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Code of Conduct for the Danish Bar and Law Society

I have been a lawyer appointed by the Danish Ministry of Justice since 2003 and I am a member of the Danish Bar and Law Society. I am covered by professional malpractice liability insurance for all my services through Söderberg & Partners.

For private individuals, I am obligated by the Code of Conduct for the Danish Bar and Law Society to inform you in writing of the terms and conditions that apply to my counsel before we begin working together.

As a lawyer, I adhere to attorney-client privilege and will keep in confidence all information I gain during our collaboration. Confidentiality is not waived even after our association has ended, with a few exceptions regarding lawyers’ disclosure requirements laid down by the law or industry regulations.

Anja Staugaard Law Firm is subject to the Danish Bar and Law Society’s rules and regulations regarding complaints. Existing client may file a complaint concerning my advisory services or my fees with the Danish Bar and Law Society’s Disciplinary Board. You may contact them by e-mail at klagesagsafdelingen@advokatsamfundet.dk.

The Code of Conduct for the Danish Bar and Law Society, in their entirety, may be found at www.advokatsamfundet.dk.

Copenhagen 21/08-23

Business Terms

Scope
These terms of business (“the Terms”) shall apply to any assistance provided by Anja Staugaard Law Firm, unless we have entered into a written agreement under which other terms and conditions apply. I have been appointed by the Danish Ministry of Justice.

Fee
Unless we have agreed otherwise in writing and in advance, my fee will be determined on the basis of the time consumed by the task. My hourly rate is DKK 3,500 excluding VAT. If we have agreed on a fixed price, or if I have estimated a price for a task, this price shall be conditional on the task being completed within the stipulated time, and on no circumstances arising which might impede the performance of the task, or which I could not reasonably have foreseen. However, I will inform you immediately if I can see that a fixed price cannot be adhered to, or if an estimated price will be exceeded by more than 20%.

Billing
In general, billing will be done when the case is concluded, or when a specific task has been completed. If a case or task runs over the end of a month, it may be invoiced at the end of each month. Billing will also be undertaken if the course of the case requires it, for example after a case statement has been submitted.

Anja Staugaard Law Firm does not keep client accounts and does not therefore provide outlays for expenses such as court fees and listing fees. Such outlays will be invoiced immediately after Anja Staugaard Law Firm has paid them.

I send all bills by e-mail, unless we have agreed otherwise. Special requirements regarding payment, including electronicsettlement or a number of days of credit, shall apply only if accepted in writing by Anja Staugaard Law Firm.

Transport
Transport time will be billed at 50% of the usual hourly rate, unless otherwise agreed. Possible transport expenses will be billed only if we have agreed in advance to do so, and will in this case be billed in accordance with the state tariffs or actual expenses incurred, including for bridge tolls, etc.

Payment
The invoice amount shall fall due 30 days after the invoice date. However, invoices relating to outlays shall fall due for payment by the time of receipt at the latest. In case of late payment Anja Staugaard Law Firm is entitled to cease the work without notice and to charge interest from the due date. In connection with payment reminders, Anja Staugaard Law Firm is entitled to charge fees at the rates stipulated by law.

Conflicts of interest
When I receive a case, I investigate whether a conflict of loyalty or conflict of interest exists, and if so, or if any such conflict arises in the course of the case, I will refer you to another lawyer.

Confidentiality
Anja Staugaard Law Firm treats all information received as confidential unless the information is not of a confidential nature in the given circumstances, or Anja Staugaard Law Firm is required by law to disclose the information. If possible, Anja Staugaard Law Firm will inform you of such disclosure at the same time as the information is provided to a third person or an authority.

Money laundering
In order to avoid providing support for terrorist activity, all lawyers in Denmark are subject to a strict set of rules, which means, amongst other things, that information on identity must be obtained. For companies, this includes information about any persons who ultimately own more than 25% of the company. Clients of Anja Staugaard Law Firm are therefore required to provide any necessary identity information and documentation upon request. As a client of Anja Staugaard Law Firm, you are required to state if an ultimate owner or member of the management is a politically exposed person. A politically exposed person (“PEP”) is a person who is entrusted with one or more prominent public functions. The Danish Financial Supervisory Authority’s list of PEPs in Denmark can be seen here.

