Code Of Conduct

Our vision is to provide leading technical solutions for a sustainable tomorrow. In order to live up to our vision, we need to constantly develop, but never by compromising on corporate responsibility. Our Code of Conduct summarises how we all should act in order to run our business in an ethically, socially and environmentally sound way. Addtech’s decentralised structure is based on freedom with responsibility. We provide a great deal of individual freedom, but we also set clear requirements. In the Code of Conduct we state the common ground of our corporate responsibility. With a common ground to stand on it will be easier for each and every one to take responsibility.

Niklas Stenberg President and CEO

About the Code of Conduct

The Code of Conduct, together with our core values (simplicity, efficiency, change, responsibility & freedom), is the basis of how we perform and act in our day-to-day work. The Code of Conduct summarises the ethical values that the Addtech Group (“Addtech”) believes must be key in our activities, providing a minimum level of acceptable behaviour and covering all employees of the Group. Addtech does not accept any actions that breach the Code of Conduct. The code is based on the UN’s Global Compact, the ILO’s core conventions, UN’s Universal Declaration of Human Rights and the OECD’s guidelines for multinational companies, competition legislation and anti-corruption regulations.

This Code of Conduct has been adopted by the Board of Directors of Addtech AB (publ) and any amendments or dispensations may only be executed by the Board.

3 February 2021, Stockholm

GENERAL PRINCIPLES

The business activities within our group are based on close, long-term relationships with customers, suppliers and other partners, and we strive to be perceived as a trustworthy, long-term and reliable partner. It is therefore essential that our business activities are run not only on the basis of business requirements, objectives and guidelines, but also that they meet high standards in terms of integrity and ethics. As a minimum, we must comply with applicable legislation and regulations in all countries where Group companies operate, and with existing Group policies. Addtech first and foremost chooses to collaborate with suppliers who share our principles. These are to be found in this Code of Conduct and in our Supplier Code of Conduct.

HUMAN RIGHTS

Anyone who works directly or indirectly for Addtech shall be entitled to have their basic human rights respected in accordance with the UN’s Universal Declaration of Human Rights.

Employment conditions

The employment conditions – including financial remuneration and work hours – that are offered to our employees must at least meet the minimum requirements of national legislation and collective agreements. All employees must be provided with their employment contract in writing and be informed of the conditions of employment. Salaries, work hours and conditions must be fair and reasonable.

Work environment

We strive to be a respected employer and to continuously improve health and safety in the workplace. We must ensure a good work environment from a physical, psychological and social point of view, and strive to be attractive employers with regard to employees’ personal development. All necessary safety measures must be taken, including providing appropriate safety equipment, training and information. The relationship with and between employees must be based on mutual respect. As a minimum, we shall strictly abide with national health and safety legislation as well as health and safety regulations in entered agreements and/or collective agreements.

Child labour

The UN Convention on the Rights of the Child, the ILO’s Minimum Age Convention (no. 138) concerning Minimum Age for Admission to Employment, and the ILO’s convention (no.182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour, are guidelines for all activities.

Disciplinary measures

Employees must be treated with dignity and respect. No employee may under any circumstances be subjected to corporal punishment or other forms of physical, sexual or psychological punitive action, harassment or force. Salary deductions may not be imposed as a disciplinary sanction, unless this is regulated by collective agreement or approved by law.

Freedom of association

Employees shall be free to exercise their legal right to be members of, organise or work for organisations that represent their interests as employees.

Equality, diversity and discrimination

We do not permit discrimination or harassment in any form. The Group’s employees shall be given the same opportunities for development regardless of gender, age, ethnic origin, religion, political views, sexual orientation, disability or other distinguishing features. In cases where there are inequalities in remuneration, for instance between men and women, we must strive actively to even these out. We also strive to achieve a more even gender balance and for equal rights to parental leave.

Forced labour

We do not accept forced labour, or involuntary or unremunerated work in any form. This includes contracts under forced conditions and illegal labour. Neither do we accept methods that restrict employees’ freedom of movement. No individual may be kept at work against their will.

