Dear colleague,

Hallins has a reputation that has been shaped over a century. It is all of our responsibility to live up to that legacy and to build an even stronger future for our company.

You have the mandate and are encouraged to take your own initiatives, make decisions, and drive our business forward. The Code of Conduct is a tool that helps you determine what is right in various situations and act in a way that addresses both legal and ethical risks.

Read the Code of Conduct. Discuss with your manager and colleagues how it should be applied to your specific circumstances and work. Do not hesitate to seek help from our legal experts if there is something you do not understand or need clarification on. Speak up if you notice behavior that doesn’t seem right.

How each of us acts defines us as a company and how the world perceives us.

Why a Code of Conduct?

WITHIN THE HALLINS GROUP, WE WANT TO CONDUCT BUSINESS IN AN ETHICAL AND LEGAL MANNER.

It is the right way to conduct business. It builds trust with our customers and society at large, which strengthens our success as a company. It also helps us avoid situations that can lead to legal problems or harm our reputation. Our Code of Conduct clearly outlines expectations for how we conduct our business – not just in a few places, but wherever we operate. The Code of Conduct summarizes what we stand for and what we expect from you.

Success for the Customer

We exist for our customers, and we create value for them by involving them in our improvement of product and service offerings.

Commitment

We are attentive, humble, problem solvers, and encouraging.

Safety

We keep our promises, are helpful, treat each other with respect, and are honest.

Development

We dare to ask and be curious. We dare to try, evaluate, and redo.

Quality

We keep our promises, provide constructive feedback and praise, and include and communicate.

Are you a manager?

Act in accordance with our values and the Code of Conduct. Be a good role model through your own actions. Ensure that your team is familiar with the Code of Conduct and knows how to apply it. Encourage employees to contact you if they have any questions or concerns.

DOES THE CODE OF CONDUCT APPLY TO EVERYONE AT HALLINS?

Yes. The Code of Conduct applies to all locations where we operate and to all employees of Hallins, including full-time and part-time employees, consultants, temporary staff, management, and the board of directors of Hallins Group companies. You are responsible for following the Code of Conduct. Failure to do so may have consequences for both you and the company. It can lead to disciplinary actions, including the risk of termination and even legal action. The company may be fined, subject to legal processes or investigations, and its reputation may be damaged or negatively affected.

HOW SHOULD I USE THE CODE OF CONDUCT?

Read it to understand what is expected of you. Then use it as a reference if you need guidance in a specific area. You should also consult the company’s policy documents, resources, and procedures. They are intended to complement the Code of Conduct and provide additional guidance and information.

WHAT SHOULD I DO IF I CANNOT FIND THE ANSWER IN THE CODE OF CONDUCT?

The Code of Conduct contains rules and principles for how we conduct our business. However, it cannot describe every actual situation that may arise, and sometimes the right answer may not be obvious. If you ever hesitate about how to act, ask yourself these questions:

Does it violate the law?

Is it unethical?

Could it harm Hallins’ reputation worldwide?

Would it feel uncomfortable to read about it in the media?

If the answer is yes, pause and contact your manager, who can help you find a way to handle the situation.

WHAT IF THE CODE OF CONDUCT CONFLICTS WITH LOCAL LEGISLATION?

We want to conduct all of our business in accordance with the Code of Conduct. However, nothing in the Code of Conduct should be seen as an encouragement to violate the law.

We Respect Each Other

Mutual Respect

At Hallins, we take pride in our inclusive work environment that promotes a supportive atmosphere and encourages individual development and strong teams. Unwanted behavior that creates a hostile, offensive, or hostile work environment has no place here. Instead, we encourage and expect mutual respect, both among employees and between our company and our business partners.

For you, this means:

Treat all individuals with respect.

Never bully, intimidate, or threaten another person.

Avoid behavior that someone else could reasonably perceive as offensive or inappropriate.

Stand up against harassment and other inappropriate behavior, whether directed at you or someone else.

Against Discrimination

At Hallins, we value diversity among employees and expect hiring managers to comply with applicable anti-discrimination laws. Employment-related decisions such as hiring, compensation, position, promotion, disciplinary actions, termination, and working conditions should be based on individuals’ abilities or performances, not irrelevant personal factors.

For you, this means:

Do not discriminate. Instead, assess applicants based on their talent, skills, and experience.

Please report if you encounter discrimination or believe you have been subjected to unfair discrimination.

WORKING FOR DIVERSITY AND INCLUSION…

… builds trust by rewarding individuals based on their contributions and reinforces a respectful atmosphere.

… contributes to our performance by ensuring that we attract and employ the best, most qualified individuals.

… enhances our work environment by helping us bring out the best in people.

