PRODUCTS

We offer a competitive product assortment from a sustainability perspective, as well as a strong eco assortment. New sustainable materials, technologies and business opportunities will be pursued in our product development.

OPERATIONS

We continuously reduce the negative impact from our operations, transport and waste. We strive to reduce our use of energy and resources in processes and products. We believe renewable is the best long-term option.

WAYS OF WORKING

Environmental considerations are included in all relevant decisions. Our environmental initiatives are characterized by continuous improvement and review, and we go beyond our operations. Our employees are encouraged to assume personal responsibility for the environment in their professional work.

KNOWLEDGE & COMMUNICATION

We are perceived as an industry leader and a trusted partner in environmental matters. Our employees are high-skilled and trained in environmental matters. Information about the yearly environmental impact of our activities and our products is open and communicated proactively.

CHILD LABOR

Duni sites must follow all national laws and regulations as well as ILO conventions 138 and 182 regarding minimum age and applicable types of work.
ILO = International Labor Organization

WORKING CONDITIONS

Duni may not use or permit physical violence, psychological force or any form of non-physical ill-treatment, including threats of violence, sexual harassment or other verbal ill-treatment.

A clean production environment is important for the workers’ well-being and for the quality of the manufactured products.

All facilities must be well-ventilated to ensure the adequate circulation of air and temperature. The lighting must be adequate for the performance of work at all times of the day.

Clean sanitary facilities must be available throughout the working hours and be accessible without unreasonable restrictions on their use.

SAFETY

All production and administrative facilities must have employers’ safety as a priority at all times. Applicable local law and regulations with regard to safety at work must be observed and documented. For example, see the points below:

There must be sufficient and clearly marked exits allowing an evacuation in case of an emergency. The exits must be kept free from obstructing objects and be unlocked, and a key must be accessible to all at all times.

An evacuation plan must be displayed. Evacuation drills must be carried out.

Fire extinguishers must be regularly maintained and kept visible and accessible to all staff.

First aid equipment must be available.

Machinery must be equipped with operational safety devices and maintained on a regular basis. Personal protective equipment must be available when needed. Hazardous materials must be stored in secure and ventilated areas.

WORKERS’ RIGHTS

The following conventions must be observed, which state, among other things, the following:

ILO conventions 29 and 105 which s tate, among other things, that the production facility must not use involuntary or uncompensated labor of any kind, including prison labor.

ILO conventions 29 and 105 which s tate that if foreign contract workers are hired, they must not be required to remain employed for any time of period against their own will. The respective facility must pay any recruitment fees and other commissions to the recruitment agency.

ILO conventions 100 and 111 which s tate, among other things, that no employee may be discriminated because of race, color, gender, nationality, religion or ethnic background.

ILO conventions 87 and 98 which s tate, among other things, that all employees should be free to join associations of their own choosing, and the respective facility must not interfere with employees who wish to lawfully and peacefully organize or bargain collectively. The decision to organize or not must be solely a decision by the employees.

Duni shall act with good business practice in accordance with the Group’s ethical standards and expectations.

Duni has many employees who have daily contact with customers, suppliers, owners, representatives of society and other stakeholders. They expect Duni to maintain a high ethical profile and observe good business morals.

The Business Ethics Policy is based on the view that Duni shall be operated profitably while maintaining good ethics. Above all, this covers how managers and employees shall act when coming into contact with customers, suppliers, owners, competitors and other external parties.

Duni expects all third parties i.e. suppliers of which Duni has a relation with to comply with our Business Ethics Policy and applicable laws in respective country.

All employees have a responsibility to identify and report any possible corruption issues with external parties that Duni has a relationship with.

FRAUDULENT CONDUCT

It is of the utmost importance that all of Duni’s business operations are characterized by the highest possible standards of responsibility, openness and honesty. Any suspicion of fraudulent conduct, corruption or other similar situations must be reported without delay to the HR Director or CFO. This can easily be done in person, by a phone call, through an email or anonymously via a letter.

Fraudulent conduct can bring disciplinary sanctions and lead to criminal charges. Major fraudulent conduct can lead to a report being giving to the authorities.

CONFLICTS OF INTEREST

Employees must avoid ending up in situations in which personal, familyrelated or financial interests may conflict with the interests of Duni. If any such situation were to occur, the employee must report this and seek the advice of a higher manager.

CONFIDENTIALITY

Employees must not pass on confidential information acquired in connection with their employment, nor must they utilize such information for their own gain.

If third-parties share confidential information with Duni or vice versa, that information shall be handled with the same care as if it was Duni’s confidential information.

BAN ON COMPETITION FOR DUNI EMPLOYEES

It is forbidden for employees of Duni to run – either wholly or in part – a company which competes with Duni’s business. Duni expects all employees to act only in the best interests of the Company. All kinds of competition against Duni are prohibited. All Duni employees are responsible that Duni complies with applicable competition laws.

Ban on co-operation with competitors:

Duni expects all employees to act only in the best interests of the Company. Avoid situations or activities where your personal interests are, or may appear to be, in competition with or in opposition to Duni’s interests.

