Axactor strives to maintain the highest level of professional standards and places maximum focus and importance upon honesty, integrity, accountability, transparency, and compliance in all aspects of its conduct of business. This includes effectively managing environmental, social and governance matters. We also recognize that business has a role to play in solving social challenges. We work to do so through responsible investments, by supporting and developing the skills of our employees, and by offering innovative products that cater to our customers’ needs. This combines faster payments and respectful treatment of debtors, brings down outstanding credits, secures a stronger financial market, and increases quality of life for many people in financial difficulties.
The Board of Director and the Executive management is fully committed to the work to ensure that Axactor complies with all applicable laws and regulations and operates in line with Axactor’s values, policies and guidelines in all business activities.
The company shall act in an ethical, sustainable, environmentally and socially responsible manner, practice good corporate governance, and respect internationally recognized human rights principles. Axactor has zero tolerance for corruption, fraud, money-laundering and terrorist financing. To safeguard compliance and support the effectiveness of such acts, the company will maintain an open and ongoing dialogue on these issues, internally and externally. This is reflected in among others the Environmental policy, Corporate Governance policy, Anti-fraud, anti-corruption and anti-money laundering policy, our privacy declaration and Corporate Social Responsibility policy, which are all available on the company’s website. Axactor has in addition a set of internal policies, procedures and guidelines specifying the principles in the mentioned policies.
Axactor sets clear responsibilities and expectations for our leaders, employees and partners. This enables us to operate efficiently with the necessary oversight and control. Effective governance structures further allow us to work smoothly by ensuring that everyone has a clear understanding of the distribution of roles, responsibilities, rights and accountability. The corporate governance of Axactor complies with formal regulations and generally accepted best practices.
Effective, secure and sound collection processes are essential tools to achieve Axactor’s strategic, operational and financial targets, and the company has implemented an operational policy to ensure that these targets can be met without compromising the highest ethical standards and principles of good collection practices.
The risk management framework shall also ensure efficiency and control of the business operations in compliance with laws and regulation and our business ethics, as well as profitability and continuity. Axactor’s internal control and risk management systems consist of a set of policies and procedures covering e.g. our strategy, operations, business ethics, regulatory compliance, and internal and external reporting. All employees receive adequate training. Compliance is monitored and reported, and continual improvement work carried out.
Axactor operates a structured risk management process that includes strategic risk, financial risk, reputational risk, technical risk, and legislative and regulatory compliance risks. The Board carries out regular reviews of the most important areas of risk exposure and its internal control arrangements. The internal control framework shall assure that the operations are effective and aligned with our strategic goals and correct, reliable, complete and timely financial reporting and management information.
The Board of Directors was not made aware of any material breaches of Axactor’s policies in 2019.
The company measures customer and debtor satisfaction through surveys. Axactor has also implemented procedures for complaints and whistleblowers. In addition, Axactor is under the supervision of regulatory authorities in all its markets. None of these channels have uncovered any material deviations from the sustainability principles.
In addition to company-wide guidelines, procedures and policies, all markets have local CSR initiatives. Some examples from the Spanish unit include:
Axactor’s business is by nature non-polluting and generally harmless to the external environment. Axactor is nevertheless committed to reduce its environmental footprint. Axactor’s Environmental policy, approved by the Board, addresses how the company manages and controls environmental issues in its operations and services.
The Environmental policy is available on the company’s website.
The main environmental issues relate to energy consumption, travel and the waste hierarchy, both in the day-to-day operations and in the lifetime management of IT-equipment.
Axactor monitors compliance to its policies and procedures through annual internal audits/self-assessments, with the results presented in a separate report to the Board of Directors towards the end of the year.
With regards to energy consumption, all Axactor offices shall – if feasible- have systems for time-regulated monitoring of ventilation, heating/cooling and lighting. No relocations or reconstructions of existing offices shall lead to higher energy consumption. An internal audit/self-assessment performed in the second half of 2019 showed compliance with the policy in all countries except Spain, where actions have been defined to mitigate and ensure policy compliance during 2020.
