CODE OF CONDUCT 1./8

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1 CODE OF CONDUCT 1./8

2 1. OBJECTIVES The DKI Group is a privately owned Danish Group that has been an order-producing subcontractor of plastic components to the industrial market since its incorporation in 1946 under the name Dansk Kunststof Industri. From a modest start as one of the pioneers of the Danish plastics industry DKI has developed into an internationally recognised and future-oriented company working in close cooperation with its customers. Today, DKI has aproximatelly 250 employees at its factory in Slovakia. DKI Plast will only achieve long-term business success by demonstrating good corporate citizenship, which in turn can only be secured if the business is based on constant achievement of good results. This is the very heart of the DKI Plast Code of Conduct as regards sustainable development, issues related to religion, employee relations, health and safety, environmental protection and community relations. It is essential to DKI Plast that the DKI Plast Code of Conduct is an integral part of the entire value chain. We therefore expect not only the companies within the DKI Plast Group, but also our external suppliers, wholesale and retail customers to acknowledge and respect the Code of Conduct. We regularly control that the DKI Plast Code of Conduct is being complied with. 2./8

3 2. THE 11 COMMITMENTS 10 fldafja gjňgjňgv úouiäňúi0ii. T10 mhe 10 COMMITMENT 1. DKI Plast operates with and respects other cultures. 2. DKI Plast supports, respects and takes a proactive approach in protecting internationally defined human rights. 3. DKI Plast respects equal opportunities and fights discrimination in the workplace. 4. DKI Plast respects the individual s right to religious freedom. 5. DKI Plast respects the right to freedom of association. 6. DKI Plast wishes to provide employees with a workplace free of harassment or abuse and condemns any form of enforced labour. 7. DKI Plast supports the UN Convention on the Rights of the Children. 8. DKI Plast provides training, education and further development of human resources at all levels. 9. DKI Plast aims to be a leader within the environment, health and safety and supports sustainable development. 10. DKI Plast do not accept any form of corruption like bribery or kickback. 11. DKI Plast wishes to ensure that it complies with all relevant laws and regulations. 3./8

4 3. WHAT DOES DKI PLAST MEAN BY THE 11 COMMITMENTS? HUMAN RIGHTS a) DKI Plast has its origins in Denmark. This background is naturally reflected in DKI Plast s point of view on human rights. DKI Plast wants all its employees to be treated with respect and dignity. b) DKI Plast recognizes that all human beings are entitled to all the rights and freedoms set forth in the UN Declaration of Human Rights. EMPLOYEE RELATIONS Non-discrimination a) DKI Plast shall not deny employees opportunities or otherwise discriminate employees based on race, gender, age, religious or political beliefs, or maternity status. b) DKI Plast shall base decisions concerning hiring, salary, benefits, advancement, termination or retirement solely on the employee s ability to do the job, with no distinction, exclusion or preference made on other grounds. c) DKI Plast shall respect all relevant employment laws and regulations in the countries in which they operate. Freedom of Association a) DKI Plast shall respect the freedom of the employees to join associations of their own choice without fear of reprisal this does, however, not mean that the employees must be organized. Compulsory Labour a) DKI Plast shall not use work or services that are extracted from any person under menace of any penalty, and for which that person has not offered himself or herself voluntarily e.g. slavery, bonded labour, debt bondage, or other exploitative practices. b) DKI Plast shall inform all employees of the terms and conditions of service and the voluntary nature of employment, and the freedom to leave in a customary way in the respective country. Working Terms a) DKI Plast shall ensure that the working hours of the employees are in compliance with legally set working hours in the countries in which DKI Plast is operating. b) While it is essential for DKI Plast to have flexibility in the organization and in the scheduling of work, DKI Plast will not force the employees to excessive overtime. c) DKI Plast shall allow employees at least one day off in seven. 4./8

5 d) DKI Plast shall provide wages and benefits in such a way that they are not less than the minimum wages set by applicable law and match the prevailing local industry practices. CHILD LABOUR a) DKI Plast respects the legal requirements for the employment of minors. DKI Plast due to the scope of it s activities employ only workers older than 18 years. b) DKI Plast will ensure that the UN Convention on the Rights of the Child is respected. c) The minimum age limit accepted by DKI Plast is 18 years. TRAINING AND EDUCATION a) DKI Plast operates a system of continuous training from the first introduction throughout the employee s life with the company. b) DKI Plast believes that training and education of the employees enable the employees to obtain skills and expert knowledge and develop the employees competences and opportunities required to match future challenges. c) Training and education also help prevent and minimize the risk of accidents. DKI Plast will therefore offer the necessary training and education of the employees. d) Training and education shall ensure that the employees are familiar with the core values of DKI Plast. 5./8

