Creos Product Design Sustainability Code of Conduct 

Creos code of conduct, coc, defines the basic requirements for our business relationship towards our stakeholders, social surroundings, and the environment. Creos views sustainable development as an integral part of its pursuit of value creation and has integrated sustainability principles to its core business processes. 

We require commitment to our Code of Conduct from all our stakeholders. We keep this Code of Conduct updated by posting the latest version on creosl.com. 

This Sustainability Code of Conduct is based on major international agreements and documents, including the United Nations Sustainable Development Goals (SDGs), United Nations Guiding Principles on Business and Human Rights, the EU CSRD Principles and Rights and The Organisation for Economic Cooperation and Development’s (OECD) Guidelines. 

1. GENERAL PRINCIPLES 

1.1. Creos is committed to respecting human rights, protecting the planet, and delivering a positive environmental legacy for future generations. 1.2. Stakeholders must comply with the standards set out in this Code of Conduct. Creos seeks to collaborate with its Stakeholders on a level attempting to prevent, mitigate, and remedy adverse human rights impacts, as well as reduce the environmental impacts of our operations, products, services, and supply chains. 1.3. Stakeholders must comply with applicable laws, regulations, and standards. In certain jurisdictions. 

2. SOCIAL SUSTAINABILITY 

2.1. Fair Labour Practices and Human Rights 2.1.1. Stakeholders must comply with fair labour practices and human rights, as set out in the United Nations’ Guiding Principles on Business and Human Rights. 2.1.2. Stakeholders must avoid causation of and complicity in any human rights violations. Heightened attention shall be paid to ensuring respect of human rights to specifically vulnerable rights holders or groups of rights holders such as women, children, migrant workers, or (indigenous) communities. Each Stakeholder must comply with general labour rights and maintain an active view on the human rights performance of direct and indirect stakeholders. 2.1.3. Each Stakeholder must pay exceptional attention to topics regarding modern slavery, and how it monitors standards in its own supply chain. Stakeholders must not use or contribute to slavery, servitude, forced or compulsory labour, or human trafficking. 2.1.4. All forms of forced (involuntary) labour must be eliminated. Forced labour includes all work or service exacted from any person under the menace of any penalty and for which that said person has not offered her/himself voluntarily. 2.1.5. All forms of child labour must be eliminated. Stakeholders must comply with the local minimum employment ages set by the applicable laws. 2.1.6. Stakeholders must comply with applicable labour laws concerning employment. All employees must have written employment agreements that are executed, binding and enforceable, and that in a transparent manner establish all terms of the employment (no hidden terms or oral agreements). 2.1.7. Employees must be able to carry out their respective functions in the workplace. 2.1.8. Stakeholders must not tolerate or promote any unacceptable treatment of individuals such as 

mental cruelty, sexual harassment, or discrimination. 2.1.9. Stakeholders must not restrict the rights of employees to join, associate, organise or participate in workers’ unions or collective bargaining in a lawful and peaceful manner. 2.1.10. All Stakeholders are invited to take appropriate steps to ensure that the provisions of this Code of Conduct are communicated and understood by workers and employees. 2.2. Working Hours, Wages and Benefits for Employees 2.2.1. Stakeholders must exercise fair and equitable compensation practices, considering each employee’s individual work experience and performance while being equitable internally. 2.2.2. Stakeholders must adhere to applicable wage and compensation laws, including those relating to minimum wages, overtime, piece rates, and other elements of remuneration. 2.2.3. No unilateral setoffs against the salary payments or other payments can be made to employees unless this is explicitly allowed under applicable laws and the relevant employees have been clearly and timely informed of the consequences of such offsetting. 2.2.4. Stakeholders must adhere to all applicable working-hours regulations. 2.2.5. Cooperation Parties’ employees must be provided with rest days after consecutive workdays. 2.2.6. In the event of cross-border personnel employment, Stakeholders must adhere to applicable legal requirements, especially with regards to minimum wages. 2.2.7. Stakeholders must ensure that employer contributions are paid fully, accurately, and timely. 2.2.8. Stakeholders must provide adequate and periodic free-of-charge professional training to ensure the skills and capabilities needed for carrying out employment tasks successfully. 2.2.9. With regards to sufficient employment terms, Stakeholders must implement standardised policies on workforce planning, holiday regimes, and remote working. 2.3. Health and Safety 2.3.1. Creos is committed to protecting the safety and health of people and communities in all its operations. Creos expects all its Stakeholders to provide a safe and healthy workplace. 2.3.2. Stakeholders must have adequate policies and procedures in place to ensure and support physical and mental health of employees at the workplace. 2.3.3. Stakeholders must act in accordance with the applicable statutory local, national, and international standards regarding occupational health and safety. 2.3.4. The Stakeholders’ working spaces must be secure and allow reasonable freedom of movement of employees, as well as entry and exit to/ from premises. 2.3.5. Stakeholders must provide (free-of-charge) adequate training and education for employees regarding health and safety issues. 2.3.6. Stakeholders must create, maintain, and execute emergency preparedness plans and procedures that are understandable and clearly communicated to all employees. 2.4. Diversity, Equity, and Inclusion 2.4.1. All the Stakeholders’ employees must be treated equally, regardless of their race, religion, colour, sex, sexual orientation, gender identification, national, social, or ethnic origin, age marital status, military or veteran status, disability, pregnancy, union membership, political affiliation, or any other basis determined by applicable laws. 2.4.2. Stakeholders must not discriminate in hiring and employment practices. 2.4.3. Stakeholders are urged to foster inclusive teams and purposefully shape an employee-friendly corporate culture with a sense of belonging to the workforce and community. 2.4.4. Stakeholders are urged to enforce procedures within their organisation which establish effective whistle-blower channels. 

