GROUP POLICY Fiskars Code of Conduct Version history: Person responsible Päivi Timonen, General Counsel Owner Fiskars Ethics Advisory Group Framework 1.A Group Next Revision Date Code Policies Version Date Author Description Reviewed Date By Approved Date 2.0 1.3.2016 P. Bask Final 31.1.2016 K.Kauniskangas 4.2.2016 A/C By Fiskars Corporation Hämeentie 135 A, P.O. Box 130 FI-00561 Helsinki, Finland Tel +358 204 3910 www.fiskarsgroup.com
TABLE OF CONTENTS 1. General Principles... 3 2. Ownership... 3 3. Review and Approval Rules... 3 4. Communication... 3 5. Document s Location in the Policies and Instructions Framework... 3 6. Validity... 4 7. Conducting Our Business Responsibly... 4 7.1. Compliance With Laws and Regulations... 4 7.2. Valuing Fiskars People... 4 7.3. Fiskars Customers... 4 7.4. Clear and Precise Communication... 5 7.5. Maintaining Our Good Name... 5 7.6. Protection of Privacy... 6 7.7. Maintaining Competitive Advantage... 6 2
FISKARS CODE OF CONDUCT 1. General Principles This Code of Conduct (referred as Code ) demonstrates Fiskars commitment to conducting its business in an ethical and responsible manner. Conducting business in the right way is our way of doing business according to our values. There is no right way to do the wrong thing. This Code helps to translate Fiskars values into action. This Code applies to everyone within Fiskars, including employees, directors, officers, board members, consultants and other personnel working under Fiskars direction (referred to in this Code as Fiskars People ) and covers all Fiskars group companies worldwide. Fiskars People are expected to observe not only the letter, but also the spirit of the Code. Therefore all Fiskars People must be aware of, and conduct their activities in accordance with this Code and all supporting policies, even when the Code requires a higher standard of behaviour than is required by national law and local regulation. Fiskars also expects that all of its business partners should be governed by the same or similar principles stipulated in this Code. Fiskars expects all business partners ensure that those principles are communicated to their employees and sub-contractors. Fiskars Supplier Code of Conduct has been developed in order to communicate Fiskars ethical and sustainability expectations to our suppliers. 2. Ownership This Code is owned by Fiskars Ethics Advisory Group. Its composition and roles and responsibilities are defined in a charter. 3. Review and Approval Rules This Code and any material changes to it must be approved by Fiskars Board. 4. Communication Ethics Advisory Group is responsible for communicating this Code, as well as for giving training and other advice regarding the implementation of this Code. Appropriate and regular training on this Code will be provided to all relevant existing employees. Fiskars management s support in implementation is essential. 5. Document s Location in the Policies and Instructions Framework This Code s location in the framework is 1.A Global Policies. 3
6. Validity This Code will become valid on 1 March 2016. 7. Conducting Our Business Responsibly Fiskars is proud of its business heritage and believes that its excellent reputation contributes to its business success. Fiskars supports a culture of fairness, transparency, responsibility and integrity in all its business activities. To help Fiskars People understand their responsibilities, this Code outlines the following key ethical principles: 7.1. Compliance With Laws and Regulations Fiskars is committed to full compliance with all applicable laws and regulations of relevant countries. As a minimum, these include laws and regulations related to employee rights, securities markets, such as disclosure obligations and insider regulation, corporate governance, taxation, fair competition, export control, product safety and intellectual property. 7.2. Valuing Fiskars People Fiskars People are Fiskars most valuable asset. It is Fiskars responsibility to ensure that it provides a safe and sustainable working environment with fair terms of employment for all employees. Respect for people and protection of human rights is paramount. In particular, Fiskars is committed to: equal opportunity in all employment practices, policies and rules as well as treating all employees fairly and impartially based on competence, experience and performance, without regard to race, ethnicity, age, disability, gender or sexual orientation and/or any other characteristics protected by applicable law. ensuring high standards of Health and Safety management throughout all its operations worldwide, providing an inspiring working environment, where all Fiskars People are encouraged to engage in their own personal and professional development and growth, not allowing working conditions or treatment that contravene basic human rights and our zero tolerance for child labour, or are in conflict with laws and practices of relevant countries where these require a higher standard supporting and respecting the protection of internationally proclaimed human rights as defined in the United Nations Universal Declaration of Human Rights, including freedom of thought, opinion, expression, religion and to peaceful assembly, protecting Fiskars People; threats, intimidation and violence in the workplace will not be tolerated. 7.3. Fiskars Customers Fiskars customers range from individual shoppers at our stores and online, wholesale accounts, major hospitality and institutional customers, distributors and licensees. Fiskars is committed to ensuring that every customer can expect the highest quality of customer care and to be treated in a courteous and friendly manner. 4
