Code of conduct

KVD Group is a conglomerate that includes subsidiaries, several business areas, and many employees. It is therefore important that we have common and fundamental values on how our operations are conducted.

Our ambition is for us to not only meet but also exceed the expectations our employees, customers, stakeholders, and partners may have of us. Our commitment is to act ethically in all situations without compromise.

KVD's core values; Considerate, Driven, Simple, and Innovative, along with the Code of Conduct and other corporate policies, are to guide us in our daily work. This does not answer how we should behave in all situations, but should help us make the right decisions daily – decisions that affect us all and that make both our workplace and the world a bit better. This is how we take responsibility!

KVD's code of conduct is based on the UN's Global Compact's ten principles in the areas of human rights, labor, environment, and anti-corruption. The principles in the code of conduct are also based on the UN's declaration on human rights, which in turn is based on the UN's declaration on human rights, the UN's global goals for sustainable development, and the ILO's fundamental conventions on rights at work, the Rio Declaration, and the UN Convention against Corruption.

Who Does the Code of Conduct Apply To?

The code of conduct applies at all workplaces where we operate and to everyone working within the KVD group - whether we are employees, interns, consultants, board members, or part of the executive management.

Employees

As employees, we all have both an individual and a shared responsibility to follow the code of conduct and to integrate it as a natural part of our corporate culture. All employees are expected to be familiar with and follow the code of conduct.

Corporate Management & Managers

Corporate management, managers, and leaders carry the culture and have a significant influence over the daily operations in our businesses.

Therefore, if you are a manager, leader, or an employee with leadership responsibilities, you have an extra large responsibility to follow our code of conduct and act as a role model for your employees.

You are expected to lead by example and are responsible for ensuring the information reaches the organization and to follow up on the code's implementation as a natural part of the operation.

Management and managers should support and guide employees who feel uncertain about applying the code of conduct in their daily work.

Our Workplaces

At KVD, we take a holistic view when it comes to health, equality, and working conditions. We see it as our duty as an employer to provide our employees with the best possible conditions to perform to their full potential - both during the working day and through all stages of life.

We consider applicable legislation and collective agreements as a minimum standard for our working conditions regarding minimum age, working hours, lone work, rest, leave, compensation, and benefits.

We will also ensure that partners offering services such as subcontractors, leased staff, staffing personnel, and interns comply with the code of conduct regarding employment conditions and work environment requirements.

We believe that clear and supportive leadership is as important as committed and responsible employee-ship. Through well-defined roles and work processes, as well as ensuring you as an employee have the right competencies and opportunities for competence development, and that your work efforts are continuously followed up, this will be achieved.

Good Working Conditions

KVD shall offer good working conditions and employment conditions for all employees to feel security in their employment, stay healthy and accident-free, have the opportunity for a healthy balance between work, family, and leisure, and good prospects to work all the way up to retirement. All our legal entities with employed staff shall be covered by collective agreements.

We consider applicable legislation and collective agreements as a minimum standard for our working conditions regarding minimum age, working hours, lone work, rest, leave, compensation, and benefits.

We will also ensure that partners offering services such as subcontractors, leased staff, staffing personnel, and interns comply with the code of conduct regarding employment conditions and work environment requirements.

We believe that clear and supportive leadership is as important as committed and responsible employee-ship. Through well-defined roles and work processes, as well as ensuring you as an employee have the right competencies and opportunities for competence development, and that your work efforts are continuously followed up, this will be achieved.

Work Environment & Health

KVD's workplaces shall be safe, injury-free, and healthy. Employees and managers have a joint responsibility for each other and our work environment.

We believe that systematic work environment efforts focusing on health-promoting activities and new perspectives on health help us create a better workplace with healthy employees.

Our workplaces shall be drug-free, and through various activities and health initiatives, our employees are given the opportunity for healthy living habits. We are convinced that all work-related accidents and illnesses can be prevented. We always prioritize safety first. We have a zero vision for work-related accidents and commit to providing a healthy and safe work environment for all our employees, including necessary information and training.

If you as an employee see a risk or risky behavior, you are expected to act by alerting or directly stopping the dangerous work.

Equality & Diversity

KVD shall be a role model from a gender equality and diversity perspective, and as a part of the business community, we should help meet society's various challenges.

