POLICY. Code of Conduct for Suppliers DUSTIN GROUP

POLICY Code of Conduct for Suppliers DUSTIN GROUP

of 6 Code of Conduct for Suppliers Introduction Dustin Group has adopted the principles stated in this Code of Conduct for Suppliers. Dustin is committed to creating value for our stakeholders and to contribute to improving living conditions for people and the environment. We realize the need to combine sound and profitable business operations with social and environmental responsibility. Based on this commitment, we have set up this policy to make our position clear to our different stakeholders. Dustin Group strives for long-term, good business relations and healthy cooperation with our suppliers. This policy applies to our suppliers of products and services, including direct suppliers, subsuppliers, producers and business partners producing goods and services for Dustin Group. Dustin Group supports international standards in human rights, labour conditions, the environment and anticorruption and we expect our suppliers, including direct suppliers, sub-suppliers, producers and business partners, to align their operations with principles that are in accordance with this policy we consider this as a non-negotiable criterion when establishing or continuing our business relations. Dustin Group Code of Conduct for Suppliers is based on international conventions such as the Universal Declaration of Human Rights, the Children s Rights and Business Principles, UN Guiding Principles for Business and Human Rights, OECD Guidelines for Multinational Enterprises, UN Global Compact and International Labour Organization (ILO) Conventions and Recommendations relevant to improve working conditions in the supply chain. Dustin Group will work, together with our suppliers, to secure that the above-mentioned international framework is respected and to contribute to improved conditions for people and the environment. Principles We expect our suppliers to follow Dustin Group Code of Conduct for Suppliers. Our suppliers are also required to ensure that all of their suppliers, sub-suppliers, producers and business partners, involved in the manufacturing of goods and services for Dustin Group follow this policy. 1. Legal requirements Dustin Group s general rule is that our suppliers must, in all their activities, follow the national laws in the countries in which they operate. Should any requirements in this Code conflict with the national law in any country or territory, the law must always be followed. In any such case, the supplier must notify Dustin Group immediately. Dustin Group s requirements may exceed the requirements set out in national law. 2. The rights of Freedom of Association and Collective Bargaining Our suppliers shall respect the right of workers to form unions in a free and democratic way, not to discriminate against workers because of trade union membership and to respect workers right to bargain collectively. Suppliers shall not prevent workers representatives from having access to workers in the workplace or from interacting with them. When operating in countries where trade union activity is unlawful or where free and democratic trade union activity is not allowed, suppliers shall respect this principle by allowing workers to freely elect their own representatives with whom the company can enter into dialogue about workplace issues.

of 6 3. No Discrimination Suppliers shall not discriminate, exclude or have a certain preference for persons on the basis of gender, age, religion, race, birth, social background, disability, ethnic and national origin, nationality, membership in unions or any other legitimated organizations, political affiliation or opinions, sexual orientation, family responsibilities, marital status or any other condition that could give rise to discrimination. In particular, workers shall not be harassed or disciplined on any of the grounds listed above. 4. Fair Remuneration Suppliers shall respect the right of the workers to receive fair remuneration that is sufficient to provide a decent living for themselves and their families, as well as the social benefits legally granted. Suppliers shall comply, as a minimum, with wages mandated by governments minimum wage legislation, or industry standards approved on the basis of collective bargaining, whichever is higher. Wages shall be paid in a timely manner, regularly, and fully in legal tender. Partial payment in the form of allowance in kind may be accepted pursuant to the specific provisions set out in ILO nr 95. The level of wages shall reflect the skills and education of workers and shall refer to regular working hours. Deductions will be permitted only under the conditions and to the extent prescribed by law or fixed by collective agreement. 5. Decent Working Hours Suppliers shall ensure that workers are not required to work more than 48 regular hours per week. Some exceptions, specified by the ILO (ILO nr 1), can be recognized. Applicable national laws, industry benchmark standards or collective agreements shall be interpreted within the international framework set out by the ILO. In exceptional cases defined by the ILO, the limit of hours of work prescribed above may be exceeded, in which case overtime is permitted. The use of overtime is meant to be exceptional, voluntary, paid at a premium rate of not less than one and one-quarter times the regular rate and shall not represent a significantly higher likelihood of occupational hazards. Furthermore, suppliers shall grant their workers the right to resting breaks in every working day and the right to at least one day off per week (seven day period). 6. Occupational Health and Safety Suppliers shall respect the right to healthy working and living conditions of workers and local communities. Vulnerable individuals, such as young workers, new and expecting mothers and persons with disabilities, shall receive special protection and consideration. The workers should be granted sick leave without any form of repercussions. Workers should be given their stipulated parental leave in case of pregnancy. Dismissal of pregnant female workers is not acceptable. Suppliers shall comply with occupational health and safety regulations, or with international standards where domestic legislation is weak or poorly enforced. The active co-operation between management and workers, and/or their representatives is essential in order to develop and implement systems that ensure a safe and healthy work environment. This can be achieved through the establishment of occupational health and safety committees.

