HAKI Group Code Of Conduct

HAKI's code of conduct provides guidance on how our principles and values should be put into practice.  It acts as an ethical compass to be followed by all staff within the HAKI GROUP, irrespective of workplace and function.  The code of conduct applies to HAKI's Board members and contract-based staff as well.  The code also sets out what we expect of our suppliers.  Our code of conduct is based on documents such as the UN Global Compact, international guidelines and conventions, and the IS026000 social responsibility standard.  

We respect human rights:  

1. We treat all people with fairness, dignity and respect.  
2. We support and encourage diversity.  
3. We do not treat employees differently based on their gender, religion, age, disability, sexual orientation, nationality, political views, social background or ethnic origin.  
4. We respect the right of all employees to form unions.  
5. We do not harass, threaten or discriminate.  
6. We do not tolerate child labour, illegal labour or forced labour.  

We create good working conditions:  

1. We aim to eradicate occupational accidents and do not compromise on health and safety in the workplace.  
2. We take a preventive approach to reduce the risk of accidents and industrial injuries.  
3. We offer staff opportunities to develop professional skills and abilities.  
4. All production units have the ISO 45001 work environment standard as a guideline.  

We are an active corporate citizen:  

1. We are involved in the local communities where HAKI has operations and endeavor to employ and develop local staff and managers.  
2. We participate in projects and cooperation with industrial networks, schools, technical colleges, universities and research institutes.  
3. We prioritise the support and sponsorship of organisations that share our values and that benefit the societies in which we operate.  
4. We take a neutral position on political issues. Neither the company's name nor its financial resources may be used for political purposes.  

We adhere to good business ethic:  

1. We never offer gifts, benefits or payments that could influence/be seen to influence the objectivity of the recipients' decisions or that breach legislation and/or local practice.
2. We do not accept gifts, benefits or payments that could influence/be seen to influence, the objectivity of our decisions or that breach legislation and/or local practice.  
3. The following types of benefits are unacceptable:
   1. money gift and loan of money
   2. goods and services for private purposes and private discounts on goods and services
   3. right to use a vehicle, boat, holiday house or similar for private use,
   4. pleasure- or holiday trip, purchase of sexual services or visits to strip clubs,
   5. perks that may result in the donor receiving a hold on the recipient.
4. We avoid situations in which company loyalty could come into conflict with personal interests.  
5. We comply with competition law and promote fair competition.  
6. We ensure that all staff can raise concerns about irregularities within HAKI, without the risk of personal consequences for whistleblowers.  

We address sustainability issues:

1. We work towards long-term goals to reduce the company's environmental impact.  
2. We conserve energy, water and materials and other natural resources and aim to increase our use of renewable materials.  
3. We take account of environmental and health factors when choosing raw materials, chemical products and distribution methods.  
4. We endeavor to cut our emissions of greenhouse gases.  
5. We have sound emergency procedures based on the systematic evaluation of the risk of accidents, fires and uncontrolled emissions to the environment.  
6. We use our expertise to provide eco-optimisation of customers' products.  
7. We disclose transparent and objective information about our environmental work to our staff, the general public and authorities.  
8. We publish a sustainability report annually in accordance with internationally accepted guidelines.  
9. All production units have the ISO I4001 environmental management standard as a guideline.    

We aim to always deliver the right quality:  

1. We aim to always meet our customers' exacting requirements, needs and expectations by delivering services and products of the right quality.  
2. We are continually improving our operations.  
3. We conduct regular evaluations of our quality assurance measures through analysis, recording of discrepancies and internal/external audits.  
4. Production units in Sweden are certified in accordance with the IS0 9001:2015 quality assurance system and applicable sector-specific certifications. Other productions units are controlled by internal audits.  

We set sustainability requirements for our suppliers: 

1. We work with suppliers that accept and comply with HAKI's code of conduct. We also expect them to pass these values and ethical principles on to their suppliers.  
2. We assess suppliers prior to and during our cooperation with them.  
3. We encourage our suppliers to introduce certifiable management systems on quality, the environment and work environment.  
4. We regularly follow up supplier performance within business ethics, social responsibility and sustainability. If they do not comply with our requirements this can result in demands for improvement or cessation of cooperation.  

We communicate honestly and clearly:

1. HAKI's communication with all stakeholders should be honest and clear. Our aim is for effective communication to promote HAKI's business and fulfil the requirements of our public stock listing.  
2. We respect all employees' freedom of expression about matters that concern them personally. On issues regarding HAKI's business conditions and operations, however, only the respective company management are entitled to communicate on behalf of HAKI. All inquiries about HAKI's business conditions and operations must therefore be referred to local company management or Group management. All external information that could affect the development of HAKI's share price must be communicated by either the CEO or the CFO.  

We raise concerns about serious irregularities through whistleblowing procedures:  

1. All staff have the opportunity to raise concerns about serious irregularities, without the risk of harassment or opposition, using HAKI's whistleblowing system.  
2. Serious irregularities include unethical or illegal behavior, fraud and serious breaches of the code of conduct, such as bribery or discrimination against employees.  
3. Whistleblowing must not be used for general dissatisfaction or other matters that can be resolved in direct contact with the relevant persons. False accusations are not tolerated and may result in disciplinary action. 

4. Reasonable suspicion regarding gross irregularities can be reported anonymously and confidentially to Trumpet through Trumpet’s website, by telephone or by mail. Submissions can be made twenty-four (24) hours a day, seven (7) days a week, in both Swedish and English. A complaint made through Trumpet’s website, using any internet-enabled device, can be found on the Company’s website;
   https://www.midwayholding.se/visselblasning/  

   Alternatively, you can fill in the following web address into a web browser’s address bar: www.trumpet-whistleblowing.eu. Once you have accessed the web page, you need to log in to the whistleblower page, here you will be prompted to fill in the Company’s registration code: MIHWB

   A complaint made by telephone from within Sweden can be done by dialing: 020 – 10 30 91

   A complaint made by telephone from outside of Sweden can be done by dialing: +46 20 10 30 91

   Submissions by mail can be made by sending correspondence to the following address: Trumpet, Box 479, 201 24 Malmo, Sweden