SAFE AND HEALTHY WORK ENVIRONMENT

We believe that accidents, incidents, personal injuries, near-misses, work-related illnesses, and unsafe conditions can often be prevented. By prioritizing safety requirements in planning and operations, we ensure that our work environment complies with applicable laws and health and safety standards.

For you, this means:

Take responsibility for your own and others’ safety – address or report risks and identify behaviors that pose safety risks.

Be aware of and follow all safety requirements, including the use of personal protective equipment. Never take shortcuts or disregard prescribed safety procedures.

If you are a manager, ensure that employees have the proper training and equipment for their work.

Do not use or possess illegal drugs at work. Do not work while intoxicated or under the influence of drugs or alcohol.

COMPLIANCE WITH ENVIRONMENTAL REQUIREMENTS

At Hallins, we ensure that our operations comply with applicable environmental protection legislation and internal requirements.

For you, this means:

Follow the environmental protection laws and requirements within the company that apply to your work.

Take all necessary precautions when handling or transporting hazardous materials, parts, or waste, including loading, unloading, and storage. If you are unsure of the requirements, consult your supervisor for guidance.

Use and dispose of chemicals and other materials properly and report any spills, emissions, or other environmental issues.

FREEDOM OF ASSOCIATION

At Hallins, we respect all employees’ right to form and be members of a trade union to represent their interests as employees, organize collectively or individually. We also respect all employees’ right to refrain from joining a union.

For you, this means:

You have the right to seek guidance and support in all employment-related matters from recognized trade unions and workers’ representative organizations.

If you are a manager, do not interfere in employees’ decisions regarding union representation or membership.

WORKING HOURS AND COMPENSATION

At Hallins, we follow applicable laws and agreements regarding working hours, rest, compensation, and benefits.

For you, this means:

The terms and conditions of your employment, including your rights and responsibilities, should be presented clearly to you.

Your working hours should not exceed the allowable maximum, and you should receive statutory rest periods.

Your employment and compensation terms should meet applicable minimum wage requirements as per the law and collective agreements.

MODERN SLAVERY AND CHILD LABOUR

At Hallins, we do not tolerate any forms of modern slavery, such as forced labour, debt bondage, and human trafficking. We respect children’s right to personal development and education and do not engage in child labor.

For you, this means:

Ensure that we do not engage in or support modern slavery, whether within our organization, with our suppliers, or other business partners. If you are a manager, ensure that employees have voluntarily chosen their work and have the right to leave their employment according to applicable employment terms and laws.

When hiring, follow the minimum age for employment in your country. Never employ children under 15 years old, even if it is allowed by local legislation.

Do not assign young workers (ages 15–18) to tasks that are hazardous or pose risks to their personal development, physical or mental health.

We conduct business responsibly and lawfully.

COMPLIANCE WITH PRODUCT-RELATED REQUIREMENTS

Hallins’ products are designed, manufactured, marketed, and sold to comply with applicable legal requirements and internal quality and safety standards. Compliance is crucial for building trust in our products, leading to our success and that of our customers.

For you, this means:

Follow all legal and regulatory requirements, including emissions, safety, hazardous materials, and parts, as well as noise standards.

If you design new products or modify existing ones, ensure they meet the regulatory and legal requirements at the time of product launch and thereafter.

Do not manipulate tests or test results.

THIS IS IMPORTANT

Sometimes, market demands may conflict with our obligations under applicable laws.

In such situations, we must continue to comply with all legal requirements related to the design, manufacturing, sale, performance, and marketing of our products and services, even if there is a chance that these requirements may be discovered by authorities or management.

Do not take shortcuts or make decisions that could compromise compliance with product-related requirements, regardless of the likelihood of detection by authorities or management.

Present our products and services accurately. Ensure that all statements are well-founded and do not provide misleading information, especially regarding safety and environmental characteristics.

FAIR COMPETITION

We believe that our products and services can succeed in a competitive market, and fair competition benefits us. We compete based on the merits of our products and services and do not engage in anticompetitive practices, such as secret agreements with competitors. We treat our suppliers professionally and select them based on objective criteria. Since this is a complex area, it is important to know what is required and consult with your immediate supervisor when in doubt.

For you, this means:

Use only legal methods to gather information about competitors.

Do not enter into agreements with competitors on important matters such as price fixing, market division, or customer allocation.

Follow Hallins’ policies and procedures if you participate in activities involving contact with competitors, such as industry organization meetings, research and development consortia, or industry standardization work. Obtain all necessary approvals before participating in such activities.

Do not independently decide to exchange commercially sensitive information with competitors.

Unless otherwise specified in Hallins’ policies and procedures, do not control or restrict prices or terms for our products set by independent resellers, suppliers, or customers.

