Code of Conduct

21st of August 2022

Background and purpose


a:gain is committed to making a change towards a more sustainable construction and real-estate industry. As a result of this commitment, a:gain subscribes to a set of corporate responsibility principles and guidelines, hereunder a code of conduct for business partners.

a:gain works closely with suppliers, production partners and other collaborators (business partners) to drive forward the important agenda of minimising the footprint from building materials and interiors. In doing so, a:gain seeks to make a positive contribution not only towards the environment, but also towards society. Furthermore, a:gain is committed to building a business based on good business practices.

a:gain works in compliance with internationally recognised minimum standards on human rights, including labour rights, the environment, and anti-corruption through our code of conduct. a:gain therefore also demands that all our business partners respect and comply with the same code of conduct (the “CoC”) at all times. The CoC is described in this document.

Any divergent terms in the general terms and conditions of our business partners, including, but not limited to, any divergent terms within the Business Partner’s own code of conduct, will be null and void. A term will be deemed divergent (also) in the case of having a narrower scope (etc.) than the CoC of a:gain, see also clause 15.1.2.

Selection of Business Partners (third parties)

Our business partners are responsible for the selection of their own business partners and cannot circumvent any of the terms and conditions of the CoC based on the hire of third parties when performing its contractual duties.

General Compliance

General Compliance

a:gain and all our business partners must comply with all applicable national and local laws, rules and regulations.

In case of discrepancies between the CoC compared to national laws or other applicable standards, a:gain and/or the Business Partner will be under an obligation to oblige with the higher of the two (or more) requirements.

Breach of any terms and conditions of a:gain CoC will grant a:gain the right to immediate termination of any agreements concluded with a business partner.

Business ethics and anti-corruption principles

a:gain and all of our business partners will always act in an ethically sound manner within the field of business ethics.

a:gain and all of our business partners should establish adequate processes to counter corrupt practices. Such processes should support and be in line with the United Nations Convention against Corruption, the UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA).

The anti-corruption principles listed below should as a minimum be managed:

not permitting corruption of public officials or private-to-private corruption;

not permitting payment of bribes in relation to business partners, government officials or employees; including through the use of intermediaries;

not permitting use of facilitation payments, unless you are subject to threats or other coercion;

not offering or accepting excessive gifts, hospitality, entertainment, customer travel and expenses in any situation in which it might influence, or appear to influence, any of the employee’s decisions in relation to the Business Partner;

any activity to support the process of money laundering or financing of terrorism; and

any act or omission intending to circumvent the above.

Human rights and working conditions

General human rights pertaining to the workplace

a:gain and all of our business partners will at all times respect (and act in accordance with) the various fundamental human rights as defined in the United Nations Universal Declaration on Human Rights ( and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work (–en).

a:gain and all of our business partners must as a minimum have adequate safeguards and policies in place to protect its employees, namely in an effort to condone any form of discrimination in the workplace. This includes, but not limited to:

The right to non-discrimination, including the right not to be subjected to negative differential treatment based on irrelevant personal characteristics such as race, gender, religion, nationality, age, disability, sexual orientation or political opinion;

The right to no social bullying based on race, ethnicity, caste, national origin, religion, disability, gender, sexual orientation, union membership or lack thereof, political affiliation, marital status, pregnancy status, physical appearance, age, or similar;

The right to non-discrimination within remuneration, overtime, access to training and promotion, termination or retirement based on illegitimate reasons;

The right not to be subjected to slavery, servitude or forced labour;

The right not to be subjected to sexual harassment, physical or verbal;

The right to family life, including protection of mothers before and after childbirth and children’s and young people’s protection from exploitation e.g. no child labour (this includes employing children under the age of 15 and dangerous work done by children under the age of 18) (see also clause 17.2);

The right to form and join trade unions, including the right to collective bargain and the right to strike;

The right to privacy, including processing employees’ personal data in compliance with applicable laws and regulations;

The right to a safe working environment, including the right not to be exposed to hazardous materials and dangerous working conditions (see also clause 18.3); and

The need for a sound work-life balance in compliance with local laws and legislation.

Similarly, a:gain and all of our business partners will have adequate safeguards and policies in place ensuring that its employees are not subjected to harsh or degrading treatment, sexual or physical harassment, mental, physical or verbal abuse, coercion or intimidation in any way.

a:gain and all of our business partners will have adequate measures in place to ensure that employees working with dangerous machinery are sufficiently trained in the right safety procedures.

a:gain and all of our business partners will comply with all applicable national laws on working hours and public holidays, including maternity and paternity rights, compassionate and paid annual leave.