You may never speak to a competitor about:

Prices or price components
• Business terms
• Allocations of geographic regions, customers, products or market shares
• Production or sales quotas
• Costs of capacities
• Intended investments
• Concerted actions against suppliers or customers
• Fixing bids in tendering procedures or any similar matter
• If you are uncertain about what you may speak about, seek guidance or advice from responsible manager

GIFTS / CORRUPTION / BRIBES

Duni condemn any form of corruption and bribery and this includes facilitation payments to induce public official to perform their duties. All Duni employees and related parties are responsible for ensuring Duni is compliant with applicable anti-bribery laws.

A bribe is defined as a reward, benefit, or gift to another person with the intent to induce improper performance of a business or public function. This may involve cash, but it can also relate to goods, travel, services, discounts, gift cards or various kinds of hospitality. It is improper to give or receive benefits which involve the recipient having to act in a certain manner when doing their job. Even if the risk of the employee being influenced is small, the action is still improper. There is no set limit for what is to be regarded as bribe; the value of the benefit to the recipient is the crucial factor.

However it is always prohibited to give or receive:

Monetary gifts and similar monetary advantages
• Monetary loans
• Kickbacks
• Contributions to political parties, political candidates etc.

Below some examples of red flags:

• Costs of capacities
• Intended investments
• If the Benefit has substantial value or is granted frequently
• If the recipient of the Benefit has work tasks that include exercise of public authority or is carrying out public procurements
• If the Benefit has no clear connection to the recipient’s work or assignment
• If the Benefit does not form a natural and useful part of the recipient’s work or assignment
• If the employee or Contractor is invited to an event with private companion
• If the Benefit is directed at specifically selected individuals
• If the Benefit is not granted overtly
• If the Benefit is not proportional to the purpose of the Benefit
• If the Benefit is initiated by the recipient

ENTERTAINING / EVENTS

Entertaining may be focused either outwards, towards Duni’s business associates, or inwards, towards Duni’s staff. Entertaining must be done with restraint and correspond to what may be considered reasonable in each individual case. When in doubt you should seek guidance or advice from responsible manager.

An event that is aimed at a wider group of people, is useful for Duni’s business or for networking/socializing with customers and third parties and is otherwise not extravagant, is typically permitted.

REPORTING CULTURE – WHISTLE-BLOWING

All employees are responsible for immediately reporting any discovered violation of the ethical rules or breaches of domestic laws to their managers, to the HR Director or any member of the Duni Management Team. Duni guarantees the employees anonymity, and that a whistleblower can never be adversely affected.

Please also read Duni’s whistleblower policy.

MONITORING, EVALUATION AND REVIEW

Duni is responsible for ensuring that all employees and other covered under this Policy are informed about Duni’s Business Ethics Policy. This is easily accessible for all at Duni intranet. It is translated in eight different languages.

The Policy is annually reviewed by the Audit Committee and finally approved by the Board of Duni.

FAILURE TO COMPLY

Deviation from this Policy may lead to disciplinary action, possibility of dismissal and legal proceeding/criminal charges.

PURPOSE

The wellbeing and safety of our employees is at the core of the Duni Way of doing business. A safe and healthy business environment is important for the long-term sustainable growth of Duni. Safety should always be considered first to ensure our own and others’ health and safety.

Duni shall always meet legal and stakeholder requirements for health and safety. The Duni Code of Conduct and the General Requirements details the social expectations of all Duni manufacturing and office sites. We adhere to ILO conventions as detailed in our Code of Conduct. The Duni Global Health & Safety Policy is a summary of our commitment and expectations and is directed to all employees, leaders, contractors and visitors within the Duni Group.

COMMITMENT, COLLABORATION AND DIALOGUE

Duni leaders of all levels are role models for safe behavior. Safety is ensured only when Duni leaders are constantly seen to act to validate the importance of the wellbeing and safety of all. Duni leaders are responsible to ensure open dialogue with employees, compliance with the formal policy, and local health and safety procedures. Leaders shall act promptly to report unsafe conditions.

Duni employees are responsible to engage and act as role models for work safety and adhere to local health and safety procedures. Training and understanding are at the heart of a safe working environment. All employees shall have sufficient training and feed-back to act safely. Information on health and safety has to be available in a language which the employees understand.

EACH MANUFACTURING SITE

At each manufacturing site there shall be a means for collaboration on safety issues. This as a rule includes but is not restricted to safety committee, worker representatives chosen by themselves and documentation and communication on safety work progress.

Each manufacturing site shall have:

A statement for local management commitment for Health & Safety
• Workplace risk assessments, including when making changes
• Health and safety instructions and warnings where relevant
• Procedures for regular safety inspections or assessments to identify unsafe behavior. These may take many forms, like safety commitment rounds, peer-reviews, internal audits, housekeeping etc.
• Regular health assessments as per identified risks or local law
• Incident and accident reporting
• Clearly communicated activities or goals to ensure continuous improvement.

AVAILABILITY AND FOLLOW-UP

This Health and Safety Policy provides a framework for local policies and is available to all employees on the intranet and to other stakeholders at www.duni.com. Duni Group will monitor compliance through regular on-site Code of Conduct audits at own manufacturing. Duni Group will also report injuries in yearly reporting. Whistle-blower policy will be handled at board level in accordance to set procedure.

