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COMPLIANCE WITH THE LAW We comply with all legal requirements applicable to our operations. Furthermore, we apply our Code even when our standards are stricter than legal requirements, as long as our standards do not conflict with local laws. Customs or local practices never take precedence over legal requirements. For you this means nn If you find that our Code is in conflict with applicable legal requirements, you must inform your manager REPORTING KNOWN OR SUSPECTED VIOLATIONS As an Elfa employee, you are responsible and accountable for reporting suspected or known misconduct to your manager or your manager’s manager. If you feel uncomfor- table doing this, speak with your unit’s contact person in Human Resources. Any of the manners described below are to be reported: nn Any questionable accounting, internal accounting controls, auditing matters or questionable financial practices (an “Accounting Allegation”) nn Any possible non-compliance with applicable legal and regulatory requirements (a “Legal Allegation”); nn Any possible non-compliance with this Code (a “Code Allegation”); and nn Any alleged retaliation against employees and other persons who make, in good faith, Accounting Allegations, Legal Allegations or Code Allegations (a “Retaliatory Act”) You may also, in your sole discretion, report suspected or known misconduct confiden - tially and anonymously to a third-party reporting service, by phone or by accessing their website, using the contact information provided on page 17. If you think there was a violation of the Code and you report it, your supervisor or management will not retaliate against. In case there is suspicion of illegal activities, the matter will be reported to relevant authorities. For you this means nn You are responsible and accountable for reporting suspected or known misconduct to your manager or your manager’s manager. If you feel uncom- fortable doing this, talk to your unit’s Human Resources or Legal Depart- ment, or Elfa’s Ethical Council nn If you are a manager, you have a responsibility to ensure that reports of suspected or known misconduct are adequately addressed NO RETALIATION POLICY Elfa does not tolerate any form of retaliation against an employee for making a good faith report of suspected misconduct. “Good faith” means that, to the best of your knowledge and belief, everything you report is true and that you report everything you know. For you this means nn Any employee who engages in retaliation will be subject to disciplinary action. If you believe that you have experienced retaliation, you should report it as suspected misconduct 6
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GUIDANCE FOR DECISION-MAKING If you are faced with an ethical dilemma and are unsure how to proceed, use this chart to help guide you to the best course of action. 1. Is it legal? 2. Does it comply with our values, policies, procedures and our code? 3. Would I feel comfort- able if I had to explain my actions to my manager or my family? 4. Could I defend my actions if they appeared on the front page of the newspapers or in a social media posting? No! Not sure. Yes on all! Don’t do it. The action might have serious consequences. Seek help first. Ask for guidance. The decision to move forward seems appropriate. 7