Child labour

a:gain and all of our business partners will not in any way, directly or indirectly, engage in or benefit from the use of child labour (regardless of whether the employment is full-time, part-time, free-lance based etc.).

Under no circumstances shall a:gain and all of our business partners use labour younger than the age of 15. However, the minimum age for fulltime employment shall not be less than the age of completion of compulsory schooling in the respective country.

Environmental obligations


Corporate social responsibility (CSR) is a key part of a:gain’s business model and identity.

a:gain therefore encourages all of our Business Partner to have relevant CSR policies in place, i.e. reflecting the profile of each respective Business Partner’s company, with due respect paid to such Business Partner’s size, organisation, industries etc.

a:gain and all of our business partners must pursue having policies or practises in place which are in accordance with United Nations Sustainable Development Goals (SDGs).

The CSR obligations relate to a:gain and all of our business partners as such, and therefore apply regardless of whether the given act or omission (e.g. injury of an employee handling dangerous substances) happens as part of the production of a product actually intended for purchase by a:gain vs. by a third party.

As a minimum, a:gain and all of our business partners should act in accordance with the guidelines listed below in 18.2-18.5.

General environmental protection

As a minimum, a:gain and all of our business partners must follow the relevant laws and regulations within with all regulated environmental issues related to waste management, air pollution, wastewater, soil contamination, and biodiversity, as mentioned in clause 15.1.2 above. However, such laws and regulations should merely be minimum standards and cannot stand alone in case they do not, on a case-by-case basis, provide adequate environmental protection.

a:gain and all of our business partners will continually assess its environmental footprint in an effort to minimise it to a level proportionate with the production etc. a:gain and all of our business partners commit to minimising the negative impacts from activities, products and services through a proactive approach and responsible management of the environmental aspects including, but not limited to, the use of scarce natural resources, energy and water, potential and actual soil contamination, waste management (hazardous and non-hazardous substances) and products issues (design, packaging, transport, use and recycling/disposal);

Dangerous substances

a:gain and all of our business partners shall assure compliance with prohibited chemicals list (e.g. the REACH regulation).

a:gain and all of our business partners must ensure that employees will only handle dangerous substances if such contact is deemed an integral part of their job function. As few employees as possible shall have such responsibilities, except where having a larger group eases the risks for each individual employee.

Further, the a:gain and all of our business partners must at all times ensure the following:

Handling of dangerous substances shall be limited to as few occurrences as possible (with due respect to the nature of the work performed);

Employees handling dangerous substances shall at all times possess the relevant knowledge and expertise, including relevant training, enabling them to perform such duties safely;

a:gain and all of our business partners must have adequate policies in place for the protection of the life and health of its employees, and such protection is broadened for employees handling dangerous substances; and

In case an employee is injured during the handling of dangerous substances, a:gain and all of our business partners must have relevant medical measures in place for (i) danger minimisation for other employees, (ii) relevant internal assistance of the injured employee without undue delay (e.g. not leaving employees alone), and (iii) easy access to alarming the authorities.

Waste disposal and emissions

a:gain and all of our business partners shall at all times monitor and be mindful of its waste disposal and emissions. This includes, but is not limited to, having adequate policies in place for the safe disposal of any materials used in production etc.

a:gain’s business partners is encouraged to reasonably adapt its business model to reflect the circular thinking of a:gain whereby not only the environmental impact on production of given goods is considered, but also the long-term effects and possibilities regarding the products lifespan, maintenance and end-of-life disassembly or disposal.

As a:gain aspires to systematically account and calculate for our sustainability impact, a:gain expects our business partners to collaborate on LCA calculations incl. sharing of any relevant data needed for the calculation.

As a result of clause 18.4.3 above, a:gain requires its business partners to comply with reasonable quality requirements, especially those affecting the longevity (lifespan) of any given product(s). Furthermore, products should not be treated unnecessarily with chemicals (etc.) that make them unsuitable for circularity, disassembly or disposal or could have long-lasting negative consequences on the environment before, during or after use.

General use of energy and natural resources

a:gain and all of our business partners will work towards optimising its internal processes to maximise the use of energy and natural resources, both in the production of office furniture, supplies and other products and services.

Accessory and follow-up elements of production, e.g. shipment of goods to a:gain, customers or third parties, will – to the extent possible – happen as sustainably as possible, e.g. by maximising the volume/content of truck-loads, containers etc. before shipment.

Production of goods must take place using buildings and production facilities with modern, energy-saving (where applicable) equipment complying with relevant industry standards.