7.4. Clear and Precise Communication It is a fundamental principle for Fiskars that all communication must adhere to all relevant legislation, regulations and standards and be undertaken in an open and objective manner. Fiskars is committed to ensuring that only true and correct information is communicated and that non-public information is not disclosed. Responsible and appropriate communication, made at the appropriate time, is essential to protect Fiskars reputation and its business. 7.5. Maintaining Our Good Name Fair Dealing Fiskars must not seek competitive advantages through illegal or unethical business practices. All of Fiskars People are expected to deal fairly with others. No one should take unfair advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. Free and Open Competition Fiskars embraces free and open competition. Competition law aims to protect free competition in the market, by regulating the relationships with business partners and competitors. Although there is no one uniform set of competition laws that apply in all countries, certain basic principles apply everywhere to prohibit collusive or unfair business behaviour that restricts free competition. Anti-Bribery and Corruption Corruption is the abuse of entrusted power for private gain. It is considered to be one of the biggest threats to market and social development. Corruption disrupts competitive markets, misallocates resources and can lead to violation of human rights. It undermines the rule of law and trust in business and its leaders. It is therefore Fiskars responsibility as a company and Fiskars People s responsibility as individuals who represent the company, to prevent corruption in all its forms, including bribery, facilitation payments and inappropriate gifts, hospitality and favours. Conflict of Interest Fiskars will not tolerate any situation where the personal activities and interests of Fiskars People conflict or appear to conflict with the best interests of Fiskars. This includes situations where an employee s judgment is likely or appears to be influenced by the possibility of personal financial gain or where an external engagement adversely impacts the individual s ability to fulfill his or her duties to Fiskars. Export Control Export controls and regulations restrict trade or export activities with certain countries, entities or individuals in order to put pressure on the targets to discourage them from violating international law or human rights, prevent proliferation of weapons of mass destruction and/or limit flows of weapons or goods that could be used for military purposes. Fiskars supports such objectives. 5
7.6. Protection of Privacy Fiskars respects, and is committed to, safeguarding the privacy of our customers as well as the privacy of Fiskars People. It is Fiskars policy to follow applicable laws and regulations governing privacy and data protection in all countries where Fiskars operates. 7.7. Maintaining Competitive Advantage Intangible Assets and Information Security Intellectual property refers to creations of the human mind that are protected by various national laws and international treaties, including copyrights, patents, trademarks, trade secrets, designs, logos, know-how and other intangible industrial or commercial property. Fiskars intellectual property is among its most valuable assets. Fiskars is committed to safeguarding its trade secrets and intellectual property and defends any challenge, misuse or misappropriation of them vigorously. In the same way that Fiskars expects others to observe Fiskars rights, Fiskars is committed to avoiding unlicensed or unauthorised use or misappropriation of intellectual property that validly belongs to others. It is important to safeguard Fiskars confidential or business-critical information as any unauthorised use may seriously harm Fiskars business. Fiskars respects the trade secrets and intellectual property that suppliers, customers or other partners have entrusted to Fiskars for business purposes. It is the responsibility of Fiskars People to protect and maintain the confidentiality of such information. Tangible Assets Fiskars is committed to managing and safeguarding its assets no matter where they are located, stored, used or shown. All Fiskars People must protect company assets, such as equipment, inventory, supplies, cash and information, by treating company assets with the same care you would if they were your own. Company assets and resources may only be used to conduct company business. Fiskars People must not use company assets other than for legitimate business or other authorised purposes. THIS CODE OF CONDUCT PROVIDES AN INTRODUCTION TO FISKARS WAY OF DOING BUSINESS AND THE RESPONSIBILITIES OF FISKARS PEOPLE. READING THE CODE OF CONDUCT SHOULD HELP YOU TO RECOGNISE THE RIGHT THING TO DO. IF IN DOUBT, ASK BEFORE YOU ACT. IF YOU THINK THERE HAS BEEN A VIOLATION OF THIS CODE YOU MUST REPORT IT WITHOUT DELAY. For additional information and advice please contact: Your manager, HR, Corporate Compliance Officer or Legal Department 6