EQT Policies & Statements

• Code of Ethics

• Conflicts of Interest Policy

• Finance Policy

• Governance Policy

• Information and Trading Policy

• Information Security and Data Privacy Policy

• EQT Responsible Investment & Ownership Policy

• Modern Slavery Act Statement

• EQT Global Workplace Health and Safety Guidelines

• EQT Anti-Bribery & Corruption Guidelines

• General Privacy Notice

• Motherbrain Privacy Notice

• EQT Diversity and No-Harassment Guidelines

• Tax Guidelines

• Business Partner Code of Conduct

• EQT Partners Limited - Remuneration Public Disclosure Statements

• EQT Exeter Advisors UK Limited - Remuneration Public Disclosure Statements

• Risk Management Guidelines

Anti-Bribery & Corruption
EQT is committed to complying with anti-corruption and bribery laws wherever it conducts business and never accepts the offering or receiving of bribes in any form. Political contributions, gifts, and business entertainment can also be considered forms of bribery and EQT has developed specific guidelines covering these types of activities. Whether a gift or business entertainment is acceptable or not may differ by country or specific situation. All gifts given to or offered by EQT employees must comply with the EQT Anti-Bribery and Corruption Guidelines and the formal approval processes set out therein. Finally, the EQT Anti-Bribery and Corruption Guidelines apply to all staff and are designed to prevent EQT from obtaining business from state and local government entities in the U.S. in return for political contributions or fundraising assistance.

To promote sustainability in our industry and to participate in the public discourse, EQT is an active participant in industry associations, working groups, and other initiatives. For more information about EQT’s strategic partnerships, please click here.

EQT's contribution to trade associations and other key partnerships was EUR 1,051K in 2023 (2022: 758K, 2021: EUR 220K, 2020: EUR 229K, 2019: EUR 146K). The contributions were primarily in the form of membership fees and dedicated studies. The three largest contributions during 2023 were made to the Nobel Prize Outreach, World Economic Forum and FCLT Global.

EQT does not make political contributions, whether to political parties, political organizations or election candidates. In line with this stand, no donations have been made from 2018 to this date to political parties, organizations or independent elections candidates and no political expenditure has incurred. Although EQT will not participate directly in party political activities, we may engage in policy debate on subjects of legitimate concern to EQT, its employees and the communities in which we operate.

Disclaimer: Please note that prior to 2022, the contributions data above does not cover spending incurred by EQT Exeter or BPEA EQT. Since EQT's contributions primarily consist of membership fees to industry associations, it is not possible to provide any detailed disclosure concerning specific lobbying initiatives.

Anti-Money Laundering
EQT is fully committed to preventing money laundering and terrorist financing, and complying with all applicable Anti-Money Laundering and Counter-Terrorist Financing laws when conducting business with all business relationships. To this end, EQT has developed an Anti-Money Laundering program consisting of policies, procedures, training, and controls designed to prevent and detect any risk of money laundering, terrorism financing, and related activities. To ensure proper oversight of anti-money-laundering-related matters, EQT has appointed Compliance Officers to oversee the client due diligence process and AML program.

EQT applies a risk-based approach to ensure appropriate controls and oversight to determine the extent of due diligence to be performed and the level of ongoing monitoring to be applied for customers onboarded both physically and digitally. Enhanced due diligence measures will be applied for clients involving high-risk jurisdictions or complex structures and relationships with politically exposed persons, correspondent banking relationships or targeted by other relevant high-risk factors. Relationships with politically exposed persons are made subject to dedicated monitoring and approval by senior management. EQT conducts daily and automated screening of clients and their relevant related parties (including ultimate beneficial owners) against:

• Sanctions lists published by the United Nations and the European Union as well as sanction authorities such as the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC).

• Politically Exposed Database to identify a politically exposed person.

All the data obtained according to client identification and anti-money laundering security measures is documented and records are kept for a minimum of five years.

Global Disciplinary Misconduct Framework

EQT has in place a Global Disciplinary Misconduct Framework whereby any type of actions or conduct that goes against EQT’s values, policies, guidelines and procedures are handled, e.g. covering employee misconduct in relation to fraud, financial and other crimes, legal and regulatory breaches, data breaches and employment practice misconduct. The framework is put in place to streamline and strengthen disciplinary processes making sure misconduct is properly escalated and ensuring consistency on how cases are assessed, treated, and closed globally through an internal team involving management, HR, inhouse employment lawyer and local compliance officer with the Audit Committee acting as a supervisory body.

Conduct that goes against EQT's core values, policies, guidelines and procedures is unacceptable and will lead to different forms of disciplinary action, including adverse impact on discretionary incentives, oral or written warning and/or immediate dismissal.

On a quarterly basis, all cases handled through the Globally Disciplinary Misconduct Framework will be reported to the Audit Committee.

Shareholder Rights Directive (Directive (EU) 2017/828) ("SRD II")
EQT Services (UK) Limited and EQT Fund Management S.a r.l. are currently assessing the impact of new rules driven by SRD II and, in particular, whether it is appropriate for them to develop, and publish, a shareholder engagement policy.

For information about the external whistleblowing channel, see here.

EQT's External Whistleblowing Instructions can be found here.