Ethical Business Policy

1   Introduction

Inertial Sensing, including any affiliates and subsidiaries, values honesty, transparency, integrity, and professionalism in dealings with suppliers, competitors, clients, government officials, and all other parties it is involved in business dealings with.

This policy applies to all employees, officers, directors, and independent contractors of the company worldwide. This document gives specific details on Inertial Sensing’s policy prohibiting corruption in the performance of business operations and individual employee responsibilities for ensuring adherence to the Policy. 

The goal is to inform all interested parties of their obligations within an ethically operated business and to ensure compliance by employees with the company's policy. It also provides information on how to identify potential risks, deal with challenging situations, and report when those situations violate or may lead to a violation of this policy.

Questions about the policy or its applicability to circumstances should be directed to the Compliance Manager, denoted at the end of this document.

2   Compliance with regulations

Inertial Sensing’s policy is to engage in business practices in full compliance with the relevant laws and regulations of Sweden, together with all other regulations in foreign jurisdictions relevant to:

  • corruption,
  • human rights,
  • workers’ rights,
  • environmental sustainability,
  • health and safety,
  • sanctions.

Employees are expected to adhere to both the spirit and the letter of this policy concerning all aspects of the company’s business anywhere in the world. It is the responsibility of employees to be aware of how each situation may violate or lead to a violation of this policy and anti-corruption laws.

2.1    Corruption

Inertial Sensing has zero tolerance for any corruption in business activities. Bribes or other improper or unauthorized payments that directly or indirectly make, offer, or promise to make, kickbacks, benefits, or advantages to any person, individual, organization, or entity, are prohibited by this policy. A violation of this policy can occur even if a bribe or other corrupt practice fails to achieve its desired outcome.

2.2  Human rights

Inertial Sensing has zero tolerance for doing business with companies or individuals who are engaged in, or profit from, abuses of human rights in any form. The company is committed to respecting human rights and ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

2.3  Workers’ rights

Inertial Sensing respects the laws and regulations of the countries in which it does business, either directly or indirectly. The company is committed to respecting the rights of workers as governed by all local regulations and expects the same from its business network.

2.4  Environmental sustainability

It is the policy of Inertial Sensing to seek continual improvement throughout our business operations to lessen our impact on the local and global environment by conserving energy, water, and other natural resources, reducing waste generation, recycling and reducing our use of toxic materials.

2.5  Health and safety

In accordance with human and workers’ rights, Inertial Sensing expects that no part of its supply chain or its distribution network encourages or permits the violations of health and safety regulations in the workplace. Neither does the company tolerate practices that jeopardize the health and safety of the public in an area of business.

2.6  Sanctions

Inertial Sensing is committed to regularly monitor and comply with Swedish government, EU, and other relevant regulations. It is the duty of the Business Manager and the Compliance Manager to follow up on regulations in general as well as export regulations in particular. Due to the dynamic nature of sanctions in force at any given time, the reader is referred to the separate export policy document, “Inertial Sensing Export Policy”.

3   Compliance procedures

Various tools are available to assist in fulfilling the obligations that Inertial Sensing has both legally and due to its own values.

The primary objective is to prevent any unethical practise occurring in the first place, whether at Inertial Sensing or somewhere in its supply chain and/or distribution network.

The secondary objective is to swiftly deal with any situations that do arise despite the best efforts of the company, and to prevent further similar occurrences.

In all cases, proper due diligence by Inertial Sensing is the most powerful course of action when assessing a new supplier, distributor, agent, or customer.

Internal oversight is to be actively encouraged of all employees and is required of senior management.

External oversight is provided by bookkeeping and auditing functions, in addition to consultation with Inertial Sensing’s banking service provider prior to engaging a new distributor or direct customer, or expansion into a new region of the world.

The possibility of engaging an external service dedicated to conducting 3rd party due diligence is to be kept in mind, although not planned to be used at this time. 