ANTI-CORRUPTION, INCLUDING GIFTS AND ENTERTAINMENT

Bribery and corruption distort the market, disrupt free competition, and violate laws that can have significant consequences for affected companies and individuals. Hallins does not engage in, and does not support, corrupt activities, such as offering or receiving kickbacks, bribes, gifts, or entertainment considered excessive, or so-called “grease payments,” either directly or indirectly through a third party. We do not accept suppliers or partners who offer bribes, and we will take necessary action if such behavior is discovered.

For you, this means:

Learn Hallins’ rules for gifts and entertainment and ensure you have legitimate business reasons for anything you offer.

Do not offer or accept bribes or anything that can be perceived as a bribe, including cash, gift cards, or anything equivalent to cash, job offers, services, travel, promises of debt repayment, or gifts and entertainment that violate the law.

Do not use business partners or any other third party to pay bribes.

Find out what is permissible if you come into contact with government officials in your work, and be aware that the rules are usually very strict.

Record all payments and transactions accurately in Hallins’ accounting and documentation.

Conduct necessary reviews from a corruption perspective when hiring or dealing with intermediaries.

Never accept anything from a supplier, business partner, or anyone else that could affect or appear to affect your ability to remain objective when making business decisions.

If a supplier or business partner offers you inappropriate gifts and entertainment, discuss it with your manager.

COMPLIANCE WITH TRADE RULES (EXPORT AND IMPORT)

As a global company, we must comply with international trade rules. These rules are used by countries to regulate the movement of products, technology, software, and technical information across national borders. Violations of these rules can lead to charges against responsible companies and individuals. It can also result in negative publicity, delayed deliveries, or even the loss of import/export permits.

For you, this means:

Investigate export permit requirements before exporting a product or sharing technical information or software across national borders.

Follow our procedures for conducting background checks on certain business partners, including distributors, importers, retailers, and customers, as we may be prevented from doing business with parties subject to sanctions.

Ensure that you are aware of and comply with the trade restrictions in the markets where you do business. These can be complex, as rules may vary between different markets and may change in response to global events.

Follow all customs and export control-related requirements, such as documentation regarding classification, value/price, and country of origin.

If you are unsure, contact the export control team, marketing group, or your immediate supervisor.

ANTI-MONEY LAUNDERING

Money laundering enables criminals and others to conceal the source of funds obtained illegally. These funds may come from or support activities such as human trafficking, drug trafficking, terrorism, extortion, or fraud. Hallins does not participate in and does not support money laundering.

For you, this means:

Get to know your customer, make sure you understand the terms of all transactions, and be vigilant for signs of money laundering.

Report all suspicious transactions to the company, including third-party payments, large-scale purchases made with cash or other liquid assets.

We distinguish between personal interests and company interests.

CONFLICTS OF INTEREST

As employees of Hallins, we have a duty to act in the best interests of the company and to avoid or disclose situations where our personal, financial, or other external interests conflict with our job duties. In some cases, even the appearance of a conflict can harm our reputation or effectiveness.

For you, this means:

Ensure that you know how to recognize conflicts of interest. If you face a conflict, discuss it with your supervisor and work with the company to resolve the issue.

Make business decisions in the company’s interest and not to benefit yourself or your family. Potential conflicts that must be disclosed may include:

– Having a close relationship with someone you supervise or may hire

– Engaging in a side business that does business with Hallins

– Taking a job with a supplier, other business partner, or competitor, especially if you work full-time for a Hallins company

– Having a family member employed by a current or potential customer, supplier, or competitor, especially in a key role involving decision-making

– You or a family member having a significant financial investment in a current or potential customer, supplier, or competitor

Do not arrange personal transactions with suppliers or customers on terms that are not accessible to the public, such as special pricing, financing, or discounts.

POLITICAL ENGAGEMENT

For Hallins, it is important to maintain an ongoing dialogue with government authorities and decision-makers to participate in discussions that may affect Hallins and our customers’ business and operations.

Hallins takes a neutral stance regarding political parties and candidates for public office. Neither the names of Hallins Group companies nor their resources should be used to promote the interests of political parties or individuals running for public office.

For you, this means:

You may support causes of your choice, but do not make political or charitable donations with company funds or in the company’s name.

You can contribute your own time and resources, but do not use work hours, company property, or other company resources to promote your own political interests.

You may raise funds for political causes or support political candidates, but do not do so during work hours.

INSIDER TRADING

During your employment at Hallins, you may have access to insider information concerning the company, customers, or suppliers. When you have access to insider information, specific statutory and regulatory obligations apply. Violations of these obligations may constitute a criminal offense and lead to prosecution.

