Code of Conduct by elcowire

CODE OF CONDUCT FOR ELCOWIRE GROUP

ELCOWIRE GROUP CONSISTS OF THE COMPANIES ELCOWIRE AB, ELCOWIRE RAIL GMBH AND ELCOWIRE GMBH

In our business, it is important that we have a common set of values and principles, and we have therefore developed a Code of Conduct as a guide in the daily work for all employees.

JOINT RESPONSIBILITY

All employees are responsible for complying with and embodying the rules and values in the Code of Conduct.

It is the responsibility of managers to check annually that all their employees are aware of the Code of Conduct and its contents. Temporary staff and consultants shall also be made aware of the Code of Conduct and given time to understand its contents.

The following Code of Conduct describes how everyone in the organisation shall comply with and embody our values and also share this responsibility with Elcowire's various stakeholders.

Every employee and board member ofElcowire shall contribute to our companies being perceived as reliable and responsible companies at which operations are conducted in accordance with the following principles:

COMPLIANCE WITH LAWS

We always work in accordance with the laws that apply in the countries in which we do business.

BUSINESS ETHICS

Our ambition is to conduct our business with exemplary ethics.

CLOSE PARTNERSHIP

We aim to run our business in close consultation with all our business partners, as well as with other parties that impact on or are impacted by our business.

SUPPLIERS

Elcowire's suppliers are subject to the specific Code of Conduct for Suppliers introduced by the Group from 2024.

BUSINESS PRINCIPLES

ANTI-CORRUPTION

Elcowire Group shall not participate in, or accept any form of fraudulent procedure.

Employees of Elcowire shall not accept payment, gifts or other financial rewards from third parties which in any way influence, or could be perceived to influence, the objectivity of our business decisions.

Representatives of Elcowire Group companies shall not offer customers, potential customers, suppliers, consultants, governments, authorities, or representatives of such bodies, any form of compensation or benefits

that are contrary to either applicable law, or to accepted business practices that are stricter than the law, in order to win or retain business or gain other unfair advantage.

We shall not do business with customers or suppliers that we suspect are acting in breach of our anti-corruption rules.

TAXES

In all the countries in which Elcowire does business, we shall comply with the tax legislation and tax regulations of the country concerned.

If the tax legislation fails to give clear guidance, we shall be guided by the basic principles of good ethics, accuracy and transparency.

FAIR COMPETITION

The companies in Elcowire Group shall compete fairly and with integrity. The companies shall not exchange information, conclude contracts or enter into agreements with competitors, customers or suppliers where such action could unduly influence the market or the outcome of a tender procedure.

Elcowire shall use legitimate methods to gather information about its competitors.

CONFLICTS OF INTEREST

If a conflict of interest arises between private and professional activities, the employee, manager or board member shall communicate the situation to the relevant level in Elcowire and manage the conflict of interest in an ethical manner.

MONEY LAUNDERING

Our employees shall work actively to prevent and counteract Elcowire being exposed to or involved in money laundering. HUMAN RIGHTS

Everyone is born free and equal in value and with the same rights.

Elcowire shall support and respect the protection of internationally recognised human rights and ensure that the Group is not complicit in human rights abuses in its own operations, anywhere in the value chain or among the business’s stakeholders.

FORCED LABOUR

Elcowire does not tolerate forced labour. This includes agreements concluded under forced conditions and illegal labour. We also do not tolerate methods that restrict the free movement of employees, and nobody may be forcibly made to work against their will for any period of time.

CHILD LABOUR

Child labour is not tolerated. The minimum employment age is the age reached upon completion of compulsory education, but never lower than the age of 15. Exceptions are temporary short-term jobs that do not affect schooling, such as holiday employment.

DISCRIMINATION

All employees shall have the same opportunities based on their ability, experience and performance, irrespective of their gender, religion, age, disability, sexual orientation, nationality, political views, trade union membership, social background or ethnic origin. All employees shall be treated with respect. Discrimination, physical or verbal harassment and unlawful threats are not tolerated.

FREEDOM OF ASSOCIATION

Elcowire respects the rights of all employees to join a trade union to protect their interests as employees, to organise themselves and to negotiate their wages collectively or individually. An employee’s right to decide not to join a union shall also be respected.

WORK ENVIRONMENT

Elcowire strives to be an attractive and respected employer. The companies in the corporate Group shall provide a good work environment, from both a physical and a social perspective, and shall be attractive employers in terms of supporting employees’ personal development. Relations with and between staff shall be based on mutual respect and dignity.

We work to continuously improve health and safety in the workplace, and to offer our employees a safe and secure work environment. All companies in the Group shall, at a minimum, comply in full with national legislation and/or collective agreements.

We consider diversity and inclusion to be positive for the organisation, as well as its decisions and business activities, so these shall characterise daily operational tasks such as recruitment.

Employees shall be given reasonable influence in areas that affect their individual work situations.

TERMS AND CONDITIONS OF EMPLOYMENT

The terms and conditions of employment, including pay and working hours, offered to our employees shall, at a minimum, meet the minimum requirements of national legislation, agreements and industry standards.

ENVIRONMENTAL PRINCIPLES

RESOURCE EFFICIENCY AND CIRCULAR THINKING

Elcowire’s products, processes and services shall be designed in such a way that they use energy, natural resources and raw materials efficiently and minimise waste and waste products. All the resources of the business shall be recycled to the greatest extent possible, to avoid wasting resources and to promote circularity in society.

THE

PRINCIPLE

OF CAUTION

As soon as suitable alternatives are available, Elcowire shall avoid using materials and methods that may pose environmental and health risks. All the companies in the Group shall, at a minimum, comply in full with national legislation and international regulations.

COMPLIANCE

The CEO of Elcowire Group AB is ultimately responsible for ensuring that the everyday work across the entire business is carried out in accordance with our Code of Conduct.

Deviations from this policy require the approval of the Board of Directors of Elcowire Group AB. The document is reviewed annually by the Board of Directors of Elcowire Group AB.

All Elcowire employees are encouraged to report suspected violations of the Code of Conduct to their manager or manager’s manager.

If the employee's report is not taken seriously, or if the employee does not feel comfortable reporting suspected violations of the Code of Conduct to their immediate managers, the employee should instead make a report via the Whistleblower pages on elcowire.com. Reports can be submitted anonymously.

No punishments or other negative consequences shall result for people who submit reports regarding the Code of Conduct.

Failure to comply with the provisions of this Code of Conduct may result in disciplinary action.

This document was originally created in Swedish.

The Code of Conduct shall be translated into English and the local language of each company.

The document was approved at a board meeting of Elcowire Group AB held on September May 2024.

Paul Gustavsson CEO, Elcowire

Group AB

HUMAN RIGHTS AND SOCIAL JUSTICE