3.1  External bookkeeping

The Swedish Bookkeeping Law (Bokföringslag, 1999:1078) specifies the bookkeeper’s obligation to follow good account practices and adhere to regulations regarding reporting of corrupt practises. To this end, Inertial Sensing’s financial bookkeeping function is performed by an external agent.

3.2  External audit

The Swedish Companies Act (Aktiebolagslag, 2005:551) contains various regulations relevant to corruption issues. This includes the regulations on the responsibility of an auditor to undertake certain actions if suspicion of corruption arises. To this end, Inertial Sensing’s financial reports are audited every year by an external auditor.

3.3  Suppliers

Inertial Sensing is committed to only using products and services from suppliers that have a commitment to:

  • upholding human rights,
  • upholding workers’ rights,
  • sourced responsibly with respect to health & environmental protection,
  • are not involved in any transactions involving bribery, money laundering, tax evasion or other forms of corruption,
  • are not involved in sanction breaking or circumvention.

Inertial Sensing uses a limited range of reliable suppliers in the conduct of its manufacturing activities, research and development activities, marketing, administration, and other activities of business.

Whenever possible, suppliers located within Sweden are preferred. Where a Swedish supplier is not available only suppliers from the following countries are to be used:

  • EU / EES
  • USA
  • Canada
  • Australia
  • New Zealand

Irrespective of the location of the supplier, Inertial Sensing restricts business to only well-established companies with a clear public record or to those companies with which a personal relationship has been established with owners and management, ensuring confidence in the quality and ethical responsibility of the supply chain. Any change to the practice or values of a supplier will lead to a reassessment of the business relationship and potential termination of the relationship.

3.4  Distributors, agents, and customers

Inertial Sensing places an extremely high value on ensuring that its products and services are part of an ethically responsible supply chain, meaning that goods and services:

  • are not involved in any transactions involving bribery, money laundering, tax evasion or other forms of corruption,
  • are not ultimately supplied to customers or countries under sanction restrictions,
    are delivered with as much information as possible about the final customer available to Inertial Sensing,
  • are not sold to entities with questionable records on:
    • human rights abuses,
    • workers’ rights abuses,
    • causing health & environmental problems,
    • ethical business practices.

Inertial Sensing primarily sells its products and services through a global network of agents and distributors. A very high emphasis is placed on establishing a personal relationship with these entities to the highest level possible within each organization. Typically, this is with the owner of the company. This helps to ensure confidence in the ethical nature of the business conducted by the agent. In addition to this, all new distributors and agents are vetted so that Inertial Sensing has knowledge of:

  • the beneficial owners of the relevant company or group of companies,
  • the senior management in the company,
  • the PEP (politically exposed person) status of these owners and managers,
  • the sanction status of the company, group of companies, owners and managers.

In the few cases where a business transaction is conducted directly with a customer outside the distributor network, the customer is assessed as much as possible with regards to all aspects of ethical practices. Most often the customer will be a company that is listed on a public stock exchange in some region, with published business practice information. In the cases of privately owned companies, the final use and nature of business is most often clear (e.g. a large independent drilling company).

In the case of suspected corrupt or unethical practices by a distributor or agent of Inertial Sensing coming to the attention of Inertial Sensing management, an immediate investigation will be conducted to ascertain the nature and scope of the issue. Remedial action up to and including termination of distribution contracts may be applicable, after appropriate legal counsel has been sought.

In the case of suspected corrupt or unethical practices by an end user of Inertial Sensing products coming to the attention of Inertial Sensing management, an immediate investigation will be conducted to ascertain the nature and scope of the issue. Remedial action may be taken as appropriate, for instance termination of SurveySafe cloud accounts, suspension of service agreements and so forth, after appropriate legal counsel has been sought.

4   Gifts

Gifts are commonly offered as gestures of gratitude or tokens of appreciation, but in some situations, they can also be construed as bribes. Inertial Sensing does allow gifts made in good faith, but they must comply with this Policy.