Political involvement

We observe political neutrality. Neither the name Addtech, the name of a Group company, or any resource whatsoever under the Group companies’ control may be used to promote the interests of political parties or candidates.

BUSINESS ETHICS

Anti-corruption standards

We do not accept corruption, bribes or unfair anti-competitive practices. Procurement, sales and marketing of our products and services must be handled professionally and in line with relevant legislation and regulations.

We comply with applicable anti-corruption legislation and regulations.

Conditions for discounts, commission and bonuses must be reasonable and stated in writing.

We must not offer or give undue payments or other remuneration to any person or organisation in order to induce the person or organisation to establish or maintain a business relationship with our Group companies. We must not, directly or indirectly, request or accept any form of undue payment or other remuneration in order to induce the establishment or maintenance of a business relationship.

No employee may either give or receive gifts, remuneration, benefits or offers that may be considered to constitute an undue benefit. An undue benefit is one that may influence the recipient’s behaviour such that the person then acts in a disloyal or illegal manner towards their employer for their own gain.

Gifts to public agency employees or in connection with public procurements are never permitted. We shall not do business with customers or suppliers where we have reason to believe that they are in breach of our anti-corruption regulations.

Conflict zones

We must ensure that no business that we do in any way supports war, conflict, extremism, money laundering, drug trade or slave trade. This includes the use of conflict minerals.

The company’s property and resources

We respect other companies’ assets, and protect our tangible and intangible assets from loss, theft or infringement. Addtech’s property and resources may not be used for personal gain, towards fraudulent purposes or in any other improper manner.

Customers and suppliers

We strive to provide products and services that meet or exceed our customers’ expectations. We base our relationships with business partners on sound business and market practices, a high standard of ethics, and agreements that are clear and fair.

Impartiality and conflicts of interest

Addtech’s business relationships shall be impartial and all business decisions must be taken on the basis of what is best for the Group companies, regardless of personal relationships or benefits. Conflicts of interest between employees and the Group companies are to be avoided. Employees may not take part in activities that conflict with Addtech’s or the Group companies’ interests.

Healthy competition

We support fair and free competition in all areas of our operations. All kinds of price fixing or market sharing between competitors, resale price maintenance, hampering of innovation, exchanging of trade secrets or other anti- competitive activities are prohibited. Addtech employees may not, in their contacts with the competition, discuss market sharing, price fixing or other price-sensitive conditions or costs.

If any company in the Group is contacted with proposals concerning such collaboration, or if a situation arises where it is difficult to assess whether or not something is permissible, this should be reported to the recipient’s immediate superior or higher management.

In the case of a competition authority carrying out an unannounced inspection, employees must co-operate with the authority’s representatives and must not in any way obstruct the inspection.

Accounting and reporting

All financial transactions must be accounted for in line with generally accepted accounting principles.

SOCIETY

Communication

We have an open approach in the dialogue with those who are affected by the Group’s activities. We respond to external enquiries and communicate with affected parties in a correct and effective manner. Business-related issues are handled by the Group companies.

Questions relating to Addtech should be addressed to info@addtech.com.

Confidential and proprietary information

Employees may not disclose information that could have a harmful effect on the business or negative implications for a co-worker. For example, information about strategies, research, product development, business partners and financial results should be treated confidentially. Information about staff members and salaries may also be sensitive and should therefore be treated carefully.

Social media usage

All employees should use social media carefully and avoid posting anything that can have a negative effect on work relations or business interests. Never give the impression that you are speaking on behalf of the company in any personal communication or social media.

Local involvement

Addtech’s companies have strong local affiliation and their businesses are often located in small towns. Upon acquisition, we strive to remain in those locations, and to make the most of and develop existing skills. We want to contribute to strengthening the community in which we operate by having an invigorating and long-term approach to our business activities. We strive to recruit new employees locally and to offer jobs to young people. Through active and constructive dialogue with the local community, we want to create conditions for growing locally.

