Code of Conduct

1. Introduction

KOMPAN has a strong commitment to economic, environmental, and socially sustainable development. As a result of this commitment, KOMPAN Group has subscribed to the principles of the United Nations Global Compact (www.unglobalcompact.org). KOMPAN expects all its businesses to comply with the UN principles in addition to the laws of the countries where its businesses are located. As a global leader within its core businesses, KOMPAN strongly believes that it is in the mutual interest of both KOMPAN and its suppliers to meet the present and future requirements of markets and society. This includes demonstrating responsibility towards the people taking part in the manufacturing and delivery of products and services.

In order to make its position clear to all suppliers, KOMPAN has established the KOMPAN Code of Conduct for Suppliers (the "Code"). The Code describes KOMPAN Group social responsibility requirements for suppliers. As a condition of doing business with KOMPAN, we expect suppliers to comply with these requirements. It is KOMPAN's intention to maintain this Code in a spirit of constructive dialogue, and in partnership with suppliers, for the mutual benefit of both parties.

In the Code, the term "KOMPAN" refers to all KOMPAN Group companies.

2.KOMPAN general requirements of suppliers

2.1 Area of application

The Code applies to the supplier and all supplier Group companies (the "Supplier"). The Supplier shall inform all Supplier Group companies of their obligations in relation to the Code and the Supplier is responsible towards KOMPAN for all Supplier Group companies' compliance with the Code.

2.2 General responsibilities

Supplier shall take all necessary actions to ensure the Supplier's compliance with this Code, without undue delay. In addition to complying with the Code, the Supplier shall comply with applicable local laws.

The Supplier is solely responsible for the costs of complying with the Code. If KOMPAN finds or suspects incidents of noncompliance with the Code, related to the Supplier, and KOMPAN informs the Supplier hereof, KOMPAN expects the Supplier to investigate and correct issues of noncompliance as soon as possible and within an agreed timeframe. If the Supplier does not show willingness to correct these issues, KOMPAN will consider terminating the business relationship with the Supplier. Any such termination of any business relationship between KOMPAN Group companies and the Supplier is considered a termination for cause and does not entitle Supplier to any kind of compensation.

If the Supplier uses sub-suppliers for its supplies to KOMPAN and/or acts as a distributor or wholesaler towards KOMPAN, the Supplier shall use his best endeavors to ensure that its sub-suppliers comply with the Code.

2.3 Site Audit

KOMPAN may conduct announced audits at the Supplier's sites, including the Supplier's manufacturing facilities, in order to verify that the Supplier is in compliance with the Code ("CoC audit"). CoC audits may be performed either by KOMPAN employees or by a third party auditor chosen by KOMPAN. In order to verify the Supplier's compliance with the Code, the Supplier shall be prepared to provide KOMPAN access to relevant and reasonably requested information and documentation, during an audit. All auditors carrying out CoC audits are bound to confidentiality by written agreements. All information and results obtained in connection with CoC audits will be handled confidentially by KOMPAN and will only be shared with the Supplier. KOMPAN will only use such information for internal purposes.

3.Contact

For general questions or comments on the Code, Supplier may contact Supplier's procurement contact at KOMPAN.

4. Supplier behaviour

4.1 Child Labour

KOMPAN respects the children's right to development and education. Therefore, KOMPAN does not accept the use of child labor as a part of the full-time workforce at the Supplier. This includes employing children under the age of 15, children younger than the legal minimum age, or children younger than the age of completing compulsory school.

Juveniles (children between the age of 15 and 18) are only allowed to be employed by the Supplier, provided that the work complies with local laws and the ILO Minimum Age Convention. In general, all children, under the age of 18, must not be employed in *hazardous work, must not work night shifts, and are entitled to more breaks than adults.

*Hazardous work is work which, by its nature or the circumstances, is likely to harm the health, safety, or morals of children.

4.2 Discrimination

KOMPAN respects cultural differences and does not do business with a Supplier if the Supplier practices discrimination at work based on race, religion, gender, age, nationality or sexual orientation. Supplier's employees must not be exposed to any physical punishment, threats of violence or physical, sexual, psychological or verbal harassment or maltreatment in the work place or in work related situations.

4.3 Forced Labour

The Code does not permit forced or involuntary labor from the Supplier. This includes forced prison work, work on a forced contract, slavery, and other forms of work which are done against one's will or choice. KOMPAN does not tolerate employment which confines the employee in unreasonable debt bondage, for example, through fee-charging employment agencies.

4.4 Working Environment

KOMPAN supports the fundamental human right to have sound working conditions. Supplier must ensure a good and safe working environment which complies with all applicable rules and laws. As a minimum:
Workers must not be exposed to dangerous work without being properly protected.
Workers must be provided personal protection equipment and be instructed in its proper use.
Facilities must comply with applicable laws and rules about construction safety as well as fire protection - and fire alarms.
Facilities must provide appropriate light and ventilation
All dangerous materials must be stored in safe places and used in safe and controlled ways.
All machinery must be properly maintained and shielded.
Facilities for meals, resting and sleeping, must, if provided, be kept clean and safe.

4.5 Working hours and salary

KOMPAN recognises the need for a sound balance between working time and leisure time for all employees.
Unless the law provides otherwise, the maximum working time at the Supplier's sites is 48 hours per week plus maximum 12 hours overtime work. All workers shall be allowed to have at least one day off in a period of seven days unless the national law/rules provides otherwise.
Salaries for work and overtime shall be in accordance with the applicable national law or applicable national rules. Deductions in salary due to company fines or penalties must never compromise minimum salary.

4.6 The right to organize and collective bargaining

The Supplier must not interfere with the worker's right to form and join unions or to bargain collectively. This means that the Supplier must recognize his employees' right to choose whether or not to associate with, or establish any, organization, including labor organizations. If trade unions are not allowed in the area of operation, or only state authorized organizations are allowed, the Supplier shall facilitate alternative measures to allow employees to access management to discuss work-related matters.

4.7 Right to privacy

Supplier shall respect his employees' right to privacy when gathering or keeping personal information or implementing employee-monitoring practices.

4.8 Environment

Environmental considerations are an integral part of KOMPAN business practices. Supplier shall commit to reducing the environmental impact of its manufacturing process.

Pollution Prevention and Resource Reduction
Supplier shall avoid pollution and actively strive to reduce material consumption.

Chemicals and Hazardous Materials
Supplier shall ensure that chemicals and hazardous materials are handled, stored and disposed in an environmentally safe way

Air Emissions
Supplier shall ensure that air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required by law prior to discharge.

Wastewater and Solid Waste
Supplier shall ensure that wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required by law prior to discharge or disposal.

Recycling and reuse of Materials and Products
Supplier shall contribute to the recycling and reuse of materials and products to the extent possible and to ensure compliance with KOMPAN Specifications.

4.9 Corruption

Corruption and bribery are recognized as barriers to sustainable development and free trade. KOMPAN does not accept these practices, and therefore, does not offer or accept any kind of undue payment in any of our business transactions. We expect our Suppliers to act accordingly.