For us, this means that all employees shall have equal treatment, equal opportunity for career and development in work regardless of gender, ethnic background, religious affiliation, sexual orientation, disability, functional variation, or age.

Decisions concerning employment, promotion, salary setting, working conditions, disciplinary actions, or termination of employment shall be based on the employee's ability or performance, not on irrelevant personal-related factors.

At our place, every employee shall:

• have the opportunity to feel joy and security at work.

• feel accepted as individuals in the workplace and be treated with respect by all colleagues, customers, and other partners.

• have their salary determined based on factors that solely depend on market salary, the difficulty level of the position, and based on their own performance and competence.

• experience that development opportunities within the company are equal for everyone.

• be given the opportunity to exercise the right and obligation to care for and raise their children.

• have the opportunity to combine work life, career, and family.

Zero Tolerance for Harassment & Discrimination

At KVD, we do not accept any form of offensive treatment, harassment, or sexual harassment in our workplaces.

For any such incidents, we have a preparedness and a developed action plan to counteract, prevent, and resolve issues surrounding all forms of offensive treatment.

As an employee, you are expected to treat all fellow humans with respect and act or sound the alarm in any such events to counteract all forms of bullying, exclusion, hazing, and unequal treatment.

Freedom of Association

We respect our employees' freedom of association and applicable collective agreements. KVD's employees have the right to form or join trade unions, and we respect our employees' and their trade unions' right to negotiate collective agreements and co-determination in the workplace.

Protection of Personal Data

At KVD, we handle personal data responsibly and comply with all applicable legislation regarding personal data when we collect and share these. This applies to personal data for employees, job applicants, consultants, interns, etc., and our customers' personal data.

Information & Communication

At KVD, we share information, and we believe in transparent and open communication but keep confidential information secret in all situations.

As an employee at KVD, you may not spread or misuse confidential information. Examples of confidential information are non-public information about KVD's operations, results, strategies, business transactions, business plans, business processes, etc.

The commitment to preserving confidential information also applies after an employment or consultancy assignment has ended.

Licenses & IT Systems

Only approved systems and software may be used on the company's IT tools. Only computers, phones, tablets approved and configured by the IT department are approved for use in the service and/or in KVD's network.

If users need additional software or equipment, this must be approved by the IT department. The purpose is to ensure that applicable licensing models are followed and that the equipment meets the company's security requirements regarding virus protection.

Respect and Care for KVD's Property

KVD has both physical assets (facilities, equipment, work tools, etc.) and intellectual property (computer systems and programs, concepts, trade secrets, brand, etc.) that our employees or other contractors have access to during employment. KVD's assets may only be used for legitimate business purposes and not for personal or others' profit.

As an employee at KVD, you have, during the use time, the obligation to protect KVD's property and assets against damage, theft, and misuse. Upon termination of employment, all physical property and assets belonging to KVD must be returned.

Respect and Care for Our Clients' Property

KVD also handles property owned by our clients. This places high demands on respectful and careful handling of our clients' property.

We Take Responsibility for the Environment

KVD actively works for a sustainable society and thus needs employees who take responsibility. With large and small efforts and wise choices, we should do what we can to drive the transition to a climate-friendly society and minimize our operations' impact on the environment and carbon emissions.

Sustainable Offices & Workplaces

At our workplaces, there should be opportunities for source separation, and we make it easy to recycle by:

• placing environmental stations for waste management for the waste that can be recycled.

• We aim for reduced consumption of paper and other office supplies and have minimized the use of disposable items.

• We use energy responsibly by, where possible, installing motion sensors for lighting and using LED bulbs. Our employees receive instructions to turn off all electronics when not in use.

Business Travel

In our policy for business travel, we advocate for the most environmentally friendly travel option to reduce the environmental impact.

In the first instance, the possibilities of conducting a meeting remotely (via web or phone) should be considered before deciding on a business trip. In the second instance, we should choose transportation modes that have the least possible environmental impact.

When choosing company cars, models that meet the requirements for a climate bonus, if possible, are allowed.

Own Transport

Transports account for nearly 70 percent of the group's total climate impact measured in tons of greenhouse gases. Our own transports should always be fully loaded and always fueled with environmentally friendly diesel (24 percent renewable).

