Code of Conduct

KOMPAN has a strong commitment to economic, environmental and socially sustainable development. KOMPAN is dedicated to operating its business in a responsible manner that is adding value to people’s lives, and we expect the same dedication from our suppliers. As a global leader within its core businesses, KOMPAN strongly believes that it is in the mutual interest of both KOMPAN and its suppliers to meet the present and future requirements of markets and society. This includes demonstrating responsibility towards the people taking part in the manufacture and delivery of products and services.

KOMPAN expects all its businesses to comply with EU regulation and to the laws of the countries where its businesses are located. In order to make its position clear to all suppliers, KOMPAN has established the KOMPAN Code of Conduct for Suppliers (the "Code"). The Code describes KOMPAN Group economic, environmental and socially responsibility requirements for suppliers. As a condition of doing business with KOMPAN, we expect suppliers to comply with these requirements and support KOMPAN in achieving the requirements in the Code. It is KOMPANs intention to maintain this Code in a spirit of constructive dialogue and in partnership with suppliers, for the mutual benefit of both parties.

In the Code, the term "KOMPAN" refers to all KOMPAN Group companies.

KOMPAN requires the Supplier to acknowledge, accept and adhere to this Code as set out below. KOMPAN operates in many different countries, and across cultures, traditions, local laws and regulations. The Code is universal for KOMPANs business and for doing business with any Supplier.

2.1 Area of application

The Code applies to the supplier and all supplier Group companies (the "Supplier"). The Supplier shall inform all Supplier Group companies on their obligations in relation to the Code and Supplier is responsible towards KOMPAN for all Supplier Group companies' compliance with the Code.

2.2 General responsibilities

The Supplier shall take all necessary actions to ensure Supplier's compliance with this Code, without undue delay. In addition to complying with the Code, Supplier shall comply with applicable local laws. If a domestic context in which the Supplier operates renders it impossible to meet the obligations set out in this Code fully, the Supplier shall notify KOMPAN, and the Supplier is expected to respect the rights in international principles to the greatest possible extent. The Supplier is solely responsible for the costs of complying with the Code.

The Supplier must collaborate with KOMPAN concerning issues stated in this Code, as well as other Code related issues that might fall outside the scope of this Code. The Supplier shall use all reasonable efforts to ensure that its sub-suppliers comply with the requirements under this Code.

The Supplier shall ensure that no entity within the Supplier Group, its management, owners and sub-suppliers appear on any international Sanctions or Watch’s lists. The Supplier shall inform KOMPAN immediately if it becomes aware that any of its companies, sub-suppliers, management, owners or persons of business partners appears on any international Sanctions or Watch’s lists.

2.3 Non-compliance

If KOMPAN finds or suspects incidents of non-compliance with the Code related to the Supplier or the Suppliers sub-supplier, and KOMPAN informs supplier hereof, KOMPAN expects the Supplier to investigate and correct issues of non-compliance as soon as possible and within an agreed timeframe. If the Supplier does not show willingness to correct these issues KOMPAN will consider terminating the business relationship with Supplier. Any such termination of any business relationship between KOMPAN Group companies and Supplier is considered a termination for cause and does not entitle Supplier to any kind of compensation.

If Supplier uses sub-suppliers for its supplies to KOMPAN and/or acts as a distributor or wholesaler towards KOMPAN, the Supplier shall use his best endeavors to ensure that its sub-suppliers comply with the Code.

2.4 Breach of the Suppliers obligations

In the event of a material and/or repeated breach by the Supplier or the Suppliers sub-suppliers of any of the obligations under this Code, KOMPAN is entitled in whole or in part to terminate its contract with the Supplier without incurring any liability towards the Supplier.

Any products which have been manufactured by the Supplier in material breach of the obligations under this Code are deemed non-conform, and KOMPAN reserves the right to reject such products, without prejudice to any other rights of remedy available to KOMPAN under any contract or the law.

2.5 Site Audit

KOMPAN may conduct announced audits at the Supplier's sites, including the Supplier's manufacturing facilities in order to verify that the Supplier is in compliance with the Code ("CoC audit"). CoC audits may be performed either by KOMPAN employees or by a third- party auditor chosen by KOMPAN. In order to verify the Supplier's compliance with the Code, Supplier shall be prepared to provide KOMPAN access to relevant and reasonably requested information and documentation, during an audit. All auditors carrying out CoC audits are bound to confidentiality by written agreements. All information and results obtained in connection with CoC audits will be handled confidential by KOMPAN and will only be shared with Supplier. KOMPAN will only use such information for internal purposes.

For general questions or comments on the Code, Supplier may contact Supplier's sourcing contact at KOMPAN.

KOMPAN has a zero fraud and bribery tolerance. KOMPAN employees cannot accept, and the Supplier shall not offer to provide, neither directly nor indirectly, any gifts, gratuities or other benefits, which may influence decisions with the respect to KOMPANs relationship with the Supplier or which may be conceived as a bribe. The Supplier shall disclose to KOMPAN any situation that may appear as a material conflict of interest and comply with all applicable laws and regulations relating to anti-bribery and anti-corruption.