of 6 Suppliers shall ensure that there are systems in place to detect, assess, avoid and respond to potential threats to the health and safety of workers. They shall take effective measures to prevent workers from having work related accidents, injuries or illnesses. These measures should aim at minimizing the causes of hazards within the workplace. Suppliers shall strive to improve workers protection in case of accident including through mandatory insurance schemes. The worker s safety shall be a priority at all times. No hazardous equipment or unsafe buildings are accepted. Suppliers shall take appropriate measures, to see to the stability and safety of the equipment and buildings they use, as well as to protect against any foreseeable emergency. The factories shall have clearly marked exits and preferably emergency exits on all floors. All exit doors shall open outwards. Exits shall not be blocked and shall be well lit. If emergency exits are locked, the keys shall be placed so that they are available to all staff at all times. Suppliers shall respect the workers right to exit the premises from imminent danger without seeking permission. All workers shall be made aware of the safety arrangements, such as emergency exits, fire extinguishers, first aid equipment, etc. An evacuation plan shall be displayed in the factory, the fire alarm shall be tested regularly and regular evacuation drills are desirable. First aid equipment must be available in each factory and at least one person in each department shall have training in basic first aid. Suppliers shall also ensure adequate occupational medical assistance (in particular, medical assistance should be available at short notice in case of accidents) and related facilities, access to safe drinking water, safe and clean eating and resting areas as well as clean and safe cooking and food storage areas. Furthermore suppliers shall always provide effective personal protective equipment to all workers free of charge and to ensure that they are used in a proper way. 7. Conditions of Residential Facilities If a factory provides residential facilities to workers, the requirements regarding safety, etc. set out in section 6 above shall also cover such residential areas. All workers must be provided with their own individual bed and the living space per worker must meet the minimum legal requirement. Separate dormitories, toilets and showers shall be provided for men and women. There shall be no restriction on the worker s right to leave the residential facility during off hours. 8. No Child Labour Dustin Group prohibits child labour. Suppliers shall ensure not to employ, directly or indirectly, children below the minimum age of completion of compulsory schooling as defined by law, which shall not be less than 15 years, unless the exceptions recognized by the ILO apply (ILO nr. 138). Suppliers must establish reliable and effective age-verification mechanisms as part of the recruitment process, which may not be in any way degrading or disrespectful to the worker. This principle aims to protect children from any form of exploitation. Special care shall be taken on the occasion of the dismissal of children, as they can move into more hazardous employment. In removing children from

of 6 the workplace, suppliers shall identify measures to ensure the protection of affected children and to cooperate with local NGOs to find the best solution for the child. Any measures taken shall always aim to improve, not worsen, each individual child s situation. Any costs for education, etc. shall be paid by the factory. The supplier shall inform Dustin Group in writing of its discussions with local NGO s and any measures taken in respect of each individual child. Special Protection for Young Workers Dustin Group requires that suppliers shall ensure that young workers (a child who is above the minimum working age described above up to 18 years of age and engaged in economic activity) do not work at night and that they are protected against conditions of work which could be harmful to their health, safety, well being and development. Where young workers are employed, suppliers shall ensure that the kind of work is not likely to be harmful to their health, safety, well-being and development, their working hours do not reduce their attendance at school, their participation in vocational orientation approved by the competent authority or their capacity to benefit from training or instruction programs. Suppliers shall ensure the necessary mechanisms to prevent, identify and mitigate harm to young workers; with special attention to the access young workers shall have to effective grievance mechanisms and to occupational health and safety trainings schemes and programs. 9. No Precarious Employment Suppliers shall ensure that their employment relationships do not cause insecurity and social or economic vulnerability for their workers and that work is performed on the basis of a recognized and documented employment relationship, established in compliance with national legislation, custom or practice and international labour standards, whichever provides greater protection. Suppliers shall provide workers, before entering into employment, with understandable information about their rights, responsibilities and employment conditions, including working hours, remuneration and terms of payment. Suppliers shall provide decent working conditions that also support workers in their roles as parents or caregivers, especially with regard to migrant and seasonal workers whose children may be left in the migrants hometowns. Suppliers shall not use employment arrangements in a way that deliberately does not correspond to the genuine purpose of the law. This includes apprenticeship schemes where there is no intent to impart skills or provide regular employment, seasonality or contingency work when used to undermine workers protection, and labour-only contracting. Also, the use of sub-contracting may not serve to undermine the rights of workers. 10. No Bonded Labour Suppliers shall not engage in any form of servitude, forced, bonded, indentured, trafficked or nonvoluntary labour. Suppliers can risk allegations of complicity if they benefit from the use of such forms of labour among their sub suppliers or business partners. Suppliers shall act with special diligence when engaging and recruiting migrant workers both directly and indirectly. Suppliers shall allow their workers the right to leave work and freely terminate their employment

