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Dear colleague, We should all be very proud of what we do and how we do it. Still, every day we need to keep in mind that it is what each and every one of us do that defines who we are as a company, and how the world sees us. Elfa is a renowned brand, with a reputation that has been earned since 1948. It is up to all of us to honor that heritage and build an even stronger future for our company. Elfa’s Code of conduct is a set of principles guiding us to conduct ourselves with honesty and integrity in all actions representing Elfa. All employees at Elfa are to sign two documents; TCS Code of Business Conduct and Ethics and the Elfa Group Code of Con- duct. The latter serves as complement and to some extent it reinforces our owner’s code of conduct. We call on all of you to discuss with your manager and col- leagues how it applies to your specific circumstances and line of work. Don’t be afraid to ask for support from from your direct manager, HR or anyone in the Ethical council, if there is some- thing you do not understand or need help clarifying. And speak up if you notice behavior that does not seem right to you. Anders Rothstein, CEO Elfa International AB 2
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THE ELFA CODE OF CONDUCT. 4 Our ONE Elfa core values. 5 Who the code applies to. 5 Compliance with the law. 6 Reporting known or suspected violations. 6 No retaliation policy. 6 Guidance for decision-making. 7 OUR COMMITMENT AT OUR WORKPLACE. 8 We respect each other. 9 Non-Discrimination. 9 Health and safety. 9 OUR COMMITMENT IN THE MARKETPLACE.10 Fair dealing. 11 Product compliance.11 Fair competition. 12 Anti-Corruption, Including Gifts and Entertainment.12 We separate personal interests from business activities.13 We safeguard company information and assets.14 We communicate transparently and responsible.14 OUR COMMITMENT TO SOCIETY.15 We care for society and the environment.16 We speak up. 16 RELATED GROUP-WIDE POLICIES AND CODES.17 3
