Code of Conduct for DISAB€¦ · 3.1 Child labour DISAB does not accept either forced labour or child labour and supports the UN Convention on the Rights of the Child (CRC). We will

Code of Conduct for DISABGuidelines for how we conduct our business in an

ethically, socially, and environmentally correct way.

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Table of contents

1. Introduction 41.1 Description of the company 41.1.1 Our vision 4

2. Laws, regulations, and rules 4

3. Human rights 43.1 Child labour 43.2 Trade unions 4

4. Ethics and morality 5

5. Bribes and gifts 5

6. Working environment 56.1 Alcohol and drugs 5

7. Our business partners 6

8. Gender equality, diversity, and discrimination 68.1 Salaries and payments 6

9. Environmental impact 6

10. Challenges and conflicts of interest 6

11. Company information and property 711.1 Protect the company's property 711.2 Protect company information 7

12. Everyone's responsibility 7

13. Report breaches 7

14. Receipt of DISAB's Code of Conduct Appendix 1

1. IntroductionThis code of conduct summarises the communal rules and values according to which everyone at DISAB must work in order to generate trust and build satisfactory relationships with colleagues, customers, business partners and those in our surrounding environment. DISAB endeavours to achieve the highest level when it comes to ethical conduct and these rules must provide guidance in all situations affecting our work and our business. We expect everyone, regardless of their position, to conduct themselves and represent the company in the best possible way as far as professionalism, a businesslike approach and confidence in the surrounding environment are concerned and to adhere to high ethical standards in their professional practice.

It is important for our employees to be content and feel that we have a good working atmosphere. All dealings between employees, whether they are leaders or colleagues on an equal footing, must also be characterised by respect, responsibility and consideration towards one another.

1.1 Description of the company DISAB is a leading manufacturer of mobile, semi-mobile and stationary vacuum systems that are primarily used in industry. Since 1976, we have been offering our customers first-class products and system solutions that are used to remove dust and dirt and recycle material spillages. The key to our success is to combine our knowledge and experience with producing reliable products and systems with high technical performance.

1.1.1 Our visionDISAB's mission is to create dust-free industrial environments. Our vision is to be a leader in the field.

"2. Laws, regulations, and rulesAll employees and business partners must comply with applicable laws, rules and regulations in the industry sectors and countries in which we operate. This applies to our own production, how we treat our employees and how we deal with our bookkeeping, accounting and taxes.

3. Human rightsDISAB supports and respects the United Nations Declaration of Human Rights and accepts our responsibility to uphold employees’ and society’s rights in our business activities.

DISAB will not trade with any country, company or individual against which the UN or the European Union has issued sanctions. We will regularly monitor all published information from these sources in order to be sure that we are acting in accordance with them.

3.1 Child labour DISAB does not accept either forced labour or child labour and supports the UN Convention on the Rights of the Child (CRC). We will ensure that the products we sell do not come from companies that use child labour.

3.2 Trade unions DISAB respects employees' right to form and join the trade unions they themselves wish to form and join and to engage in collective bargaining.

4. Ethics and moralityDISAB’s aim is to continually exceed the requirements that customers and other stakeholders impose on the quality of our services/products. We keep our promises in customer relations and in our internal work. We carry on our business with high levels of integrity and morality and adhere to our high ethical standards. We take responsibility for our actions.

We require all employees to be aware of and comply with our purchasing guidelines and also to assume responsibility for our costs as far as possible.

In order to uphold our business ethics, we will never act in breach of applicable competition laws, e.g. by abusing a dominant position or engaging in unlawful industry collaboration such as through a cartel and we will never be involved in falsification of goods.

We take confidentiality into consideration in our work and ensure that no unauthorised persons or companies are permitted to access confidential information internally or from our suppliers. We all conduct ourselves in an ethically defensible manner.

5. Bribes and giftsWe never accept, either directly or indirectly, bribes or other improper benefits or payments for the benefit of the business and/or for financial gain.

Employees may receive gifts, services and entertainment from customers and suppliers and offer them to customers and suppliers provided that they are not of an over-generous or excessive nature. Employees must be on the alert for clear expressions of favouritism and must neither offer nor receive gifts, services or entertainment that fall outside reasonable business practice or specific company requirements.

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We never offer or give any gift or payment that constitutes or that may be interpreted as a bribe.

6. Working environmentDISAB endeavours to create a supportive working environment in which cooperation, individual responsibility, innovation and high performance are important core values. The company complies with rules and laws regarding health and safety and all employees are expected to assume responsibility for ensuring that workplaces are safe for them and their colleagues.

We will carry out an evaluation of the company and the employees' views on an annual basis through performance management interviews and draw up joint action plans that are also followed up. We also collaborate with our employees and the trade-union organisations on a continuous basis in order to create and develop a safe working environment.

We respect the fact that all employees need a healthy balance between work and leisure. All employees' skills are an important asset and the company wishes to provide everyone with individual development.

6.1 Alcohol and drugs No employee may be under the influence of alcohol or illegal drugs at work*. Use of alcohol and other drugs can be a problem for both the individual employee and for colleagues and the company.

Employees may not be involved in any transactions involving the handling, sale or purchase of illegal drugs. Illegal drugs may not be taken on to the premises of the company or the group.