As part of Axactor’s HR policy, the Travel Procedure specifies that employees are encouraged to limit travel and use tele-/video conferencing as much as possible, and that approval is needed before travels. Some travels are unavoidable due to the international scope of the company’s operations. Axactor strives to lower the travel ratio and encourages less carbon intensive travels.
Axactor has also limited the use of company cars and encourages the choice of low emission vehicles. It is mandatory to select models/specifications that have a lower than average fuel consumption and emission for its class, according to in the World Light Vehicle Test Procedures (WLTP).
Axactor is committed to reduce waste. The general waste hierarchy is to first reduce waste at the source, secondly to reuse items if possible, and thirdly to ensure that items not possible to reuse are recycled.
All offices shall have recycling of paper and systems for waste sorting to secure proper handling.
The internal audit/self-assessment for 2019 confirmed that all countries are following these principles.
Axactor has partnered with IT contractors, as mentioned below, that are certified according to ISO or conduct its business in accordance with similar standard. Under these certifications, the contractors are obliged to ensure recycling of IT-equipment and seek efficient and environmentally friendly alternatives for sourcing, packaging and transportation.
During 2020, Axactor will investigate the opportunity to become an Eco-Lighthouse certified enterprise, in order to create and even more environmentally friendly and safer work environment. This will include CO2 reporting. The Eco Lighthouse Foundation has prepared industry specific requirements for a range of different industries. Certification is subject to independent assessments and re-certifications every three years. Certification will require issuance of annual environmental reports.
Axactor respect the personal integrity of individuals. Axactor processes different types of personal data in different ways for different situations, depending on whether a person is a representative of a customer, vendor or public authority, a debtor, employee, a job applicant, visitors to our website(s) etc. Regardless of situation, Axactor shall only process personal data in accordance with applicable data protection regulation.
We are obliged to implement appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with Regulation (EU) 2016/679 (GDPR) and local data protection laws. Further, personal data shall only be collected for specified, explicit and legitimate purposes, and the data must be processed fairly and in a transparent manner in relation to the data subjects. Records of our processing activities shall be kept. Axactor shall process requests from data subjects regarding any of its rights in an appropriate manner and as deemed reasonably practical. In order to minimize the processing, personal data shall be deleted or anonymized when we no longer have legal grounds for processing the personal data. Only personal data necessary for the relevant processing are to be collected and processed. In order to ensure that we comply with the GDPR and local data protection laws, we have developed a Data Protection policy and procedures and guidelines applicable for the Axactor group with clear roles and responsibilities. However, even if the GDPR sets out a common general legal framework in all EEA countries, there are certain differences in the legal requirements, such as debt collection laws, administrative laws, civil proceedings laws and accounting laws. We adapt our procedures to reflect these differences. All our employees must complete a training program which shall include basic data protection training and more advanced data protection training adjusted for the data processing to be conducted by the employee. All deviations and data breaches must be reported internally through the established incident and data breach notification channel.
Axactor has a process for approving new products and business development prior to launch and to secure an appropriate quality and service level. Axactor shall have a responsible product offering and monitors the social impact and risks of our products and services. Axactor strives to ensure and improve customer and debtor satisfaction, and customer and debtor satisfaction surveys conducted in 2019 showed a high level of satisfaction in all the markets we operate.
Axactor has a complaint process in each country. A limited number of complaints were received from debtors and none considered critical. All complaints are handled in accordance with the procedure; investigated, answered, errors (if any) corrected, reported and filed.
Operations are performed in accordance with common KPIs across Axactor, and are reported to Group on a monthly basis and the Board semi-annually. Several improvement project to raise the quality have been initiated and are closely monitored.
Portfolio investments (NPL) and REOs are also monitored closely by the Group investment management team on a regular basis, and the Board’s Investment Committee quarterly.
Axactor has a process for ensuring that new customers are satisfactorily evaluated and approved, to ensure compliance, avoid loss of reputation and secure an appropriate quality and service level according to both parties` expectations. A policy sets out clear and appropriate guiding principles for how new customers are approved and contracts are set up.