The Supplier shall respect international agreements on human rights, and on request provide example of good human rights practices in its operations.

4.1 Child Labour

KOMPAN respects the children's right to development and education. Therefore, KOMPAN does not accept the use of child labour as a part of the full-time work force at the Supplier. This includes employing children under the age of 15, children younger than the legal minimum age, or children younger than the age of completing compulsory school. Juvenile (children between the age of 15 and 18) are only allowed to be employed by Supplier, provided that the work complies with local laws and the ILO Minimum Age Convention.

In general, all children under the age of 18 must not be employed in hazardous work*, not work night shifts and they are entitled to more breaks than adults.

Note *: Hazardous work is work which, by its nature or the circumstances, is likely to harm the health, safety or morals of children.

4.2 Discrimination

KOMPAN respects cultural differences and does not do business with a Supplier if the Supplier practices discrimination at work based on race, religion, gender, age, nationality or sexual orientation. The Supplier's employees must not be exposed to any physical punishment, threats of violence or physical, sexual, psychological or verbal harassment or maltreatment in the workplace or in work related situations.

4.3 Forced Labour

The Code does not permit forced or involuntary labour at the Supplier. This includes forced prison work, work on a forced contract, slavery and other forms of work, which are done against one's will or choice. KOMPAN does not tolerate employment which confines the employee in unreasonable debt bondage, for example, through fee-charging employment agencies.

4.4 Working Environment

KOMPAN supports the fundamental human right to have sound working conditions. The Supplier must ensure a good and safe working environment which complies with all applicable rules and laws. As a minimum:

• Workers must not be exposed to dangerous work without being properly protected.

• Workers must be provided with personal protection equipment and be instructed in its proper use.

• Facilities must comply with applicable laws and rules about construction safety as well as fire protection - and fire alarms.

• Facilities must provide appropriate light and ventilation

• All dangerous materials must be stored in safe places and used in safe and controlled ways.

• All machinery must be properly maintained and shielded.

• Facilities for meals, resting and sleeping, must, if provided, be kept clean and safe.

4.5 Working hours and salary

KOMPAN recognizes the need for a sound balance between working time and leisure time for all employees. Unless the law provides otherwise, the maximum working time at the Supplier's sites is 48 hours per week plus maximum 12 hours overtime work. All workers shall be allowed to have at least one day off in a period of seven days unless the national law/rules provide otherwise.

Salaries for work and overtime shall be in accordance with the applicable national law or applicable national rules. Deductions in salary due to company fines or penalties must never compromise the minimum salary.

4.6 The right to organize and collective bargaining

The Supplier must not interfere with the worker's right to form and join unions or to bargain collectively. This means that Supplier must recognize his employees' right to choose whether or not to associate with or establish any organization including labour organizations. If trade unions are not allowed in the area of operation, or only state authorized organizations are allowed, the Supplier shall facilitate alternative measures to allow employees to access management to discuss work related matters.

4.7 Fair Competition and Intellectual Property Rights

The Supplier shall conduct their business in line with all applicable competition laws and regulations. The Supplier shall ensure that intellectual property of KOMPAN and other third parties including but not limited to copyrights, patents, designs and trademarks are used according to relevant agreements, as explicitly permitted and in accordance with applicable laws and regulations.

4.8 Confidentiality, Data Protection and Data Security

The Supplier shall respect its employees' right to privacy when it gathers or keeps personal information or implements employee-monitoring practices. The Supplier shall ensure that confidential information and personal information provided by KOMPAN and others on behalf of KOMPAN is used solely as explicitly permitted and in accordance with applicable laws and regulations. This also applies after the business relationship with KOMPAN ends, and when relevant, complies with EU regulation on processing of data and IT security when dealing with KOMPAN.

4.9 Environment

Environmental considerations are an integral part of KOMPAN business practices. The Supplier shall commit to reducing the environmental impact of its manufacturing process.

• Pollution Prevention and Resource Reduction: The Supplier shall avoid pollution and actively strive to reduce material consumption.

• Chemicals and Hazardous Materials: The Supplier shall ensure that chemicals and hazardous materials are handled, stored and disposed of in an environmentally safe way.

• Air Emissions: The Supplier shall ensure that air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required by law prior to discharge.

• Wastewater and Solid Waste: The Supplier shall ensure that wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required by law prior to discharge or disposal.

• Recycling and reuse of Materials and Products: The Supplier shall contribute to the recycling and reuse of materials and products to the extent possible and to ensure compliance with KOMPAN Specifications.

The Suppliers are expected to proactively manage their major environmental risks and most relevant aspects by mapping the major risks and implementing of risk mitigation measures.

4.10 Corruption

Corruption and bribery are recognized as barriers to sustainable development and free trade. KOMPAN does not accept these practices and therefore does not offer or accept any kind of undue payment in any of our business transactions. We expect our suppliers to act accordingly.

The obligations under this Code are additional to the Suppliers other obligations pursuant to any contract between KOMPAN and the Supplier. The obligations under this Code shall continue in force in respect of any deliveries from the Supplier to KOMPAN or vice versa, regardless of the termination or expiry of any contract between the parties.

Approved by Lars Lehmann, CEO, August 2025