The identity information will be processed and stored for the sole purpose of preventing money laundering and support for terrorist activity, and in accordance with the law, it will be stored for a minimum of 5 years after the end of the client relationship.

Insider trading
All employees at Anja Staugaard Law Firm are subject to the applicable legislation prohibiting the transfer of internal knowledge about listed companies in accordance with the prohibition on insider trading contained in the Danish Consolidated Act on Securities Trading.

Liability
Anja Staugaard Law Firm is insured with HDI, policy no.156-76206427-30017, and is liable for damages in accordance with the ordinary rules of Danish law in connection with any losses that my advice incurs for you. However, the coverage is limited to the maximum coverage under the insurance. The maximum coverage under the insurance is DKK 10,000,000 per claim per year and DKK 2,500,000 per lawyer per year, and Anja Staugaard Law Firm cannot be held liable for a higher amount in damages.

Other concurrent claims against Anja Staugaard Law Firm may reduce this amount.

The liability of Anja Staugaard Law Firm does not include consequential financial losses, operating losses, lost profits, loss of goodwill, expenses for data recovery or loss of data, public image or other types of indirect loss. Liability can only be claimed by the person to whom Anja Staugaard Law Firm has provided advice.

Personal data
See the next page for a description of how Anja Staugaard Law Firm processes the personal data received from you in connection with the advice provided.

Communication
Anja Staugaard Law Firm communicates via e-mail, unless otherwise agreed. E-mails from Anja Staugaard Law Firm will not be encrypted unless so requested by you, as a client, or required by law. The systems at Anja Staugaard Law Firm are checked for viruses, malware, etc. according to recognised standards, but Anja Staugaard Law Firm can assume no responsibility for e mails or attachments that may contain harmful viruses, etc. You are therefore urged to check e-mails and attachments for harmful viruses, etc., before opening them.

Withdrawal
Anja Staugaard Law Firm shall be entitled to withdraw from a task if a client has overdue, unpaid debts to the firm, or if a required deposit has not been paid. Anja Staugaard Law Firm also reserves the right to withdraw if a task does not create value for you as a client.

Opinion letters
Anja Staugaard Law Firm draws up opinion letters when so requested by you or your accountant. Opinion letters are invoiced at the hourly rate, with a minimum fee of DKK 1,500 excluding VAT.

Intellectual property rights
The intellectual property rights to material prepared by Anja Staugaard Law Firm shall belong to Anja Staugaard Law Firm, unless otherwise agreed.

Disputes
Complaints concerning the conduct or fees of lawyers may be brought before the Disciplinary Board of the Danish Bar and Law Society (Advokatnævnet), Kronprinsessegade 28, 1306 Copenhagen K. You can read more about the Disciplinary Board at www.advokatsamfundet.dk/ advokatnaevnet, but I would naturally urge you to speak with me in the first instance.

This letter is subject to and must be interpreted in accordance with Danish law. Any dispute in connection with the legal advice provided by Anja Staugaard Law Firm or the contents of the letter of engagement must be brought before the Danish courts.

I look forward to advising you and to a good partnership.

Copenhagen 21/08-23

Personal data

Anja Staugaard Law Firm is the data controller

How do you contact us?
Anja Staugaard Law Firm is the data controller responsible for processing the personal information we receive from your company and employees. Here is our contact information:

Anja Staugaard Law Firm
Hyskenstræde 3, st. tv.
1207 Copenhagen K
CVR.no.: 40 54 12 09
Telephone 30 28 07 11
Mail: info@anja-staugaard-advokatfirma.dk

Contact information for the Data Protection Advisor
If you have any questions concerning our information processing, you are always welcome to contact our Data Protection Advisor at: info@anja-staugaard-advokatfirma.dk, or phone 30 28 07 11, or by ordinary post to the above address.