Management shall ensure responsible investments. Through a “know your customer” procedure Axactor conducts appropriate checks to avoid entering into agreements with customers involved in any fraudulent, corruptible, money-laundering or other illegal activities, or coming from a sanctioned country, and to prevent any conflict of interest. All Axactor’s contracts shall contain warranties of compliance to relevant laws and regulations.
Axactor has a structured purchasing processes and sourcing strategies to ensure that the services and goods we acquire are the result of transparent, objective, time and cost-effective decision making and risk management. Ethics, regulations, professionalism and equal treatment of suppliers are absolute requirements in this work. All purchases shall among others be fair, unbiased, consistent, and aim to attract the widest and most diverse pool of applicants possible and appropriate. Axactor shall never engage any suppliers involved in any fraudulent, corruptible, money-laundering or other illegal activities, and ensure they comply with data privacy and have implemented sufficient organizational and technical information security measures to protect the privacy of the personal data processed. Axactor has consequently partnered with e.g. IT contractors that are ISO-certified under 9001 Quality, 14001 Environmental and 27001 Security or similar standard such as ISAE3402 type II and ISAE 3000 type II. Under these certifications, the contractors are obliged to ensure environmentally friendly alternatives for its business, high information security standards, compliance to e.g. GDPR etc.
Axactor shall encourage competition by ensuring non-discrimination in purchase and use competitive purchasing processes and promote the use of resources in an efficient, effective and ethical manner. The decision making shall be conducted in an accountable and transparent manner in accordance with Axactor Delegation of authority policy.
Our suppliers shall be compliant with good corporate governance and not involved in any illegal activities that can cause negative consequences and harm the reputation of Axactor, consistent with socially responsible, diverse and ethical business operations and practices. The selection of suppliers should be based on transparent and objective criteria, free from personal interests, biases, or other untoward or political influences. Axactor shall select suppliers with an acceptable environmental standard and use products and services that represent the lowest total impact on the environment. All records should be as complete and accurate as possible, and timely kept. During the contractual period the respective manager responsible for the contractual relationship should assess that relevant suppliers provides the right quality and quantity of goods or services at the greatest total value to the business, in accordance with the agreement and in compliance with laws, information security requirements and business ethics.
These principles are outlined in Axactor’s procurement policy which is approved by the board.
The Axactor organization continued to expand in 2019, with the number of employees increasing to approximately 1,150 FTEs from 1,040 FTEs at the end of 2018. Axactor has employees located in all its operating markets. At the end of 2019, Axactor had 656 FTEs in Spain, 198 in Germany, 117 in Norway, 106 in Italy, 34 in Sweden and 28 in Finland. In addition, the company employed five in Latvia and eighth in Estonia related to the Finnish operations.
Axactor’s centralized HR function in Oslo, Norway, is led by an EVP of Human Resources who is responsible for continuous development and refinement of Axactor’s HR policy. This is an overriding policy for Axactor’s people practices and applies to all employees across the Group. Country specific HR operations and adaptations to local regulations and norms have been delegated to the local HR teams.
The HR policy clearly states that the company shall always comply with local laws and regulations for employment and working conditions, and fair employment practices are embedded in the Code of Conduct and Corporate Social Responsibility policy. The company embraces diversity and inclusiveness, and a healthy, safe and non-discriminatory working environment where everyone is treated equal and with respect, regardless of gender, nationality, race, religion, sexual orientations, disabilities, or marital status. Axactor conducts diversity monitoring and audits to ensure compliance.
Any and all employees are free to participate in any employee unions and have the right to collective bargaining. Axactor shall offer a working environment where it is possible to combine work, career, family life and spare time.
The Group aims to be a workplace with equal opportunities and has included in its policies regulations to prevent gender discrimination regarding salary, promotion and recruiting. Axactor seeks to achieve a gender balance within the occupational categories and organizational levels across the Group. At the end of 2019 the company overall employed 760 women (63%) and 440 men (37%). On the managerial level 31% were women and 69% men, whereas 2 of 7 country managers were women. The Board of Directors consisted of 3 women and 3 men.
New reporting regulations for gender equality will be in effect from 2020. Axactor is implementing a new HR system during 2020 and will develop a HR reporting structure that is compliant with the new regulations. This system will also improve the human capital development metrics and human capital risk assessment reporting.
