WHY A CODE OF CONDUCT?

Cibes Lift Group AB’s core values – professional, progressive and personal – shall reflect our corporate culture. Cibes believes in responsible social and ethical behavior, and that the people working at Cibes shall not be deprived from human rights or suffer physically or mentally from their work. Our ambition is to live up to the expectations of our stakeholders. Therefore, Cibes and its employees are obligated to observe high standards of professional and ethical practice. This is the foundation and the reason why we have adopted this code of conduct.

The use of the term Cibes throughout this Code of Conduct refers collectively to Cibes Lift Group AB/Cibes Holding AB and its subsidiaries.

PRACTICAL GUIDELINES

In our daily work we may face situations from time to time which are not explicitly covered by the Code of Conduct or other policies and guiding documents. Often it is a question of common sense or our sound judgment. lf we are unsure about the correct behavior in a specific situation, we should ask ourselves, or discuss with a manager or colleague, the following questions:

• Is it consistent with our code of conduct?
• Is it legal?
• Is it ethical?
• Will it reflect well on Cibes Lift Group´s brand?

SCOPE

This Code of Conduct applies to Cibes and applies to all employees and subsidiaries as well as to Cibes Holding AB. The code also includes third parties such as agency workers, consultants, sub-contractors and others working on behalf of Cibes. The subsidiaries may implement their own code of conduct, in which the provisions set forth in this Code of Conduct shall be the minimum standard. Subsidiary means any legal entity which directly or indirectly controls, is controlled by or is under the same control as Cibes, regardless of country of registration.

The Vice President/Managing Director/Country Manager (“VP/MD/CM”), or person appointed by VP/MD/CM are required to review the Code of Conduct and other Company policies with new employees and with other employees on a regular basis so that all parties are fully aware of the guidelines and what they mean in the relevant context.

Violations of this Code of Conduct may result in disciplinary actions, including up to dismissal. In addition, Cibes will report violations of legislation and regulations to relevant authorities.

Employees should be aware that – apart from any disciplinary measures that Cibes may take for violating this Code of Conduct – they may be subject to prosecution, imprisonment and fines, including reimbursement to Cibes, the government or any other person or entity for any losses or damages resulting from the violation of this Code of Conduct. Moreover, employees must be aware that Cibes itself may be subject to prosecution, fines or other legal action due to the illegal or improper conduct of its employees.

HUMAN RIGHTS AND WORKING ENVIROMENT

Cibes respect all internationally recognized human rights including the lnternational Bill of Human Rights and the principles concerning fundamental rights set out in the lnternational Labour Organization´s Declaration on Fundamental Principles and Rights at Work. Cibes strive to avoid overstepping the human rights of others and address adverse human rights impacts with which Cibes is involved.

Fair employment conditions
Cibes employees should, at least, be granted statutory or by CBA determined annual leave, sick leave and maternity/paternity leave without any negative consequences. Each employee shall be provided written documentation including basic terms and conditions of the employment. Salary and terms shall be reasonable and comply with applicable law, collective bargaining agreement or industry standards. The normal work week shall on an ordinary basis not exceed a normal work week according to local rules and working hours shall comply with applicable restriction of working hours act.

Denounce of child labor and forced labor
Cibes does not accept child labor. The minimum working age at Cibes shall be the age of completion of compulsory school alt 16 years old. In cases when the employee may be younger than 18 years old, the legal restrictions regarding type of work and working hours shall be closely observed and complied with.

Cibes does not accept any form of forced labor. Forced labor according to this code includes, but is not limited to, threats or risking penalty for not performing work, deposit payment or demand to deposit personal belongings.Equal treatment and opportunities

All employees shall be treated fair and just. No discrimination, or harassment or victimization of any kind is accepted. This including but not limited to, discrimination with reference to sex, transgender identity or expression, ethnicity, religion or other belief, disability, sexual orientation, age, membership of trade unions or any other potential discriminatory factor.

Freedom of association and right to organize
Cibes respect our employees’ right to join, or not to join, an association of their choice, to organize and bargain collectively in accordance with applicable law. No employee risk being harassed or retaliated for exercising such right.