The purposes and legal basis for the processing of your personal data
We process your personal data in order to handle your case and to advise you on the specific task you have asked us to perform. The legal basis for our processing of your personal data is article 6(1)(b) of the General Data Protection Regulation.

In the case of sensitive personal information or CPR numbers, our processing takes place on the basis of article 9 (2) (f) of the General Data Protection Regulation and section 11, subsection 2, (3) of the Data Protection Act, for the purpose of enforcing or defending legal claims where our legitimate interest precedes your interests and fundamental rights.

Categories of personal data and the origin of your personal data
Anja Staugaard Law Firm processes the following categories of personal data about you: Ordinary personal data about employees, including contact information such as name, position, e-mail address, telephone, postal address and place of employment. If we undertake registration in the databases of the public authorities (effect.dk, dkpto.dk or minretssag.dk) it may be necessary, for the sake of identifying the person concerned, for us to process more of the person’s ordinary personal data, including CPR number.

The sources of the personal data are either you or another person affiliated with the party that you represent.

How do we secure your personal data?
Anja Staugaard Law Firm has adopted internal security rules on data security which contain instructions and measures to protect your personal data from being destroyed, lost or altered, as well as from unauthorised disclosure and unauthorised access to or knowledge of the data, etc.

Anja Staugaard Law Firm has implemented appropriate technical and organisational measures relating to confidentiality and data security to protect the collected personal data from being destroyed, lost or altered, and to prevent unauthorised disclosure and unauthorised access to or knowledge of the data.

This means, inter alia, that access to personal data is physically and systemically restricted to those colleagues who have a work-related need to access it, and who have received training and instruction in the processing of personal data. We are all subject to the duty of confidentiality and non-disclosure.

Personal data in physical form or on portable data media (USB drives and the like) is locked away when not in use, while personal data in digital form is protected by access control, personal passwords, encryption, backup systems and updated firewalls and antivirus protection.

Anja Staugaard Law Firm also has a procedure for dealing with any security breaches, and for providing you and the Danish Data Protection Agency with notification of this.

However, no information system can be 100% secure. Anja Staugaard Law Firm cannot therefore guarantee the absolute security of your data. Moreover, Anja Staugaard Law Firm cannot be responsible for the security of data you send to us via networks which are not under our own control, including the Internet and wireless networks.

Your rights
Under the General Data Protection Regulation, you have a number of rights in relation to the processing by Anja Staugaard Law Firm of information about you. If you wish to make use of your rights, contact us.

  • You have the right to request access, rectification or deletion of your personal information.
  • You also have the right to object to the processing of your personal data, and to limit the processing of your personal data.
  • In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
  • You have the right to receive the personal data you have provided in a structured, commonly used and machine-readable format (data portability).

There may be certain conditions or restrictions attached to your rights. It is not therefore certain that you are for example entitled to data portability or data deletion in specific instances – this will depend on the specific circumstances of the processing activities. You have the right to complain to the Danish Data Protection Agency about our use of your personal data. You can read more about your rights in the guidelines of the Danish Data Protection Agency regarding the rights of registered persons, which you can find at: www.datatilsynet.dk.

Complaints to the Danish Data Protection Agency
You have the right to submit a complaint to the Danish Data Protection Agency if you are dissatisfied with the way Anja Staugaard Law Firm processes your personal data. The contact information of the Danish Data Protection Agency is available at: www.datatilsynet.dk

Secure email

I use TLS 1.2 for all outgoing email correspondence.

If you need to send me an email containing sensitive personal information, you can either send me the email encrypted, for example via Office 365, or use my company’s Eboks (CVR 40541209).

If you would like to receive emails with sensitive personal information via your Eboks, you must register Anja Staugaard Law Firm as a sender in your Eboks.

If it becomes necessary to send an email to you containing sensitive personal information, I will use the same procedure.