances through timely and
accurate tax payments. We comply with both the letter and the spirit of tax laws in
all jurisdictions, ensuring that our approach reflects the intent of legislation.
Brunswick provides authorities with complete and transparent information as
required, applies the arm’s length principle in transfer pricing, and integrates tax
governance and compliance into our overall risk management to address financial,
regulatory, and reputational risks.
9. Whistleblowing
Brunswick is committed to the highest standards of corporate governance. The
whistleblower service, available on the corporate website, allows employees and
Business Partners to report concerns with full anonymity. Reports may include
illegal activities, misconduct, violations of Brunswick’s principles and policies, or
ethical and moral concerns.
All complaints are investigated by an independent third party. Brunswick strictly
prohibits any form of retaliation against individuals who report in good faith and is
committed to protecting whistleblowers from negative consequences related to
their disclosure.
10. Information management
Confidential information or data concerning business activities or Business
Partners may only be used for the purpose intended. Employees are responsible for
protecting confidential information. This includes business plans, financial data,
personal information and intellectual property.
Information technology should be reliable and developed in accordance with
globally recognized ethical standards and comply with the General Data Protection
Regulation (GDPR) and other applicable regulations.
Brunswick shall proactively work against any type of misuse of insider information
and employees are therefore not allowed to trade in instruments in listed real estate
companies, nor engage in a business which could be seen as competitive to
Brunswick’s engagements.
Brunswick strives for open and honest communication with employees and
Business Partners. Knowledge sharing within Brunswick to improve our way of
working is encouraged, but confidential information may only be shared within
Brunswick on a need-to-know-basis.
11. Training
This Code is supported by regular training, internal guidance, and processes for
reporting concerns or breaches. All employees are required to complete training in
relation to this Code of Conduct to ensure a shared understanding of its principles.
The Code is reviewed annually and revised when necessary to reflect evolving
standards and expectations. Input from employees and Business Partners is
welcomed as part of Brunswick’s commitment to continuous improvement in
ethical conduct.
12. Additional supplier requirements
This Code applies to suppliers, contractors, and other third parties engaged directly
by Brunswick (“Suppliers”), who are expected to uphold these standards in their
own operations and supply chains. Brunswick reserves the right to verify a
Supplier’s compliance with this Code through audits, assessments, or other
appropriate means.
In case of non-compliance, Brunswick may require corrective action plans and
reserves the right to suspend or terminate business relationships if issues are not
adequately addressed. Brunswick encourages open dialogue with Suppliers to
improve practices, share knowledge, and foster innovation in sustainability, ethics,
and risk management.
Suppliers must promptly inform Brunswick if they become aware of any breach of
this Code within their operations or supply chain. Brunswick may request
documentation and other evidence from Suppliers to demonstrate compliance with
this Code.