6 HEALTH AND SAFETY a) DKI Plast works hard to prevent accidents at work. While accidents are difficult to avoid altogether, it is important that DKI Plast company makes every effort to avoid accidents and continue to improve the safety of the employees. b) DKI Plast will ensure that the efforts to improve the safety and the health of the employees as a minimum are in accordance with the local legislation and local culture. c) Where necessary, DKI Plast will provide instruction, training and supervision of work practices, handling of harmful substances, together with the application and use of techniques, such as ergonomics. d) DKI Plast will provide personal protective equipment to protect employees from any potential hazards. e) DKI Plast will ensure that adequate lighting, heating, ventilation and exhaust systems are installed at the workplace. f) DKI Plast will ensure that the procedures to deal with emergencies and accidents are widely known. g ) DKI Plast will provide medical and first aid services. h) DKI Plast will value suggestions for improvement of the safety of the employees. ENVIRONMENT a) DKI Plast aims to be a market leader in terms of environment performance in the plastic manufacturing industry. b) DKI Plast s business strategies and success must be based on environmental responsibility and sustainable development. This is done by reducing use of materials, energy resources and waste, prevention of pollution and, if possible, by recycling of waste from production units. c) DKI Plast wishes to minimize the use of chemical and harmful substances in connection with the manufacturing of products or parts of products. d) DKI Plast will strive to educate the employees so that they assist in environmental responsibility. e) DKI Plast will reward suggestions for improvement of practices and procedures which will be beneficial to the environment. ANTI-CORRUPTION DKI is committed to complying with anti-corruption laws that prohibit bribes, kickbacks, or other corrupt actions to obtain or retain business or obtain any improper advantage. All suppliers are expected to comply with applicable anti-corruption laws while conducting business on behalf of DKI. Suppliers are prohibited from directly or indirectly receiving or offering any form of bribe, kickback, or other corrupt payment, to or from any person or organization, including government agencies or officials, private companies or employees of those private companies. 6./8

7 GIFTS AND ENTERTAINMENT DKI Plast recognizes that it is customary for some of its suppliers, customers and other business associates to occasionally give small gifts or offer modest business entertainment to those with whom they do business. It is important, however, that these gifts and entertainment events do not affect an employee s business judgement, or give the apperance that judgement may be affected. When doing business with or conducting business on behalf of DKI Plast, Supplier may, for legitimate business purposes : offer gifts or entertainment to suppliers, customers or other business associates; or accept gifts or entertainment offered by suppliers, customers or other business associates, provided, however, that in each instance the gift or entertainment: is unsolicited is not a bribe, kickback or other illegal or illicit payment is not given in exchange for any consideration would not embarrass DKI Plast if disclosed publicly, and does not create the apperance (or any actual or implied obligation) that the gift giver is entitled to preferential treatment, an award of business, better prices or improved terms of sale. Any supplier that violates the provisions of this section when conducting business on behalf of DKI Plast risks immediate loss of all existing and future DKI Plast business. COMPLIANCE MONITORING The supplier will allow DKI Plast and or/any of its representatives or agent s access to its facilities and all relevant records associated with the products and services provided to DKI Plast. The supplier and DKI Plast will establish a mutually agreeable date and time for access. However, risks to DKI Plast s business may require immediate access to the products, services and associated records and supplier will accommodate DKI Plast s access as required. Supplier also agrees to cooperate with DKI Plast to investigate any allegations of wrongdoing, misconduct or corruption. APPLICATION TO SUBCONTRACTORS This code also applies to any subcontractor's to the supplier, providing goods or services to the supplier. The supplier code of conduct shall be cascaded down to all sub-tier contractors. The supplier is fully responsible for ensuring compliance by any such subcontractors as if it were the supplier itself. DKI Plast reserves the right to audit the suppliers subcontractors for compliance to DKI Plast s supplier code of conduct and supplier will accommodate DKI Plast s audit as required. 7./8

8 EVENT OF VIOLATION Supplier shall promptly report to DKI PLAST notice of known breach of this code and implement a corrective action plan to cure the non-compliance within a specified time period (furnished to DKI Plast in writing). If the supplier fails to meet the corrective action plan commitment, DKI Plast may terminate the business relationship, including suspending placement of future orders and potentially terminating current production. DKI Plast reserves the right to hold supplier responsible for reasonable costs of investigating non-compliance. 4. HOW DOES DKI PLAST ENSURE THE OBSERVANCE OF THE 11 COMMITMENTS? IV. HOW DOES ECCO ENSURE THE OBSERVANCE OF THE 10 COMMITMENTS? AUDITS a) DKI Plast carries out systematic audits in order to identify and improve processes and conditions, which are potentially harmful to our employees or to the environment. b) b) DKI Plast checks compliance with the Code of Conduct by audits. The purpose is to ensure further practical measures for the conservation of sustainable development. 8./8

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