Employees must ensure that any gifts are of value in proportion to the situation at hand, and any gifts should be infrequent to avoid being perceived as an attempt to influence an act or a decision. When offering or accepting a gift, employees should specifically consider the following:

The intended outcome: Gifts can have many purposes, such as expressing appreciation and building a relationship, but they can also be viewed as an attempt to influence a direct result, e.g., to win a bid or affect the negotiation process. 

The Company's reputation: The gift may be a private act, but if it were to come to the public's attention, employees should consider how it would affect the reputation of Inertial Sensing. 

Competition: A general rule of thumb is to think about how Inertial Sensing would perceive a similar gift made by a competitor.

5   Awareness

All employees must be informed of the existence of this policy.

If the policy is revised this will be announced in a company meeting.

A printed copy of the latest version of this document can always be found in a folder in Inertial Sensing’s staff room and on the Inertial Sensing intranet at:

PersonnelCompany PoliciesInertial Sensing Ethical Business Policy.pdf

Inertial Sensing’s employees are encouraged to ask questions.

6   Reporting

If an employee becomes aware of information where the employee suspects there is a risk of non-compliance with this policy, this should be reported directly to Inertial Sensing’s Compliance Manager who is then obliged to start an investigation and report to the board of the company.

If an employee feels uncomfortable reporting to Inertial Sensing’s Compliance Manager, the employee may report to another senior staff member, a member of the board, or to the company’s external auditor. Inertial Sensing’s employees are to be made aware through this document that they are protected in Sweden by the “whistleblowing law”:

 Lag (2021:890) om skydd för personer som rapporterar om missförhållanden

The Whistleblowing Act means that employees may not be prevented from, or punished for, reporting wrongdoings. Employees are covered by the Act even if they do not know for certain that the suspected wrongdoing is illegal.

7   Disciplinary Action

If an employee should fail to comply with this policy or relevant laws, they will be subject to disciplinary action up to and including termination of employment or other relationship with the company. Restitution could also be required, and civil or criminal action against individual employee could be warranted.

8   Policy review

This policy should be reviewed at least annually. If new regulations are published, this policy must be reviewed accordingly.

9   Accessibility and responsibilites

The latest version of this document is stored in Inertial Sensing intranet under: 

ManagementCompany PoliciesInertial Sensing Ethical Business Policy.docx

Below is a list of people responsible for policy compliance at Inertial Sensing.

| Responsibility | Staff member
| Supplier relations | Dag Billger
| Distributor & sales contracts | Dag Billger
| Compliance Manager | Duncan McLeod

10   Resources

The following is a non-exhaustive list of resources used by Inertial Sensing in setting up and maintaining this policy:

  • Företagarna. Inertial Sensing is a member of Företagarna, Sweden’s largest network of companies. This organization advises, publishes material, and organizes information on, among other topics, anticorruption and other ethical practices.
  • Stockholm Chamber of Commerce. Publishes material and gives advice on topics including social responsibility.
  • International Chamber of Commerce. Publishes material relevant to small business practice, in particular anticorruption and third-party due diligence.
  • Swedish Government. Publishes laws and information governing Sweden.
  • Specially Designated Nationals and Blocked Persons List. Maintained by the Office of Foreign Assets Control of the U.S. (OFAC), Department of the Treasury
  • Entity List and Denied Persons List. Maintained by the Bureau of Industry and Security of the U.S. Department of Commerce (BIS)
  • List of statutorily or administratively debarred parties. Maintained by the Directorate of Defense Trade Controls of the U.S. Department of State
  • Consolidated list of persons, groups, and entities subject to EU financial sanctions
  • Consolidated United Nations Security Council Sanctions List. As amended from time to time.

11   Conclusion

Inertial Sensing is committed to legal compliance in all its business activities. This document was revised and approved on 9 March, 2024.


Duncan McLeod, Compliance Manager
Dag Billger, Business Manager

Inertial Sensing reserves the right to at any time update or change this policy, and you should regularly visit this website to obtain the latest version
Last updated: 2024-03-18