CODE OF CONDUCT for suppliers This Supplier Code of Conduct (the “Code”) is a result of Elfa’s ambition to establish a proactive collaboration with its suppliers of direct material (“Supplier” or “you”). The purpose of the Code is to promote a lawful, professional and fair practice that includes respect for human rights, business ethics and our environment. The Code is based on fundamental compliance principles such as the Ten Principles of the UN Global Compact with the aim to contribute to UN Sustainable Development Goals and to Elfa’s core values: Customer focused, Professional, Humane, Holistic and Innovative. The Code sets out the minimum standards of business behaviour which means that a Supplier must have processes in place to monitor and maintain these standards. Breaches of the Code may negatively impact your business relationship with Elfa. Potential consequences may include but are not limited to contract termination. WHO THE CODE APPLIES TO The Code applies to Elfa’s suppliers of direct material. In addition, Elfa expects the standards in this Code to be respected throughout the supply chain of its Suppliers. You are expected to communicate the expectations and require- ments outlined in this Code to your sub-suppliers, involved in production or operations for Elfa. COMPLIANCE WITH LAWS As a Supplier, you are required to comply with all applicable laws and with this Code. If the Code sets a higher standard than, but does not conflict with, legal requirements, the Code shall take precedence. Customs or local practices shall never take precedence over legal requirements. If you find that this Code is in conflict with applicable legal requirements, you shall without delay inform the Group Purchasing Manager at Elfa. REPORT MISCONDUCT Elfa believes that a strong ethical culture thrives in an environment in which people feel free to report misconducts and situations of non-compliance with this Code. Such non- compliance might include suspected or known illegal or unethical conduct or other suspected or known breaches of the requirements in this Code (collectively defined as misconduct). Elfa may investigate reports of misconduct, and take appropriate actions based on our findings. The Supplier shall without delay inform Elfa of any misconduct and the work that has been done to resolve the situation. Reports of mis- conduct shall be sent to Elfa’s Group Purchasing Manager or Elfa’s Ethics Council. Contact information can be found at the end of this document. The Supplier is encouraged to implement a complaint mechanism, such as a whistle-blower system, or equivalent to promote the reporting of misconduct. The anonymity of anyone reporting misconduct shall be protected. NO RETALIATION Elfa will not retaliate against anyone for submitting a report of misconduct, when doing so in good faith. Similarly, it is not acceptable to retaliate or tolerate retaliation against anyone who, in good faith, reports misconduct. AUDITING Elfa reserves the right to monitor and audit the Supplier’s compliance with this Code. Accordingly, you must cooperate by providing relevant information and personnel in order for Elfa to conduct a meaningful audit. In addition, you are required to evaluate and perform risk assessments of your supply chain to ensure compliance with the Code as well as to conduct audits of your supply chain, when requested by Elfa. Any non-compliance by you or your supply chain must be effectively remedied in a timely manner and at no additional cost to Elfa or our customers.
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