Getinge Policy

Communication Policy

Document ID: POL-0127 rev1

Adopted by the Board of Directors 16-JUL-2019

1. Summary

The objective of this Communication Policy is to contribute to a correct and long-term effective
exchange of information within Getinge and its employees and between the company and the
company’s external stakeholders. Communication in accordance with the Communication Policy
contributes to increased confidence in management, employees and owners and enhances
knowledge of the company’s profile, goals and objectives. It further ensures consistent
communication with the operating environment in accordance with the company’s strategies.
Information within Getinge is ultimately intended to support the company’s vision, mission and
strategies. In addition it should strengthen Getinge’s reputation and brand and counteract the risk
of a decline in trust.

Getinge’s Communication Policy has been established by the Board of Directors in accordance
with applicable listing requirements with a view to meet legal requirements and to comply with
applicable stock market regulations.

2. Scope and Objective

This Policy is valid for all Getinge companies, its subsidiaries and joint operations (jointly “Getinge”)
and applies to all employees, as well as consultants and agency personnel who work at Getinge
premises or under the direction of Getinge (all referred to in this policy as “employees”).

This Policy provides an overview of Getinge’s principles covering both external and internal
communication to make sure it is performed in a coordinated, efficient and professional manner. In
order to support the organization internally in communication, two supporting directives have been
developed as part of this overall Communication Policy. Also, matters of inside information are
addressed by Getinge’s Insider Policy.

All employees and members of the Board are expected to follow this Policy as well as applicable
directives in all communication, internally and externally.

Print-outs and copies of this document have to be checked for validity and correctness before use.

Template: Page 1 of 6
SOP-1102-D rev2
 POL-0127 – Communication Policy rev1

3. Principles
The Communication Policy applies to all written statements in annual reports, interim reports, press
releases, letters to shareholders or employees, statements from management, information on the
Company’s digital communication platforms, information in public registers and other content in
both external and internal communications.

The policy also covers all verbal statements at group or individual meetings with analysts and
investors, telephone conversations with analysts and investors, speeches by company
management, interviews with the media and at press conferences, and all other external or internal
communications and statements that are to be executed.

In all situations where any form of communication is to take place, regardless of whether it is
through written or oral communication and regardless of choice of medium and recipient, it must be
considered how the communication affects the company as a whole. All persons must in each
situation evaluate the impact and consequences of the communication. When handling inside
information, each person has an independent responsibility to ensure that they comply with
relevant rules and requirements.

The guiding principles for Getinge’s communications are to:

• Communicate in an open, reliable, well-structured and transparent way, both internally and
externally;

• Treat all stock market stakeholders equally;

• Disseminate all inside information timely and accurately;

• Fulfil legal requirements and comply with applicable stock market regulations;

• Uphold a high level of ethics;

• Ensure the reliability of information by maintaining specific communication channels and

procedures;

• Ensure a consistent and aligned communication to protect and promote our company
image and business in a proper and consistent manner.

4. Responsibility and spokespersons

External communication

The Board of Directors is ultimately responsible for Getinge’s strategy and organization and shall
ultimately monitor the administration of and compliance with the Communication Policy.

The Chairman of the Board is the Board’s spokesperson and responsible for issuing statements
to Getinge’s external stakeholders on ownership issues and owner relations. The Chairman of the

Print-outs and copies of this document have to be checked for validity and correctness before use.

Template: Page 2 of 6
SOP-1102-D rev2
POL-0127 – Communication Policy rev1

Board may also issue statements on issues related to the company’s business. Other Board
members must refer such matters to the Chairman of the Board or the President & CEO.

The President & CEO is ultimately responsible for all matters of communication. The President &
CEO has ultimate responsibility for contacts with the media and is the primary spokesperson for all
issues concerning the company as a whole. The President & CEO may delegate the role of
spokesperson as well as strategic and operational implementation of communication activities to
other employees. In the first instance such delegation is to the Executive Vice President
Communication & Academy, who in turn can further delegate.

The Executive Vice President Communication & Academy leads the communications and is
responsible for planning and steering of all of Getinge’s communication.

Corporate Communications is responsible for planning, coordinating, steering and implementing

communication in accordance with this Communication Policy.

The Chief Financial Officer (CFO) is responsible for all information about and related to the
company’s financial position and results in press releases, financial reports and other information
material. The CFO is responsible for preparation of financial information in interim reports, financial
statements and annual reports. The CFO is responsible for remaining continuously up to date with
the legal and stock market requirements applicable to the company’s communications. The CFO
shall in cooperation with the President & CEO and the Executive Vice President Communication &
Academy, ensure that Getinge performs its communications obligations in accordance with the
applicable laws and stock market regulations, including the listing requirements and generally
accepted stock market practice. In so far as the CFO deems necessary, the CFO shall seek legal
advice to ensure such compliance.

None of the company’s employees are authorized to speak on behalf of Getinge regarding financial
and share-price sensitive matters, unless he or she has been appointed to do so by the President
& CEO or the CFO in relation to the financial position.