3. ENVIRONMENTAL SUSTAINABILITY 

3.1. Creos is committed to ensuring safe and environmentally sound development, manufacturing, transport, use and disposal of its products and services. All Stakeholders are expected to make every effort to protect the environment, minimize adverse environmental impacts and optimize the use of energy and natural resources. 3.2. Stakeholders must comply with all applicable local, national, or international environmental laws and regulations, as well as all applicable health and safety regulations. 3.3. Stakeholders must protect their employees as well as the wider public against environmental hazards inherent in their services and products. 3.4. If the Stakeholder’s activity is subject to local, national, or international environmental permits and/or licenses, the Stakeholder is responsible for always ensuring compliance to the terms of such permits and licenses, including timely renewal/re-application, reporting obligations and other. 3.5. Stakeholders are encouraged to integrate sustainable environmental principles into their work processes and supply chain management (optimization of the use of energy, raw materials, and land management; minimize impact on biodiversity, climate change and water scarcity; reduction of emissions to air, consumption; reduction, reuse, and recycling of waste). 3.6. Stakeholders are encouraged to use energy-efficient and environmentally friendly technologies, where possible. Use of and production of harmful pollutants and chemicals should be limited. 3.7. Stakeholders are encouraged to use sustainable materials and manufacturing methods to support re- and upcycling, conserve of natural resources and reduce waste. 3.8. Stakeholders are encouraged to set targets and implement action plans for reducing environmental impacts in their activities. 

4. FAIR OPERATING PRACTICES 

4.1. Stakeholders must abide by all applicable national and international laws and regulations. 4.2. Stakeholders must consider business integrity as the basis of business relationships with Creos and prohibit all types of bribery and corruption. 4.3. Stakeholders must not directly or indirectly facilitate money laundering or terrorism-related financing. 4.4. Stakeholders must act in accordance with national and international competition. 4.5. Stakeholders must respect the intellectual property rights of others and use intellectual property rights of others in a manner that does not infringe the rights of any third party. 4.6. Stakeholders must be compliant with excise and other taxation obligations. 

5. PRIVACY, SECURITY AND DATA PROTECTION 

5.1. Stakeholders must be compliant with the GDPR and any other applicable data protection laws and requirements. 5.2. Stakeholders must at all times process personal data in a confidential and responsible manner. 5.3. Stakeholders must pay attention to information technology security and comply with relevant standards on IT security. 5.4. Stakeholders shall have adequate back-up, disaster recovery and other systems and procedures in place to enable their business and operations to continue without material adverse change in the event of a failure of systems. 

6. GOVERNANCE AND COMPLIANCE 

6.1. Stakeholders are required to implement an appropriate compliance management system, which facilitates compliance with applicable laws, regulations, and standards. 6.2. Stakeholders must avoid and disclose internally and to Creos all conflicts of interest that may influence business relationships. 6.3. When working with Creos, stakeholders must require their suppliers, sub-contractors, and business stakeholders to follow the same or similar provisions as set forth by this Code of Conduct. 6.4. Creos must be provided with continuous visibility on the Stakeholders’ employment, social, corporate, and environmental policies, practices, and certifications. 6.5. To monitor compliance with this Code of Conduct, Stakeholders are, upon request, required to provide Creos with yearly sustainability reports. 6.6. Each Stakeholder must allow Creos to carry out yearly sustainability compliance audits on it. 6.7. Stakeholders must provide access to a protected mechanism for their employees to report possible violations of the principles of this Code of Conduct. 6.8. Stakeholders shall facilitate active employee engagement in issue identification and resolution process.