Car Wash & Reconditioning

When choosing partners for car wash and reconditioning at our facilities, we should consider environmentally friendly alternatives and ensure water saving and more environmentally friendly chemicals or correct handling of hazardous waste.

Requirements for Suppliers & Partners

Employees at our place responsible for purchasing and selecting suppliers should set requirements for suppliers' products and their environmental work, especially on aspects such as how products are shipped and transported, environmentally friendly products, source separation, and handling of hazardous waste.

Employees Who Take Responsibility

KVD actively works at every stage of our operations to minimize environmental impact. Therefore, we continuously work with information and training for both staff and customers. We see positively that employees present environmental improvement suggestions in daily operations.

As an employee at KVD, you are also expected to act if you discover behavior, damage, leakage, or anything else that can affect the environment, e.g., oil spills, and always report all environmental deviations to management.

We Do Business with Good Business Ethics

All employees and representatives of the KVD group are expected to act with good business ethics when we do business with customers, suppliers, and other business partners. We follow the code of conduct and applicable laws when conducting our business.

Each of us is expected to have basic knowledge of the laws and regulations covering the operations we conduct and the tasks we perform. Below is an overview of some of the ethical requirements we have on us when we do business in our operations.

Choice of External Partners

When choosing external partners - such as suppliers, distributors, consultants, and other types of business partners - we should assess their ability to live up to the principles in our Code of Conduct.

Everyone we collaborate with should be able to meet the same standards that we have committed ourselves to regarding human rights, working conditions, business ethics, and the environment.

If our partners deviate from our standards, we should use our influence to change their behavior or refrain from the cooperation. In this way, we can minimize the risk of doing business with companies or individuals subject to sanctions, being part of facilitating corruption or money laundering, financing terrorism or economic crime, or being linked to serious negative impacts on human rights, labor conditions, or the environment.

Conflict of Interest

A conflict of interest arises when an employee's private interests in some way collide or appear to collide with KVD's interests. The existence of a real or potential conflict of interest does not necessarily violate the Code of Conduct, but all employees have a responsibility to inform and consult with the nearest manager or HR in potential conflict of interest situations and conflicts of interest.

It is not possible to cover all situations where conflicts of interest may arise, but the following list provides guidance on how to avoid potential situations.

Conflicts of interest include:

• Employment, other side business or secondary occupation that competes with the KVD group's operations, affects the work, can damage KVD's trust, or puts you in a situation where your independence is compromised.

• Use of insider information or other confidential information for personal gain.

• If you, a close friend, or family member has financial interests in a company or business that does business with or otherwise can affect KVD's operations.

• Handling business, matters, or issues that include relatives, close relationships, or where you can be perceived to act in your own or a close one's interest.

• Employment of close relatives and others with whom you have a close personal relationship, direct work management over, or direct reporting of a relative, unless the situation has been reviewed and approved by the HR department in advance.

• Exploiting information or business opportunities discovered during working hours, or using KVD's property, information, or position for personal gain.

KVD does not take a political stance, and therefore we do not use funds from the group to support political campaigns or other political purposes.

Accounting & Financial Reporting

KVD shall have accurate accounting that complies with applicable laws, regulations, accounting standards, and norms.

Financial information and other price-sensitive information shall be communicated according to applicable law, stock exchange rules (including listing agreements), and other regulations.

Frauds

KVD does not accept fraud in any form. Fraud includes, among other things, employees or another person misleading (deceiving) or attempting to mislead the company or abusing the company's trust through actions that involve personal financial gain.

Corruption

KVD has zero tolerance for all forms of corruption and will actively work to ensure that it does not occur within the group.

Corruption refers to the misuse of a position of trust for one's own or the company's gain, e.g., through the application of bribes. It is prohibited to offer, promise, give, request, accept a promise about, or receive a bribe. A bribe is a gift or other benefit that can influence another to unduly favor the giver within the framework of their employment or assignment.

We follow applicable anti-bribery legislation and the Swedish code on gifts, rewards, and other benefits in business. No form of extortion, bribes, or payments that can influence decisions are accepted.

As an employee at KVD, for example, you may not offer, give or receive, or request gifts, services, entertainment, or other benefits that:

• conflict with general business practice or applicable legislation.

• have an unreasonable value and consist of money, securities, money loans, other forms of personal payments in the form of discounts, commissions, bonuses, or commissions.