of 6 provided that workers give reasonable notice to the employer. Suppliers shall also ensure that workers are not subject to inhumane or degrading treatment, corporal punishment, mental or physical coercion and/or verbal abuse. All disciplinary procedures must be established in writing, and shall be explained verbally to workers in understandable terms. Dustin Group does not accept the use of disciplinary measures in the form of punishments or other forms of mental or physical disciplinary actions or sexual harassments. 11. Protection of the Environment Suppliers shall take necessary measures to avoid environmental degradation, shall assess significant environmental impact of operations and shall establish effective policies and procedures that reflect their environmental responsibility. Suppliers shall also implement adequate measures to prevent or minimize adverse effects on the community, natural resources and the environment. 12. Conflict minerals Suppliers must develop policies toward preventing the use of conflict minerals or derivative metals sourced from mines controlled by armed groups in all items to be supplied to Dustin Group. In addition, all suppliers must document their efforts to determine the source of any conflict minerals or derivatives and, on request, be able to provide Dustin Group with information of the origin of the metals tantalum, tin, tungsten and gold in products to be supplied to Dustin Group. Any smelters producing tantalum, tin, tungsten or gold metals subsequently used in products delivered to Dustin are requested to seek and obtain certification through the EICC/GeSI Conflict Free Smelter (CFS) program. 13. Ethical Business Behaviour Dustin Group does not accept any fraudulent behavior, bribery or corruption. Suppliers shall not, whether directly or indirectly, participate in any act of extortion or embezzlement, or in any form of bribery or corruption including promising, offering, giving or accepting of any undue benefit to induce or reward an improper conduct to gain any commercial, contractual, regulatory or personal advantage. A benefit could include, but is not limited to, gift, loan, money, fee, reward, journey, service, bonus, voucher of any kind, order samples for personal use or employment contract. Suppliers are expected to keep accurate records regarding their activities, structure and performance, and should disclose these in accordance with applicable regulations and industry benchmark practices. Suppliers shall also use and process personal information with reasonable care. The collection, use and other processing of personal information shall comply with privacy and information security laws and regulatory requirements. Guidance, Compliance and Reporting Dustin Group s purchasing organization is responsible for implementing and monitoring our suppliers compliance of Dustin Group s Code of Conduct for Suppliers. Any known or suspected non-compliance with this policy must be reported, acted on and followed up. All suppliers are obliged to always keep Dustin Group informed about where each order is being produced. In order to ensure compliance of this policy, Dustin reserves the right to carry out unannounced inspections of any factory producing goods or services for Dustin Group, at any time. Inspections can also be made by an independent third party of Dustin Group s choice. The supplier or manufacturer shall on request provide all appropriate records and documentation needed to follow up the compliance of the Code.

of 6 If a supplier fail to correct any deviations to the Code in accordance to the corrective action plan, following the agreed time frame, Dustin Group will stop purchasing until the matter is resolved or will terminate the business relationship. In the event of repeated violations, Dustin Group will immediately terminate the business relationship and cancel our existing orders. Dustin Group encourages our employees and suppliers employees to report any known or suspected deviations from this policy by sending an email or letter, to the addresses listed below, To Head of Group Procurement and Products: Dustin Group AB Att: Robert Pap, Head of GroupProcurement and Products Box 1194 131 27 NACKA STRAND Sweden Email: robert.pap@dustin.se To the Head of Legal and Head of Reporting and Internal Control: Dustin Group AB Att: Sara Edlund, Head of Legal or Mikael Svensson, Head of Reporting and Internal Control Box 1194 131 27 NACKA STRAND Sweden Email: deviationreports@dustin.se Regardless of the reporting channel, all allegations of potential violations of the Code that are made in good faith will receive a swift, fair and comprehensive investigation conducted with the relevant internal and/or external assistance. There shall be no retaliation or other negative consequences for persons reporting in good faith. The information received will be managed according to the Swedish Data Inspection Board s guidelines regarding handling of sensitive information.