Other members of the Getinge Executive Team are responsible, in their respective areas, for
adapting and following the principles of the Communication Policy, as well as for ensuring that the
information used in the communication within their respective area is correct, relevant, clear and
not misleading.

Local matters
The spokesperson for local matters that are deemed to have the potential to become matters of
global interest shall make decision on such matters in consultation with the President & CEO, CFO
and/or the Executive Vice President Communication & Academy, as relevant.

Changes in local operations, such as divestments, a major order, a minor order that may lead to
major commitments and the penetration of new markets are examples of matters of global interest
in which the President & CEO, CFO and/or the Executive Vice President Communication &
Academy shall be the spokesperson.

Print-outs and copies of this document have to be checked for validity and correctness before use.

Template: Page 3 of 6
SOP-1102-D rev2
 POL-0127 – Communication Policy rev1

For local matters that are only deemed to be of local interest, the local President or appointed
spokesperson shall be the company’s spokesperson towards the local media.

Internal communication
Internal information is an integrated part of all managers’ overall responsibility. The managers
must adapt and communicate Getinge’s strategy and objectives. Furthermore, each manager is
responsible for informing employees of matters that affect their work and organizational function.

All employees are responsible for actively obtaining information about the company and their
function via the internal communication channels. Employees also have a responsibility to
communicate with their managers and colleagues and thereby keep themselves informed.

5. External communication
External communication relates to communication that is intended to reach one or more target
groups outside Getinge, such as the media (which is both a channel and a target group),
customers, existing and potential investors, the capital market, authorities and the general public.
The mission of Getinge’s external communication is to support the business in reaching its overall
objectives by developing and maintaining good relations with important stakeholders and by
increasing knowledge and awareness of the company and its operations.

All handling of inside information are encompassed by the specific rules set forth in Getinge’s
Insider Policy. In addition, the External Communication Directive contains certain routines for
disclosure of inside information. These routines constitutes a complement to, and are
subordinated, the rules on handling of inside information in the Insider Policy.

Only spokespersons appointed in section 4 have a mandate to make official statements on behalf
of Getinge and/or its subsidiaries and joint operations within the individually defined areas set forth
in the section.

See further: External Communication Directive DIR-0143 and Insider Policy POL-0123

6. Internal communication
The mission of internal communication is to support Getinge in realizing its objectives by providing
employees with information about Getinge’s objectives, strategy, operations, results as well as how
to realize these objectives. The internal communication is limited by the rules of disclosure of inside
information described in Getinge’s Insider Policy, which means that information constituting inside
information cannot be communicated freely internally.

Internal communication is directed primarily to Getinge’s employees. This audience can be divided
into two subgroups:

Print-outs and copies of this document have to be checked for validity and correctness before use.

Template: Page 4 of 6
SOP-1102-D rev2
 POL-0127 – Communication Policy rev1

 managers and/or other key employees;

 all employees

Considering the limitations stated by the rules of inside information, Getinge’s employees must
secure a continually open and interactive flow of information at and between each organizational
level, supported by adopted procedures and flexible and adequate channels.

See further: Internal Communication Directive DIR-0144

7. Breaches against the policy – Speak up

Do not hesitate to raise a concern. Any Getinge employee who suspects violations of this Policy is
expected to speak up and raise the issue to their line manager, Human Resourses, to the Ethics
and Compliance Office, or to use the Speak-Up Line. The Speak-Up Line is available on Getinge
internal and external webpages.

At Getinge, we do not accept any form of retaliation against someone who speaks up, expresses
concerns or opinions.

See further: Speak Up and Non Retaliation Instruction SOP-1305

8. Roles and Responsibilities

All Getinge employees are individually responsible for reading, understanding and complying with
this Policy. Each employee is responsible for acting in accordance with this Policy, every line
manager is responsible for making sure each team member has access to this Policy and related
Directives.

Violations against the Policy can lead to disciplinary action, up to and including termination.

9. Framework

This Policy is part of Getinge’s Governance Framework, which includes:

 Code of Conduct, Our Cultural Values, Strategic framework, Policies approved by the Board of
Directors, Directives approved by the President & CEO or direct reports to the President &
CEO as well as local instructions
 Decisions made by the President & CEO or otherwise under the Delegations of Authority as
approved by the President & CEO
 The Ethics and Compliance Office is responsible for ensuring that the latest version of this
Policy is published and available to all employees on the Getinge intranet.
 This Policy will be reviewed every other year or as needed.
 The original language of this Policy is English.

Print-outs and copies of this document have to be checked for validity and correctness before use.

Template: Page 5 of 6
SOP-1102-D rev2
 POL-0127 – Communication Policy rev1

10. Contacts
Lars Sandström
Chief Financial Officer
Email: [email protected] Phone: +46 10 335 00 03

Jeanette Hedén Carlsson

EVP Communication & Academy
Email: [email protected] Phone: +46 10 335 10 03

Useful links:
 Code of Conduct POL-0108
 Insider Policy POL-0123
 External Communication Directive DIR-0143
 Internal Communication Directive DIR0144

Print-outs and copies of this document have to be checked for validity and correctness before use.

Template: Page 6 of 6
SOP-1102-D rev2