• consist of pure pleasure or holiday trips or excessive business representation.

• are offered to partners in connection with an imminent or ongoing procurement or business decision.

• due to its value or other relevant circumstances, risk improperly influencing the recipient in the exercise of their professional assignment or otherwise risk embarrassing the company or the employee if made public.

However, this does not prevent KVD group's employees from accepting or offering benefits aimed at maintaining and promoting good business relationships with customers and other partners. The condition is that such benefits are moderate, accepted, and offered openly and are otherwise in accordance with this code of conduct and the Swedish code on gifts, rewards, and other benefits in business.

We Do Not Handle Cash

We counter the risk of money laundering by KVD never accepting cash payment. When a need for repayment from KVD to a buyer arises, this repayment is always made to the account from which the payment was made. Thus, KVD can never be a channel through which cash changes owners without a sale of an object having taken place.

Information, PR & Advertising

KVD's information work and contacts with the media and journalists should increase knowledge about and trust in the operation.

We provide factual and clear information and adapt our communication to the target group and situation. We are always professional, prepared, and knowledgeable about the subject.

We Support and Strive for Fair Competition

Employees in the KVD group shall follow all relevant competition rules and refrain from entering illegal competition-restricting agreements and exchanging illegal price and/or market information with competitors.

We Follow Applicable Rules for Export Control

KVD shall comply with all applicable rules regarding export control, including not acting contrary to, or with persons designated in, economic sanctions.

KVD shall further not trade with or export sensitive goods without the necessary export permits.

We Respect Human Rights

KVD is committed to respecting and promoting international human rights. Our commitment extends across the entire value chain.

If we cause, contribute to, or are otherwise associated with serious violations of human rights, we shall take action. Forced labor, involuntary labor, or child labor in any part of KVD's value chain is never accepted.

Active Stance Against Purchasing Sexual Services and Child Pornography

Purchasing sexual services, sexually exploiting children, child pornography is illegal according to legislation in many countries, including Sweden, and can support human trafficking (trafficking), which is a violation of human rights.

Employees in the KVD group on assignment and business trips are expected to respect KVD's stance. This applies regardless of the country and both during and after working hours.

We Speak Up

At KVD, it is important that everyone representing the company acts according to our values and follows the Code of Conduct, as well as applicable laws, guidelines, and policies. If you as an employee notice something that does not seem right or that violates the Code of Conduct, we want you to speak up!

Employees and managers are expected to act upon suspicion of something that violates the code of conduct, the company's policies, or other legislation. KVD provides several opportunities to report suspicions of violations.

In many cases, early reporting can help quickly address a problem and prevent or minimize damage.

How Do You Raise an Issue?

• Talk to your manager or your manager's superior.

• Contact the relevant function, e.g., IT, finance, or the communications department.

• Make a report to HR. If you as an employee feel that the reporting is not taken seriously, or do not feel comfortable reporting the suspected crime through any of the above, there is an opportunity to report anonymously via KVD's system for Our Whistleblower Function.

The Report Can Be Made Anonymously

Your report can be made anonymously. However, we recommend that you identify yourself if you report an irregularity or a problem because it would facilitate KVD to collect all the facts, investigate your report, and have a confidential dialogue with you.

What Happens to My Report?

When you have made a report, KVD will investigate the situation and take appropriate actions. All reports shall be taken seriously and will be investigated.

An honest report never leads to negative consequences for the reporter. There must not be any form of punishment against an employee who in good faith reported a crime or suspicion of a crime against the Code of Conduct. This applies regardless of the result of the investigation.

What Happens in Case of "Violations" Against the Code of Conduct?

In cases where employees choose not to follow the Code of Conduct, the company's policies, or the laws and regulations that apply to the work, it can lead to disciplinary actions such as verbal or written reprimand, reporting to the relevant authorities, and in serious cases termination, dismissal, or prosecution.

Serious crimes consist of, for example;

• Economic crime such as bribes, fraud, corruption, and forgery.

• Significant safety deficiencies at the workplace with danger to health and life.

• Significant violations of environmental regulations and major risks of environmental pollution.

• Serious forms of discrimination and harassment.

We can all face difficult situations and choices, and there is not always an easy answer, so never hesitate to consult with a manager or HR department if you feel unsure.