Alcohol and/or drug abuse
Cibes does not tolerate or allow alcohol abuse or the use/distribution of illegal drugs on any of the company´s premises. No one may work under any influence of alcohol or a substance that prevent employees from performing their duties safely and effectively.

Work environment
Cibes always strive to provide a good and safe working environment. We work systematically with
issues regarding health and safety for our employees. Applicable legislation and regulations regarding work environment shall be complied with.

GOOD BUSINESS ETHICS

All employees and representatives are expected to show honesty and integrity dealing with other employees, customers, suppliers, business partners, organizations and authorities. Cibes respects the laws and regulations in the countries in which Cibes operates and requires that its employees and representatives do the same. The Code of Conduct does not replace legislation and if the Code of Conduct is in conflict with legislation, the legislation prevails. However, if the Code of Conduct stipulates higher standards than legislation the Code of Conduct shall be followed.

Anti-bribery and corruption (ABC)
Cibes does not accept bribery or corruption. Employees of Cibes shall not, offer, give or solicit gifts, favors, promise, payment, entertainment or other benefits of value to any individual with the intent to improper influence a decision. Equally, no employee shall accept a benefit if there is an intent to influence the decision-making. Cibes’ Anti-bribery and corruption policy contains detailed information.

Conflict of interest
All employees have an obligation to be transparent in their business relationships and conduct business in a manner that will avoid actual or perceived conflicts of interest. Gibes strictly prohibits activities or relationships, direct and indirect, of its employees that create any actual or potential conflict of interest.

Competition and antitrust law
Gibes does not engage in anticompetitive agreements, practices or combinations. We support and strive to achieve fair competition. Cibes employees shall comply with all relevant competition legislation and regulations. Therefore, employees shall abstain from entering into anticompetitive agreements or exchanging illegal pricing and/or marketing information with competitors.

Respect for confidential information
Any information that, if disclosed, in any way risks placing Cibes in a disadvantageous position, and/or information that Cibes reasonably would like to be confidential, shall be treated confidential. Such information may only be disclosed to anyone in need of the information to perform work. Each employee shall observe the confidentiality undertaking in accordance with their employment agreements and after term i nation of employment.

Product safety
Products manufactured by Cibes shall always meet the customers’ expectations. Hence, all products shall fulfil the requirements regarding product safety in accordance with from time to time applicable legislation and regulations. Compliance with product safety legislation and regulations shall be tested regularly.

CODE OF CONDUCT IN RELATION TO OUR BUSSINERS PARTNERS, SUPPLIERS AND COOPERATION PARTNERS

All employees are expected to inform Gibes’ business partners (distributors and suppliers) of the Code of Conduct. Each business partner shall also be provided with a copy and with a copy of Cibes Code of Conduct for Business partners. The business partners are expected to observe and comply with this Code of Conduct and the Code of Conduct for Business partners. Violations of the Code of Conduct and/or the Code of Conduct for Business partners may jeopardize the business partner’s business relationship with Gibes, up to termination of ongoing business.

ACCOUNTING, INFORMATION AND FINANCIAL REPORTING

Cibes works to ensure that company information will be open, accurate, continuous, rapid and of the highest quality and;

• Comply with all legislative and regulatory requirements.
• Be clearly distinguishable in its commercial nature.
• Be mindful of sensitivities relating to cultural values, gender, race, sexual orientation and religion; and not employ themes, images, symbols or figures that are likely to be considered illegal, offensive, political, religious or demeaning.

PERSONAL RESPONSIBILITY AND WHISTLEBLOWING

All employees must study the Code of Conduct, and are responsible for knowing relevant legislation, policies and regulations.
lf an employee has a concern, wishes to make a complaint or report a violation of the Code of Conduct, the VP/MD/CM shall be contacted and informed. lf the employee finds it difficult to report an issue to the VP/MD/CM, the employee shall report the issue to Cibes’ Compliance Officer.
More information is to be found in Cibes’ Whistleblowing policy

All reports will be taken seriously and investigated appropriately. An employee’s information will be treated confidentially, and no employee will suffer any form of reprisals (such as discrimination, harassment, termination of employment) for, in good faith, reporting violations of the Code of Conduct, applicable law or participating in the Company’s investigation of a complaint.