Environmental responsibility

Addtech is actively working to continuously reduce the Group’s direct and indirect impact on the environment. The environmental perspective should be part of all important decisions in order to create long-term value for the Group’s customers, employees, shareholders, and for society as a whole. Group companies shall comply with Addtech’s sustainability policy.

Taxes

In all countries where Addtech operates, the tax laws and tax rules of each country must be followed.

IMPLEMENTATION AND COMPLIANCE

Implementation of the Code of Conduct

We require all employees to comply with the Code of Conduct. The CEO of every individual Addtech company is responsible for the implementation of the Code of Conduct, for informing their co-workers of their rights and obligations, and for ensuring that our employees comply with the Code of Conduct. Addtech’s management is responsible for documenting and reporting to the Board of Directors once a year as to how we ourselves and our suppliers meet the requirements.

Compliance with the Code of Conduct

Every Addtech employee is responsible for reporting any cases of fraud or other criminal behaviour. Any infringements of our Code of Conduct that come to the Company’s attention will be followed by immediate disciplinary action being taken, which may include dismissal and/or legal proceedings in the most serious cases of non-compliance. Employees who are uncertain as to whether a specific behaviour may breach the Code of Conduct should consult their immediate superior for guidance.

We encourage employees to report relationships that may conflict with the Group’s Code of Conduct to their immediate superior or to higher management. If for any reason the employee is unable to approach these individuals, the Group’s anonymous whistle- blower procedures are to be followed. There is more information available at www.addtech.com/whistleblower. There will be no penalty or other negative consequences for people who provide information in good faith and in line with the aims of the Code of Conduct.


Supplier Code Of Conduct

 Addtech’s vision is to provide leading technical solutions for a sustainable tomorrow. In order to live up to our vision, we need to constantly develop, but never by compromising on corporate responsibility. We want to ensure that all our suppliers operate in compliance with the terms and regulations of our Supplier Code of Conduct, which is based on universally recognized standards for human rights, labour practices, anti-corruption and protection of the environment.

The aim of this Code is to ensure our supply chain relationships are built upon relevant values and are assessed fairly across the globe. Addtech wish to make a positive impact and increase transparency in our supply chain in order to strengthen relationships where most needed. In case of non-compliance with our Supplier Code of Conduct, we will help to establish a plan to reach full compliance and close gaps.

Thank you for sharing our commitment to do business responsibly together.

Niklas Stenberg
Niklas Stenberg President and CEO

About Addtech’s Supplier Code of Conduct

Addtech’s Supplier Code of Conduct summarises the ethical values that the Addtech Group (“Addtech”) believes should apply in the relationships with all our suppliers of products and services. The code is based on the UN’s Global Compact, the ILO’s core conventions, UN’s Universal Declaration of Human Rights, the OECD’s guidelines for multinational companies, competition legislation and anti-corruption regulations.

This Code of Conduct has been adopted by the Board of Directors of Addtech AB (publ) and any amendments or dispensations may only be executed by the Board.

7 February 2022, Stockholm 15867197

1. GENERAL PRINCIPLES

Addtech’s ambition is to work together with our suppliers and to review them regularly in order to achieve positive change. All suppliers to our companies shall respect the Supplier Code of Conduct and draw up and implement a code of conduct of their own, the content of which does not conflict with the values that Addtech represents. The supplier is responsible for ensuring that its sub-suppliers comply with the content of this code. Addtech chooses suppliers primarily on the basis of two criteria: – the ability to deliver services and products in a business like manner, and

– the ability to comply with the standards of this Supplier Code of Conduct.

1.1 Compliance with applicable legislation

In its activities, the supplier shall be aware of, and as a minimum requirement, comply with all national and international laws and regulations that apply in the countries where they operate. The supplier shall always comply with the highest requirements arising from either applicable legislation or this Supplier Code of Conduct.

2. HUMAN RIGHTS

Anyone who works for a supplier either directly or indirectly must be entitled to have their basic human rights respected in line with the UNU’s Universal Declaration of Human Rights.