For you, this means:

Do not use insider information, whether directly or indirectly, for your own or anyone else’s benefit, to buy or sell stocks or related securities (insider trading).

Do not recommend or induce anyone else to engage in insider trading.

Do not disclose any insider information without proper authorization.

Follow our procedures for internally reporting insider information and accidental disclosures.

We protect the company’s information and assets.

CONFIDENTIAL INFORMATION

We all have a duty to protect information that Hallins considers confidential. Theft, unauthorized use, or disclosure can cause significant harm to our business. This includes all information that we have not publicly disclosed about our processes, products, innovations, financial or strategic plans, or our position.

For you, this means:

Ensure that you have authorization and a legitimate business purpose before disclosing confidential information to anyone outside the company.

Never post the company’s confidential information on social media. Do not discuss confidential information in public places, and never leave confidential materials unattended, even in the office.

Protect the confidential information provided by suppliers, business partners, and others.

Remember that your obligation to protect confidential information may continue even after you have left the company.

INTELLECTUAL PROPERTY

Hallins’ intellectual property, such as technical inventions, patents, copyrights, know-how, trade secrets, design rights, trademarks, and related licenses, is highly valuable. However, this value can be lost or compromised if this property is abused or disclosed improperly. Hallins will take measures to protect its intellectual property and has a policy to respect the intellectual property of others.

For you, this means:

Be careful to protect all of Hallins’ trade secrets, inventions, and design rights and do not disclose or publish them unless you have specific authorization to do so.

Respect and do not use materials that constitute the intellectual property of others without permission from Hallins and the third party.

If you have access to confidential information or intellectual property, you should handle it correctly, protect it from unauthorized disclosure, and only use it in an authorized manner. If the information belongs to a third party, you should comply with all agreements with that party, including agreements on use and disclosure.

Report any suspected or alleged unauthorized use of intellectual assets belonging to Hallins or a third party in accordance with Hallins guidelines.

PHYSICAL AND FINANCIAL ASSETS

Hallins assets, including financial assets, physical property, and company equipment, systems, and networks, are critical to our ongoing productivity and company success. We must use these assets responsibly and protect them from theft, negligence, and waste, whether it involves securing access to the company’s buildings, equipment, and tools or exercising good judgment in the use of company resources.

For you, this means:

Do not use company assets, such as equipment and funds, for personal benefit or for the benefit of any other individual.

Follow local procedures and guidelines for expense reporting, and do not report personal expenses as company expenses.

Report all theft and misuse of the company’s inventory, cash, equipment, materials, and other assets.

THIS IS IMPORTANT

Private use of Hallins IT resources should be kept to a minimum. If you use the company’s IT resources for personal use, your right to privacy may be limited.

To prevent abuse and illegal activities, Hallins monitors IT activity and may install monitoring software, including software against child pornography, as well as web and spam filters.

PROTECTION OF PERSONAL DATA

When entrusted with personal data, we handle it responsibly and take appropriate measures to prevent unauthorized use. We comply with all applicable data protection laws when collecting, using, and sharing individuals’ personal data.

For you, this means:

Follow the company’s guidelines when collecting, storing, using, or sharing individuals’ personal data.

Do not access personal data stored in our systems unless for business-related reasons that correspond to the purpose for which the data was collected.

Notify your manager if you have access to individuals’ personal data that you do not need.

We communicate openly and responsibly.

REPORTING AND DISCLOSURE

We aim to report openly and truthfully at the appropriate time to provide an accurate picture of Hallins’ results. We report financial transactions in accordance with generally accepted accounting principles. We truthfully report all non-financial information that we are obligated to disclose.

For you, this means:

Be honest and accurate when reporting or recording information about our business.

If you submit or approve expenses, ensure they accurately reflect the transaction and comply with company policies and procedures.

Never distort facts when recording a transaction and never provide information you know to be incorrect.

Report immediately if you notice an error in financial records or suspect fraud has occurred.

HOW DO I RAISE AN ISSUE?

You can:

Speak with your manager or your manager’s manager.

Speak with the relevant department, such as HR.

Speak with one of the employee representatives.

Write a letter to corporate management.

CAN I REPORT ANONYMOUSLY?

Yes, as long as anonymous reports are allowed under local law.

However, we encourage you to identify yourself when making complaints. This allows the company to gather all facts, conduct a thorough investigation of your report, and engage in confidential dialogue with you.

Even if you identify yourself, every effort will be made to keep your identity strictly confidential within the company.

WHAT HAPPENS WHEN I RAISE AN ISSUE?

When you make a report, company management will investigate the situation and take appropriate actions.

If you report an issue in good faith, company management will not tolerate any retaliation against you, regardless of the investigation’s outcome.

Hallins Group Code of Conduct