*Consumption of alcohol may take place in moderate quantities at certain events, such as entertainment."All employees' skills are an

important asset for the company.

7. Our business partnersWe endeavour to ensure that our suppliers and other business partners are willing to meet the requirements set out in our Code of Conduct. We choose our business partners in a profes-sional, systematic and fair way. Our negotiations with business partners are conducted honestly and fairly.

We value and respect our customers' and consumers' trust in our company. We do this by providing information about our values and our business. In order to live up to and strengthen consumers' and customers' confidence in us, we must maintain an open attitude in the dialogue with them. We respond to requests from third parties and communicate quickly, accurately and efficiently.

8. Gender equality, diversity, and discriminationDISAB values diversity and equal treatment of people both for our employees and our business partners. We do not accept discrimination or harassment on grounds of gender, transgender identity or expression, ethnicity, religion or other belief, disability, sexual orientation or age. Nor must anyone be harassed on the grounds of their political views.

Nor do we accept any form of victimisation in our workplaces. The definition is “actions in an abusive manner at one or more employees that may lead to ill health or to exclusion from the workplace community”. All employees must feel safe working for us and any victimisation that nevertheless arises must be managed and dealt with promptly.

8.1 Salaries and payments We ensure that salaries and benefits amount to at least legislated levels and/or the lowest industry standard in the countries in which we operate.

We reward employees with individual salary development through performance without discrimination.

9. Environmental impactDISAB provides employees and other stakeholders with open, objective information on our environmental management. We are actively working to continually reduce the company's direct and indirect environmental impact. Suppliers are expected to operate in line with our environmental policy.

Suppliers must therefore be aware of and comply with requirements in accordance with national legislation, regulations and industry standards. This includes having knowledge and control over their environmental impact, as well as continually working on improved environmental measures in their business activities. In each investment, we endeavour to always use the lead-ing technology in environmental terms that is economically justifiable.

10. Challenges and conflicts of interestAll employees who come into contact with a spouse, family member or other relative or close friend in connection with business transactions with a supplier, customer or third party with which the company does business must immediately notify their superior so that appropriate measures can be taken to reallocate the work in order to avoid potential conflicts of interest.

The following guidelines apply to the most common conflict situations:

• Prohibition for employees on owning shares or holding a participating interest in any company that competes with or trades with DISAB. If you made such an investment before you began your employment, you must report it to your immediate superior. This prohibition does not apply if you own a smaller number of shares in a listed company.

• Get the go-ahead from your manager before doing business on DISAB’s behalf with any company where you yourself or any close family member could benefit from your actions in any way.

• Do not work for a supplier, customer, or competitor at the same time as you work for DISAB or

• carry out any work for any third party that could adversely affect your ability to perform or your judgment at work. Do not use the company's time, resources or materials for external work that has nothing to do with your work at DISAB.

11. Company information and property11.1 Protect the company's propertyAll employees must protect the equipment that we have in our environment or that is assigned to them and that must be used at work. In particular, employees must ensure that valuable elec-tronic equipment such as laptops, mobile phones and smartphones is always kept safe.

The company does not intend to generally monitor email, internet access, etc., but if so required by circumstances due to, for example, a suspected crime, it may be done by authorised personnel.

11.2 Protect company information DISAB complies with the GDPR reform and more information is available in our GDPR and IT policy. Information about the company and our employees must be treated as sensitive information and must be protected and may not be disseminated to unauthorised persons or persons outside the company, except for information that is forwarded for specific business purposes.

Examples of sensitive information include:

• financial performance

• acquisitions

• sales

• new products

• strategies

• customer Information

• design

• personnel and organisational information

All employees must be particularly careful to ensure that electronic equipment containing sensitive and confidential material (e.g. USB memory sticks) will not be removed or for any reason handed over to third parties outside the company. Anyone who deals with company information (particularly financial information) is required to check that it is accurate and reliable.

Confidentiality also applies when your employment has ceased.

6 7"DISAB values diversity and equal treatment of people both for our employeres and our business partners.

12.Everyone's responsibilityThis Code applies to all employees at DISAB. Everyone is expected to have access to and do business in accordance with the Code. Managers must inform all their directly subordinate employees of the existence of the Code and keep them regularly informed on it. Although questions of interpretation may arise, the Code describes the requirements that everyone working for the company is expected to fulfil. All DISAB’s employees have individual responsibility for reading and complying with this Code of Conduct, which forms part of the employment contract.

13. Report breachesIf an employee suspects that a breach of this Code has taken place, his or her immediate superior must be informed immediately. If an employee is unable to raise the issue with his or her superior, someone from the management team may be informed instead or, in serious and urgent cases, the CEO may be informed directly.

Employees have the right to be anonymous when they report a suspected breach of this Code. This is done by using an external email address that does not disclose the name of the sender in order to send an email to [email protected]. DISAB will investigate all reports received, but it may be more difficult to carry out a complete assessment if reports are submitted anonymously.

We take breaches seriously. We consider that our business is characterised by a high level of business ethics and morality. In these cases, we carry out individual assessments of what has happened and then assess what possible consequences it may have for the individual. However, DISAB always endeavours to offer a supportive climate in which employees feel that they can report cases of suspected breaches in confidence.

________________________Mats Lindskog, CEODISAB Vacuum Technology AB

www.disab.com ● [email protected]

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