2.1 Work environment

The supplier must, as a minimum requirement, comply with applicable legislation and regulations relating to the work environment and working conditions. The supplier must provide a safe, hygienic and healthy workplace. This means, but is not restricted to, the following being in place: fire safety, evacuation plan, safety equipment and procedures, system for following up accidents, access to clean toilets and drinking water, adequate accident insurance for all employees, first-aid equipment, and that employees be properly trained to be able to use machines, equipment and chemical substances in a correct and safe manner.

2.2 Working conditions

The supplier shall apply working hours and pay salaries and compensation for overtime at least in accordance with national legislation and agreements, or in accordance with the custom of the local trade. The supplier shall ensure that the work week is limited to 48 hours, and under no circumstances exceed 60 hours including overtime. Overtime shall be voluntary and infrequent. Employees are entitled to at least one day off per week. The supplier shall always provide a “living wage”, which means that the wage should always be enough to meet basic needs and provide some extra income left for spending after necessities like shelter and food are paid for. The supplier must at least offer its employees all legislated benefits, including pension and holiday entitlements.

2.3 Child labour

Our suppliers must comply with the UN Convention on the Rights of the Child, the ILO’s Minimum Age Convention (no. 138) concerning Minimum Age for Admission to Employment, and the ILO’s convention (no. 182) concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labour.

No individual who is below the age of having completed compulsory education or is below the age of 15 may be employed. The supplier must have documentation in place that certifies the age of all employees. If we should come across child labour at any of our suppliers, 3 / 6

we require that action is taken to correct the problem without worsening the child’s social situation. The supplier shall assure that the children are enrolled in a remediation program, rather than being summarily terminated from employment. The program shall include access to education and financial support and shall be decided in consultation with the child and family or next of kind.

The supplier shall refrain from hiring young workers (below 18 years of age) to perform any type of work, which is likely to jeopardize their health, safety or morals.

2.4 Disciplinary measures

Employees must be treated with dignity and respect. No employee may under any circumstances be subjected to corporal punishment or other forms of physical, sexual or psychological punitive action, harassment or force. Salary deductions may not be imposed as a disciplinary sanction, unless this is regulated by collective agreement or approved by law.

2.5 Discrimination

At Addtech we strive for a non-discriminating company culture based on responsibility and respect. We will therefore not permit discrimination or harassment in any form by our suppliers.

2.6 Freedom of association

Employees enjoy freedom of association at all levels. Suppliers may not prevent employees from joining associations or organisations or negotiating collectively. The supplier must recognize elected workers’ representatives and bargain in good faith with them regarding important concerns at the workplace.

2.7 Threats and harassment

Suppliers must not subject employees to threats or harassment, or in any other way restrict or interfere with employees’ legal and peaceful exercising of their rights.

2.8 Forced labour

We do not accept forced labour, slave labour or involuntary or unremunerated work in any form. This includes contracts under forced conditions and illegal employees. All work that is carried out must be based on a recognised employment relationship in line with what has been established by local legislation. Employees must be free to end their employment at any time in accordance with the agreed notice period without sanction or salary deduction.

Neither do we accept methods that restrict employees’ freedom of movement, and no individual may be kept at work for any length of time against their will. The supplier must have procedures and methods for minimising the risks of all kinds of forced labour and human trafficking.

3. BUSINESS ETHICS

The supplier must run its operation in an ethical manner and comply with international trading regulations and regulations concerning export controls. The supplier must implement procedures to promote transparency and guarantee that no document relating to the supplier’s performance in line with this Code of Conduct can be manipulated. The supplier must respect intellectual property rights and protect confidential information from theft, fraud and inappropriate disclosure.

3.1 Anti-corruption

We do not accept any supplier unduly attempting to influence decision makers at companies within the Addtech Group, other suppliers, buyers and/or representatives of government authorities/the public sector, etc., or in any other way taking or neglecting to take action that may conflict with legislation applicable at the time concerning corruption, bribery, extortion or embezzlement. Suppliers may never offer or receive any favours or other funds that might be considered undue benefits.