Quality, health and safety are integral aspects of the Company’s
operations, and systems are in place to monitor and follow up
accidents or incidents. Axactor’s business is by nature non-hazardous, and no accidents or injuries were recorded in 2019. There are several local initiatives to promote employees’ health, e.g. sponsoring of health club membership, common training for groups of employees, physiotherapist availability in the office on a regular basis, internal
football match arrangements, annual culture and value event
dedicated to physical health, and separate health insurances.
The internal working environment is considered healthy and safe. Axactor has a policy describing the security of its premises, e.g. to deny unauthorized access to office facilities, equipment and resources, and to protect personnel and property from damage or harm. Physical security also provides measures to safeguard employees from the threat of physical violence. Employee’s personal data is processed in accordance with GDPR and local data privacy regulations and their privacy protected.
The Company runs biannual employee engagement surveys to ensure that the company has a healthy and engaged workforce aligned with the company’s values, operating model, policies and procedures. Based on the result of the last survey the employees show an overall high level of satisfaction and motivation related to their work in Axactor. This is also reflected in the turnover for 2019 with an average rate of 3,5% for Spain, 3% for Finland, 11% in Sweden, 4% in Italy, and 5,5% for Germany. Germany has a higher turnover than previous years due to larger organizational changes conducted in 2019. In Norway the turnover for 2019 was much higher than normal with 24%. This is due to several employees seeking employment at their previous employer who have started competitive business, changes to the bonus model and working methodology for 3PC and larger transformations within the sales organization. The turnover for Norway is expected to decrease substantially in 2020 when the planned operational changes have been finalized.
All countries have defined actions according to the recommended focus areas for Axactor, combined with their local results. Each country’s action plan is followed up during the quarterly HR reviews per country. The country action plans are aligned by Group and best practices shared. No red flags are identified, and all actions are on track. Axactor also has a whistleblowing channel, presented in the Corporate Governance report, where employees anonymously can report on non-compliance to the above mention sustainability principles. No material issues have been reported.
Axactor’s HR policy states that the company is committed to continuous professional development of its employees. To secure this the company drives all training through the Axactor Academy. The Axactor Academy provides the organization with a streamlined structure to manage the competence development for all employees. Control mechanisms are in place to assess the quality of the skills development and monitor the training and certification of all employees. All markets have a defined training curriculum.
Managers and employees cooperate in setting structured career development targets for the individual employee and holds regular performance development conversations. An open feedback culture is promoted. 32 top managers have participated in a leadership development program delivered by AFF. 16 new top managers will participate in the same program during 2020.
All markets offer team leader training, to secure well qualified team leaders that knows what is expected and how to carry out the role in the local market. The sales managers and sales force in general also undergo structured training with focus on the sales process, customer service and follow-up. In Operations the training is directed to improve efficiency, best use of systems and secure the best debtor follow-up and care. In addition, all employees receive trainings to secure compliance to relevant laws and regulations such as debt collection regulations, tax and financial regulations, anti-fraud and anti-corruption, data privacy, information security, anti-money laundering and terror financing and other business ethical standards. Training is carried out in a combination of on-the-job-training, sharing of best practices and knowledge, and numerous e-learning courses and classroom trainings. Learning and development objectives are linked to Group-wide organizational objectives.
Collaboration and co-innovation across the Group are important elements in building an Axactor culture driven by the core values of Passion, Trust and Proactive.
Building One Axactor
Axactor’s efficient operational platform is viewed as one of its main competitive advantages in the debt collection industry, and the
company strives to achieve and sustain operational excellence through its ‘One Axactor’ program.
All entities in all countries are participating in the program, which focuses on integrating and aligning employees and operations on common HR practices, common operational standards and KPIs, on a common IT platform, and through group-wide policies and corporate governance structures.
The Axactor Leadership Platform secures that the managerial level conducts business in a professional manner and in compliance with Axactor’s values, policies and procedures.
The company has established clear roles and responsibilities for all level of the organization, with clear decision-making processes in an authority matrix.
During Q4 2019 the company started the implementation of a new HR system that will be fully implemented during first half of 2020.
Statement of Corporate Governance