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 RI&O Policy

• Modern Slavery Act Statement

• EQT Global Health and Safety Guidelines

• EQT Anti-Bribery & Corruption Guidelines

• General Privacy Notice

• Motherbrain Privacy Notice

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 the ecosystem and to participate in the public discourse, EQT is an active participant in industry associations, working groups, and other initiatives. For more information on current partnerships aiming to support the wider society including local communities, and to inspire change in the broader industry, please click here. EQT's contribution to trade associations and other partnerships was EUR 220,081 in 2021 (2020: EUR 228,500, 2019: EUR 145,752, 2018: EUR 216,416). The contributions were primarily in the form of membership fees and dedicated studies. In addition, EQT provided EUR 98,752 in charitable donations to the Stockholm School of Economics in 2021.

EQT did not directly contribute to any local political campaigns or candidates, lobbying or interest representation, or any spending related to ballot measures or referendums between 2018 and 2021.

Disclaimer: Please note that the data above does not cover contributions and spending by any EQT Exeter entities. 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.

• Diversity and No-Harassment Guidelines

• Tax Guidelines

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