ESG: add export control, anti-harassment and competition, update other sections

docs/esg.md

@@ -1,10 +1,10 @@
 # Environmental, Social and Governance Policy - Badrap Oy
 
-This Environmental, Social and Governance Policy has been approved on 2021-03-24 by the board of directors to be used at Badrap Oy. 
+This Environmental, Social and Governance Policy has been approved on 2024-12-02 by the board of directors to be used at Badrap Oy. 
 
 ## Corporate Responsibility Statement
 
-Safety, security and privacy of our customers, society, people, our employees and our partners are the highest priorities for us. We follow laws, regulations and good corporate governance practices.  We respect human rights, labour rights, consider the environment and have anti-corruption measures. Our Code of Conduct has short policy statements on Environmental Protection, Health and Safety, Child and Forced Labour, Anti-Bribery, Anti-Discrimination, Taxes, Security Research and Open Source and Community Work.
+Safety, security and privacy of our customers, society, people, our employees and our partners are the highest priorities for us. We follow laws, regulations and good corporate governance practices.  We respect human rights, labour rights, consider the environment and have anti-corruption measures. Our Code of Conduct has short policy statements on Environmental Protection, Health and Safety, Open Source and Community Work, Security Research, Child and Forced Labour, Anti-Bribery, Competition, Anti-Discrimination, Anti-Harassment, Taxes and Export Control.
 
 ## Code of Conduct
 
@@ -16,19 +16,27 @@ Our Code of Conduct and its major updates are communicated to the suppliers and
 
 ## Anti-Bribery Policy
 
-We have zero tolerance towards acts of bribery and corruption, by any employee or anyone acting on our behalf. We, our partners and suppliers should "not offer, promise or give undue pecuniary or other advantage to public officials or the employees of business partners. ... Enterprises should not use third parties such as agents and other intermediaries, consultants, representatives, distributors, consortia, contractors and suppliers and joint venture partners for channelling undue pecuniary or other advantages to public officials, or to employees of their business partners or to their relatives or business associates.", see also further guidelines in chapter "Combating Bribery, Bribe Solicitation and Extortion" in OECD's [OECD Guidelines for Multinational Enterprises](http://www.oecd.org/daf/inv/mne/48004323.pdf).
+We have zero tolerance towards acts of bribery and corruption, by any employee or anyone acting on our behalf. We, our partners and suppliers should "not engage in any act of corruption, including the offering, promising or giving of any undue pecuniary or other advantage to public officials or employees of persons or entities with which an enterprise has a business relationship or to their relatives or associates. ... Enterprises should not use third parties or other intermediaries, including, inter alia, agents, consultants, representatives, distributors, consortia, contractors and suppliers and joint venture partners for channelling undue pecuniary or other advantages to public officials, or to employees of persons or entities with which an enterprise has a business relationship or to their relatives or associates.". See also further guidelines in chapter "Combating Bribery and Other Forms of Corruption" in [OECD Guidelines for Multinational Enterprises on Responsible Business Conduct](https://www.oecd.org/content/dam/oecd/en/publications/reports/2023/06/oecd-guidelines-for-multinational-enterprises-on-responsible-business-conduct_a0b49990/81f92357-en.pdf).
+
+## Competition Policy
+
+We foster fair competition, ethical practices and transparency throughout our business dealings. We will carry out our activities in a manner consistent with all applicable competition laws and regulations, taking into account the competition laws of all jurisdictions in which the activities may have anti-competitive effects. We will refrain from entering into or carrying out anti-competitive agreements, including agreements to: a) fix prices; b) make rigged bids (collusive tenders); c) establish output restrictions or quotas; or d) share or divide markets by allocating customers, suppliers, territories or lines of commerce. See also further guidelines in chapter "Competition" in [OECD Guidelines for Multinational Enterprises on Responsible Business Conduct](https://www.oecd.org/content/dam/oecd/en/publications/reports/2023/06/oecd-guidelines-for-multinational-enterprises-on-responsible-business-conduct_a0b49990/81f92357-en.pdf).
 
 ## Anti-Discrimination Policy
 
-We have zero tolerance for discrimination, see https://www.syrjinta.fi/syrjinta (Finnish) and https://www.syrjinta.fi/web/en/discrimination (English). We follow the [Finnish law on non-discrimination](https://www.finlex.fi/en/laki/kaannokset/2014/en20141325.pdf). 
+We have zero tolerance for discrimination, see https://yhdenvertaisuusvaltuutettu.fi/syrjinta (Finnish) and https://yhdenvertaisuusvaltuutettu.fi/en/discrimination (English). We follow the [Finnish law on non-discrimination](https://www.finlex.fi/en/laki/kaannokset/2014/en20141325.pdf). 
+
+## Anti-Harassment Policy
+
+We prohibit harassment of any kind. Incidents should be reported to the management and will always be investigated. Retaliation is strictly prohibited.
 
 ## Child & Forced Labour Policy
 
 We forbid use of child and forced labour as defined by the Finnish laws, see [Laki nuorista työntekijöistä](https://finlex.fi/fi/laki/ajantasa/1993/19930998) and [Valtioneuvoston asetus nuorille työntekijöille erityisen haitallisista ja vaarallisista töistä](https://finlex.fi/fi/laki/ajantasa/2006/20060475). 
 
 ## Environmental Policy
 
-As a bare minimum we, our suppliers and partners are to follow environmental laws, in Finland see [Luonnonsuojelulaki](https://finlex.fi/fi/laki/ajantasa/1996/19961096). However, we strongly encourage going beyond that. We will be periodically reviewing [United Nations' Sustainable Development goals](https://www.un.org/sustainabledevelopment/sustainable-development-goals/) for goal setting and adoption in our operations.
+As a bare minimum we, our suppliers and partners are to follow environmental laws, in Finland see [Luonnonsuojelulaki](https://finlex.fi/fi/laki/ajantasa/2023/20230009). However, we strongly encourage going beyond that. We will be periodically reviewing [United Nations' Sustainable Development goals](https://www.un.org/sustainabledevelopment/sustainable-development-goals/) for goal setting and adoption in our operations.
 
 ## Health and Safety Policy
 
@@ -46,6 +54,10 @@ Our employees and suppliers who participate in security and vulnerability resear
 
 We have a zero tolerance to tax evasion and the facilitation of tax evasion. We are not engaged in aggressive tax planning. Our headquarters is in Finland and we follow local tax laws in regions where we operate.
 
+## Export Control & Sanctions
+
+We comply with applicable export control laws, and international trade sanctions.
+
 ## Standard Clause for Suppliers and Partners
 
 All Suppliers and Partners can include the following standard clause (or equivalent content in their own language) into their contract terms to demonstrate their willingness to uphold our ESG standards.