Code of Conduct

Introduction

Malux will create added value for its customers, suppliers and employees while contributing to sustainable social development. We adhere to good business ethics and have strong commitment to comply with The Ten Principles of the UN Global Compact, human rights, labour, environment, anti-corruption, privacy, and legal compliance.

Malux is working with this through a proactive dialogue for good business ethics and strives for long-term and trusting relationships with its business partners.

We consider collaboration with our suppliers to be an integral part of our success and we look forward to working with you to develop more sustainable business practices for us all. We expect our Suppliers to fully comply with applicable laws and to follow internationally recognized environmental, social,

corporate governance standards and make sure that their employees understand their rights and obligations.

On request, the supplier must also be able to tell Malux which subcontractors they use. As a condition of doing business with Malux, suppliers and their subcontractors shall permit Malux and its agents (including third parties) to conduct audits, which may include confidential interviews with employees, in order to determine their compliance with the Supplier Code of Conduct.

Compliance

Our suppliers are expected to comply with all laws and regulations applicable to the business they conduct for Malux Group. They are expected to apply the principles covered in this Code or apply equivalent principles. If any part of this Code in unclear, they should ask their Malux contact for explanation and guidance. Non-compliance with this Code may lead to measures, including and up to termination of contracts and outstanding orders. It can also be a possible assertion of claims for damages.

Reporting unethical conduct

Malux must practice what it preaches and comply with our Code of Conduct and core values. Unethical conduct contrary to our Code of Conduct and core values shall be reported to the responsible manager at Malux or Malux HR.

Declaration

As supplier to Malux Group we hereby declare that we will adhere to and comply with the principles in the Supplier Code of Conduct. The signature gives Malux the right to verify the compliance of the requirements stated in this document, through inspections or similar.

Legal compliance

As a Supplier, including sub-supplier, to Malux Group you must, in all contexts, comply with all applicable laws and regulations. In addition, we expect our Suppliers to comply with applicable United Nations Conventions. Further on, all Suppliers shall respect all intellectual property rights of the Malux Group and third parties. We expect the Suppliers to put in efforts to promote corporate social responsibility and apply the standards within its own supply chain.

Human rights

The people who manufacture products and provide services that Malux purchases, shall be respected in their profession, and not be discriminated on such grounds as national or social origin, race, gender, sexual orientation, religion, or political opinion.

Labor

Forced labor, harassment, and abuse

Suppliers who work with Malux guarantee that no form of forced or involuntary labor, harassment or abuse of employees occurs within their operations. The term forced labor refers to any work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily. All labor shall be provided freely, and the employee shall retain the right to terminate their employment after a reasonable period of notice.

Child labor

Child labor is not accepted. Malux has zero tolerance for child labor, and a supplier working with Malux is required to guarantee that they do not employ anyone below whichever is the lower of the minimum age under national legislation and the ILO’s C138 Minimum Age Convention. The supplier shall also guarantee that any employee who is older than the minimum age but younger than 18 years of age has at a minimum working condition, working hours and pay appropriate to her or his age and in compliance with applicable legislation.

Working hours and salaries

Working hours and minimum wages shall follow the national laws in the country in which the products are manufactured or services are performed.

Health and safety

Suppliers who work with Malux are toguarantee that all their employees enjoy a safe and secure work environment.

Malux promotes a safe and healthy working environment throughout the supply chain, in compliance with each country's health and safety legislation. This

means the supplier must work systematically and resolutely on reducing work-related injuries, informing employees about the risks associated with

their work environment and ensuring that employees have suitable personal protective equipment and the right training to perform their duties.

Freedom of association

and the right to collective bargaining

All employees are entitled to exercise their legal right to form, join or refrain from joining organizations that represent their interests as employees. No employee is to be subject to threats or harassment for her or his peaceful exercise of these rights. Among other things, this implies that the employer shall respect the right of employees to bargain collectively.

Enable the employees and other stakeholders to report concerns or potentially unlawful practices at the workplace.

Sanctions

Sanctions may be enforced as a foreign policy instrument by a country or other body to prohibit trade with certain countries, individuals, entities, or sectors. The United Nations, European Union and United States are among those who issue sanctions lists. It is prohibited to conduct business, whether directly or indirectly, with any country, individual, entity or sector that is subject to sanctions.

Environment

Malux works actively to reduce the global environmental impact.

We expect our Suppliers and sub-suppliers to have a proactive approach to reduce negative environmental impact. In addition to complying with all applicable environmental laws, we expect the Suppliers to continually improve the environmental performance with focus on protection of the environment, continuously striving towards reducing the environmental footprint of their production, products, and services. Hazardous substances and use of fossil fuel in operations and in the products are expected to be phased out.

Insurance

Suppliers who work with Malux are to maintain adequate insurance cover for their activities and their deliveries. If Malux so requests, the supplier shall submit a copy of their certificate of insurance or other proof of their insurance policy.

Fair competition

We consider it unacceptable that we or any of our partners should behave in a manner that may distort free competition. None of Malux suppliers may collude in price fixing or cartels or act, or fail to act, in violation of applicable competition regulations.

Anti-corruption and money laundering

We expect our Suppliers and sub-suppliers to take all necessary actions to prevent corruption, bribery, money laundering and extortion.

All collaboration between Malux and suppliers shall be businesslike, beneficial to both parties and free of any conflicts of interest. For this purpose, the term beneficial refers to business benefits. All business decisions shall be reached without consideration for personal gain. Malux will not tolerate any supplier attempting to exert undue influence on decision-makers at Malux. Nor is it acceptable to in any other way take, or fail to take, measures that may contravene applicable legislation on corruption and bribery or the principles set out in Malux Code of Conduct. In relation to Malux or other partners, Malux suppliers shall therefore specifically guarantee that they will:

- refrain from acting in such a way that a relationship develops into dependency; and

- remain highly restrictive with regard to giving and receiving gifts and other benefits and refrain from paying for and accepting travel and subsistence.

Privacy and data protection

The Suppliers and sub-suppliers protect privacy, including personal data. It treats confidential information as such and keeps it secret. It takes necessary measures to comply with applicable privacy and data protection laws, regulations, and standards. (e.g. EU-GDPR)

Conflict minerals

The Suppliers and sub-suppliers shall work towards ensuring that the products Malux buys do not incorporate "Conflict Minerals", also known as “3TG”, which are minerals smelted into tin, tantalum, tungsten, and gold sourced from entities which directly or indirectly finance conflict in the Democratic Republic of Congo or adjoining countries. To ensure this, the supplier provides certificates related to purchases from Malux.

Anders Nygren

CEO

Malux AB