Code of Conduct

1. INTRODUCTION

Finnfoam recognizes the importance of managing quality and ethics in a sustainable and responsible manner. We acknowledge our social and environmental responsibilities in order that we meet our aim of manufacturing goods and operating our business responsibly. For this purpose, Finnfoam has issued this Code of Conduct (hereinafter referred to as the “CoC”).

We expect all our employees to work in accordance with applicable laws and respect the legislation at the place of its production and where services are purchased and/or provided. Where national laws and regulations cover the same subject as CoC, the highest standard shall apply.

Finnfoam CoC contains internationally recognized labor- and environmental requirements. It defines and summarizes what we expect from all our employees, regardless of location or background, with respect to the following categories: Health and safety, Environmental protection, Labor practices and human rights, Ethics and fair business practices.

We expect our employees to conduct business in line with the values and principles outlined in this CoC in full compliance with all applicable laws and regulations.

2. COMPLIANCE WITH LAWS AND FINNFOAM CoC

Employees shall comply with all applicable laws and regulations, as well as international treaties. Finnfoam shall take all relevant and necessary initiatives and measures to at all times ensure compliance with its obligations as set out in this CoC. Finnfoam shall use all efforts to ensure that its employees comply with the requirements under this CoC.

3. SOCIAL RESPONSIBILITY

3.1 Forced labor and child labor

When hiring young people, above minimum age but under 18 years, we shall ensure that employment does not jeopardize their education, health, or safety. Children under the age of 18 may not engage in tasks that are harmful to health and safety, including night work, and children under the age of 15 (14 or 16 in certain countries) may not engage in work in such a way that their schooling is hindered or adversely affected. No form of forced or involuntary labor, child labor or wage slavery occurs.

We shall also ensure that all work is voluntary. Employment contracts shall be easily understood by the employees, and they shall have the right to terminate their employment subject to giving reasonable notice or in accordance with local law. We shall not traffic people or use any form of forced, bonded, slave, or prison labor. Employees should not surrender any personal identification documents as a condition of employment.

3.2 Right to trade union freedom and collective bargaining

Employees’ rights to freedom of association shall be respected. Employees of Finnfoam shall, without exception, have the right to join unions and to bargain collectively. Finnfoam shall not discriminate against trade union officials or prevent them from carrying out their trade union functions.

3.3 Equality and non-discrimination

Employees shall be treated in a fair and equal manner. No employee of Finnfoam shall be discriminated against, for example based on ethnic or social background, nationality, religion, age, disability, gender, marital status, sexual orientation, union membership or membership of a political organization.

3.4 Harassment

Personal rights, personal dignity and privacy of every individual shall be respected. Employees of Finnfoam shall not be subjected to corporal punishment or to physical, sexual, psychological or verbal harassment or abuse.

3.5 Health and safety

Ensuring that the highest health and safety standards are met in our premises is of prime importance to Finnfoam. We shall provide and maintain a safe work environment including workplace, workstation and work equipment, and encourage sound health and safety practices. The work environment must be secure and promote good health, taking into account the general knowledge of industry and specific risk factors. A clear set of rules and procedures for health, safety, fire protection, and emergency preparedness shall be established and complied with. Systems for detection, prevention and action against potential threats to the health and safety of all employees have been established. Employees have access to clean sanitation and clean drinking water. Employees and on-site contractors shall be adequately informed about health and safety issues and given appropriate training in their regional language to minimize health and safety risks.

3.6 Wages and working hours

Employees shall be paid at least the minimum wage and overtime pay in accordance with applicable laws and regulations, including applicable collective agreements. Working hours shall be in accordance with applicable laws and regulations, and current industry practice, and may not exceed working hours as laid down in international conventions.

4. ENVIRONMENT

4.1 Impact on the local community

No form of criminal environmental activity or reckless exploitation of land may occur in the surrounding environment. The nearby surroundings of the production plant may not be over-exploited or destroyed by pollutants.

4.2 Environmental protection

Production shall not conflict with applicable laws or regulations of European Union. Procedures and regulations for waste management, disposal and taking care of chemicals and other hazardous substances, as well as treatment of emissions shall be established and must comply with applicable legal requirements of European Union.

5. BRIBERY AND ANTI-CORRUPTION

Finnfoam shall neither pay nor accept bribes, improper benefits, or gifts, when dealing with private parties or public officials. Travel expenses of Finnfoam´s representatives shall always be paid by Finnfoam.

6. MANAGEMENT SYSTEM

Finnfoam has appropriate management systems in place to ensure that all applicable laws and regulations are complied with. Top management has defined and implemented a management system to ensure that all requirements can be met. The management is responsible for effective implementation and continuous improvements through corrective measures and periodic reviews of the requirements and for communicating these requirements to all employees.

7. COMPLIANCE

7.1. Trust and cooperation

Finnfoam expects all employees to respect this CoC and actively do their utmost to comply with it. Finnfoam believes in cooperation and cooperates with employees to achieve realistic solutions in each individual case. Finnfoam is prepared to take into account cultural differences and other factors, which may vary from country to country, but is not ready to compromise in terms of the basic requirements with regard to security and human rights.

7.2. Non-compliance

To protect business and maintain the confidence of stakeholders, compliance with operating instructions is a necessity. Every employee has the right and obligation to report to his supervisor if he or she is aware of, or if she or he suspects that the company is engaged in unethical activity or if it finds that a policy is inappropriate.

It is the responsibility of the superiors to ensure that suspicions of alerts are investigated confidentially without delay and regardless of the subject. Notification must not cause any consequences for the notifier. For this purpose Finnfoam has a Whistleblow -channel. Finnfoam’s management takes the necessary measures to correct the misdemeanors found.

If Finnfoam finds that an employee does not meet the requirements of this CoC, the work contract may be terminated unless the improvements take place within an agreed period. In case of repeated infringements against this CoC, Finnfoam will immediately terminate the cooperation with the employee.

WHISTLEBLOWING CHANNEL

As part of our responsible and ethical activities and good business principles, Finnfoam has implemented a channel through which you can report suspected misconduct in Finnfoam’s activities. You can report any suspected violations of laws or regulations, as well as serious breaches of Finnfoam’s ethical guidelines.

You can use the enclosed link to submit a report: https://app.easywhistle.com/report/finnfoam

As part of our responsible and ethical activities and good business principles, Finnfoam has implemented a channel through which you can report suspected misconduct in Finnfoam’s activities. You can report any suspected violations of laws or regulations, as well as serious breaches of Finnfoam’s ethical guidelines.

You can use the enclosed link to submit a report: https://app.easywhistle.com/report/finnfoam

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