3.2 Conflict zones

The supplier must ensure that no business that we do in any way supports war, conflict, extremism, money laundering, drug trade or slave trade. This includes the use of conflict minerals.

3.3 Impartiality and conflicts of interest

Suppliers must avoid conflicts of interest that can jeopardise the supplier’s trustworthiness and must inform the relevant company within Addtech of any potential conflicts of interest.

3.4 Healthy competition

No supplier to Addtech may be involved in any kind of price fixing or market sharing between competitors, resale price maintenance, hampering of innovation, or other anti-competitive activities that conflict with applicable competition regulations.

4. ENVIRONMENT

Suppliers shall comply with applicable environmental legislation in the country where they conduct their activities and must manage their activities in a responsible way as regards the risks of environmental impact.

Suppliers shall comply with applicable regulations regarding air pollution, hazardous waste, discharge of water, chemical storage, recycling of waste and waste management controls. They must also take reasonable action to reduce their direct and indirect negative impact on the environment and continuously monitor improvement objectives.

We encourage our suppliers to have a documented Environmental Management System (EMS) in place in order to manage the organisation’s procedures and production processes in a comprehensive and documented manner, specifically adhering to environmental regulations.

Suppliers shall obtain and retain all necessary permits and licences for their activities and must inform the relevant company within Addtech of any significant incidents, how the supplier is going to manage the situation and how it intends to prevent similar incidents from happening in the future.

4.1 Hazardous substances management and regulations

The supplier must comply with all national laws and regulations prohibiting or restricting specific substances. The supplier shall for example comply with material restrictions (e.g., REACH) and continuously maintain records of relevant raw material declarations such as Material Data Sheets (MDS) or similar. The supplier must have systems and routines in place in order to monitor safe handling of chemicals in operations, reporting and disclosures for conflict minerals, handling and disposing of hazardous waste, emergency routines to prevent and minimize effects on health and environment.

4.2 Wastewater, solid waste and air emissions

Wastewater and solid waste generated from operations, industrial process and sanitation facilities must be treated as required by applicable laws and regulations before discharge and disposal.

Air emissions of for example, volatile organic chemicals, aerosols, corrosive, particles and combustion by products generated from operations must be 5 / 6

treated as required by applicable laws and regulations before discharge.

4.3 Emission of greenhouse gases

Addtech encourage all suppliers to reduce their impact on the climate and to set greenhouse gases reduction targets for their own operation. Addtech has the long-term ambition to reach a coal free supply chain.

5. IMPLEMENTATION AND COMPLIANCE

The Code of Conduct applies to all Addtech suppliers.

Addtech retains the right themselves or via a third party appointed by the Group to carry out a review or inspection at our own expense and with reasonable notice to check that the standards stated in this Code of Conduct are being complied with. The supplier must keep a register of all relevant documents and must be able to account for how it is complying with Addtech’s Code of Conduct for Suppliers.

If a supplier infringes the Code of Conduct and does not carry out the prescribed improvements within an agreed period of time, although a complaint has been registered and a plan of action has been agreed, we will discontinue our business relationship with the supplier. Such measures do not preclude Addtech from instituting legal proceedings.

We encourage partners to report relationships that may conflict with the Supplier Code of Conduct. Addtech is providing an anonymous whistle-blower system open for partners. There is more information available at www.addtech.se/whistleblower .

6. ZERO-TOLERANCE STANDARDS

Addtech will not conduct business with a supplier engaged in violations of fundamental human rights. The following practices are considered unacceptable:

– The use of bonded and forced labour, including forced prison labour and human trafficking

– Any violation of the ILO Convention 182 Worst form of child labour

– Any harsh, inhumane or degrading treatment or punishment of employees

– The exposure of employees to life-threatening work environments, where they have not been informed of the danger and where protective measures have not been undertaken

– Deliberately causing substantial pollution to air and water or soil contamination

– Any complicity in violations of international humanitarian law and other crimes against the human person as defined by international law. 6 / 6