Further, we believe that whistleblowers who come forward with reports of wrongdoing are acting as exemplary organizational citizens by assisting us in promoting integrity, accountability and good management.

When a whistleblower comes forward with information about wrongdoing, the management at Duni commits to:

• Protect the whistleblower from any adverse action taken as a result of making the report. Any bullying, harassment unfair treatment, victimization or discrimination that results from a report being made will be treated as a breach of our disciplinary procedures;
• Deal with the report thoroughly and impartially;
• Where some form of wrongdoing has been found, Duni will take appropriate action to rectify it; and keep the whistleblower informed of progress and the outcome if applicable (e.g. given that the whistleblower is not anonymous)

The owner of this policy is the HR Director at Duni.

WHO IS COVERED?

This policy should be adopted, distributed and available to all concerned: • A permanent employee, whether full-time or part-time;

• A consultant working for the organization; or
• A contractor working for the organization, including an employee of the contractor; and
• Suppliers who are part of a business agreement that incorporates Duni’s Business Ethics and Whistleblower policies.
• All listed above may voluntarily use Duni’s whistleblower system.

DUNI’S DIFFERENT REPORTING CHANNELS

If you encounter something that you perceive to be illegal or in violation of Duni’s Business Ethics or any other internal policies, initially your concerns should be addressed to your manager, designated HR, or Finance department. They are obligated to take appropriate measures to adequately address the issues brought put in front of them.

However, if you have information about serious infringement/violations of laws and you have good reasons to believe that your concerns will not be regarded appropriately, you can file a report in the whistleblower system.

WHEN TO USE THE WHISTLEBLOWER SYSTEM

The whistleblower system should, unlike the normal reporting procedures, only be used if the suspicions concern employees with key and sensitive positions, that is those who maintain trusted positions and exercise sensitive duties and whom by their position or role can significantly affect Duni or Duni’s operations, risk and safety situation.

The use of the whistleblower system is appropriate if your concerns relates to one of the following:

• Serious wrongdoings referring to persons in key positions or a leading position within Duni.
• The processing may only refer to serious wrongdoing that may involve illegal or unlawful behavior.

For instance it might involve:

1. An unlawful act, whether civil or criminal
2. Serious breach of the Duni’s Business Ethics
3. Knowingly breaching local laws or regulations of any country
4. Questionable accounting, fraud or auditing practices
5. Practices likely to cause physical harm or damage to a person or to property
6. Practices likely to cause environmental hazards or damage
7. Abuse of power of authority for any unauthorized or ulterior purpose
8. Unfair discrimination such as discrimination based on age, race, gender, religion, sexual orientation, marital or maternity status, political opinion or ethnic background in the course of employment or provision of services
9. Conflict of interest
10. Manipulation of company data/records/systems

This list is not definitive but is intended to give an indication of the kind of conduct, which might be considered wrongdoing.

HOW TO FILE A REPORT IN THE WHISTLEBLOWER SYSTEM

A whistleblower report can either be reported by e-mail or mail.

The contact details are: E-mail: duni@claimdesk.pwc.se. The information sent via e-mail will be encrypted.

Mail: “Duni”, Claim desk, PwC, 113 97 Stockholm

You can provide whistleblower reports in Swedish, English, Polish, Russian, German, French, Dutch and Mandarin.

Concerns should include the following information:

• What type of wrongdoing has been observed
• Who is suspected of having committed the wrongdoing

Duni encourage you to provide as detailed information as possible, in order ensure that the report can be facilitated safely and efficiently.

It is optional to provide your name and contact information when filing a report. If you do, you may be contacted for further information.

Duni has engaged an external party as a receiver of the raised concerns; this external party will report back raised concerns to Duni’s attention for further handling and investigation.

ANONYMOUS REPORTS AND FURTHER INVESTIGATION

A filed concern through the whistleblower system is treated with full confidentially. You can file a report and feel safe in the knowledge that highlighting and resolving of the issue will be given the highest priority from Duni.

Every reasonable effort will be made to maintain the confidentiality of the person raising the issue or concern. The identity of that person will not be widely disclosed without her/his permission, unless disclosure is necessary or appropriate in order to conduct an adequate investigation or to meet legal and/or regulatory requirements. In that event, notice, where reasonably possible, should be given to the complaining party.

Irrespective of whether the investigation confirms the allegations, no person who comes forward in good faith will be subject to any disciplinary or any other punitive action, solely as a result of raising such concerns. However, a person who abuses the procedures by raising a concern they know to be untrue or uses the process for inappropriate purposes will be subject to disciplinary action.

If you have been involved in the wrongdoing yourself, you should be aware that the fact of making your report will not protect you from disciplinary or criminal action.

Duni will designate external or internal investigators that are independent of, and not involved in, the allegations made. Duni determine

a)whether an investigation is appropriate;
b)the scope of the investigation;
c)the form the investigation should take; and
d)to whom the report of the findings should be made.

The whistleblower will be informed of action taken as a result of the whistleblower report (given that the whistleblower is not anonymous).