Code of Conduct Germ AB

Germ AB is a company that strongly believes in long-term, sustainable relationships based on

responsible social and environmental conduct.

Germ AB and its business partners have an obligation to all stakeholders to observe high standards

of integrity, performance, and exemplary conduct. The foundation for and the reason why Germ AB

has created the code of conduct is that we are convinced that sustainability is a natural part of being

a successful business and we always strive to act in an ethical, transparent, and responsible way and

expect our business partners to do the same.

The Code of conduct, from now on referred to as the Code, applies to suppliers of products or

services to Germ AB or directly to Germ AB:s customers.

Germ AB recognizes that there are different legal and cultural environments in which our suppliers

and their production units operate. We expect our suppliers to follow internationally accepted labour

standards, including the conventions of the International Labour Organization (ILO) and to

continuously work on improving the labour conditions for those involved. Germ AB also expect

that our suppliers have an ambitious program for minimizing the negative environmental impact of

their business.

Legal compliance

Germ AB requires all suppliers to operate in accordance with the principles of the Code and in full

compliance with all applicable laws and regulations. The Code does not replace legislation and if

the two are in conflict, legislation takes precedence. If the Code sets a higher standard than the

existing legislation, the reverse applies.

Human rights in the workplace

Forced Labour

• Suppliers or sub suppliers should not use any form of forced labour, including prison labour

or bonded labour as defined by ILO conventions 29 and 105.

• Suppliers or sub suppliers should not require their employees to pay any kind of deposits,

nor may they retain their employees’ identity documents.

Child Labour

• Germ AB strongly opposes child labour.

• A child is defined as a person younger than 15 years of age, or as an exception, 14

years of age in countries referred to in article 2.4 of the ILO convention 138. If the national

legal age for working is higher than 15 years of age, the supplier must adhere to the higher

requirement.

• The supplier shall establish and implement a child labour policy ensuring that no child is

employed.

• If child labour is detected in the production of goods for Germ AB the supplier is obliged to

offer a sustainable solution in the best interest of the child.

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• Young employees (below the age of 18 years) may only be employed in non- hazardous

work, if they are above the country’s legal age for working.

Freedom of Association and Collective Bargaining

• All employees must be able to exercise their legal right to form or join a trade union and

participate in collective bargaining without threat of reprisal, intimidation, or harassment

(ILO conventions 87, 98 and 135).

• In countries where freedom of association is restricted, the company should strive to create

an environment in which the company management and employees can discuss salaries and

working conditions in a non-threatening manner.

Humane Treatment

• Suppliers or sub suppliers should treat all employees with respect and dignity. Physical

punishment or the threat thereof, sexual or racial harassment, verbal abuse or power abuse or

any other form of harassment or intimidation is unacceptable under any circumstances.

Discrimination

• Suppliers or sub suppliers should not apply any type of discriminatory practice as regards

the recruitment, compensation, promotion or the termination of an employment agreement

based upon race, caste, ethnicity, social origin, marital status, sexual orientation, disability,

religion, nationality, age, gender and/or union membership or political affiliation (ILO

conventions 100 and 111).

Wages and Benefits

• Suppliers and sub suppliers should pay its employees at least minimum wage or the

prevailing industry standard, whichever highest. The amount should be sufficient to cover

basic needs for the employee and their family as well as provide some additional income.

• Wages and over time premiums and any incentive (or piece) rates should be paid directly to

the employee on time and in full.

• Suppliers or sub suppliers should provide their employees with paid sick leave, maternity

leave annual leave and statutory holidays as required by law or the prevailing industry

standard, whichever is highest.

• To make unfair or illegal deductions from wages or the removal of benefits as a disciplinary

measure is not permitted.

Work environment

• The supplier acknowledges that a safe and healthy work environment contributes to

improvement in the quality of goods and services and to motivation of the workforce.

• The Supplier ensure that it has organization systems, processes and/ or measures in place in

order to comply with national health and safety legislation.

• The supplier shall identify, assess, and take measures to eliminate potential safety risks. The

employees shall be informed of potential safety risks and instructed on proper, safe

behaviour and the corresponding safety measures to be implemented. Should such measures

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not afford adequate hazard management, the employees shall be provided with suitable

personal protective equipment.

• Potential emergency situations and events shall be identified and evaluated. Their impact

shall be minimized by implementing emergency plans and reporting procedures.

Environment

• Suppliers should comply with existing environmental legislations and obtain all legally

required permits, licenses, and registrations applicable for their business.

• Suppliers are committed to comply with REACH*, CLP* och RoHS* regulations.

Conflict minerals

• The supplier is committed to comply with relevant laws and regulations requiring disclosure

of the use of conflict minerals. Conflict minerals are minerals from high risk and conflict-

affected areas that have directly or indirectly contributed to financing of armed groups,

where some groups are believed to be responsible for serious human rights violations.

Goods provided to Germ AB shall comply with relevant laws and regulations regarding

conflict minerals. The supplier is liable to inform Germ AB if the product/products contain

conflict minerals. The supplier shall, if applicable, report import of tantalum, tin, tungsten,

and gold according to EU Legislation.

Reach

• If a product delivered to Germ AB contains more than 0.1 percent (by weight) of a substance

on the candidate list, the supplier is liable to provide Germ AB with information about this

in accordance with REACH, Article 33.

CLP

• The CLP Regulation ensures that the hazards presented by chemicals are clearly

communicated to Germ AB through classification and labelling of chemicals. CLP stands for

Classification, Labelling and Packaging. The CLP Regulation entered into force in January

2009, and the method of classifying and labelling chemicals it introduced is based on the

United Nations' Globally Harmonized System (GHS).

RoHS

• Items and products supplied to Germ AB must comply with EU-legislation RoHS which

restricts the use of heavy metals, flame retardants or plasticizers to levels of less than

100-1000 ppm used in electronic products. Currently ten restricted substances: lead,

cadmium, mercury, hexavalent chromium, polybrominated biphenyls (PBB) and

polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl

phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP).

Climate footprint

• Germ AB want the supplier to calculate the carbon footprint of items supplied to Germ

according to Greenhouse Gas Protocol, Scope 1, 2 and 3. The results of these caclulations

shall be presented to Germ upon request.

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Business ethics

• Germ AB respects laws and regulations and requires that its business partners do the same.

Germ AB does not accept any corrupt activities, including but not limited to bribery,

conflicts of interest, fraud, extortion, tax evasion, embezzlement and unlawful kickbacks,

and the supplier shall not engage in, or cause Germ AB to engage in, any form of corrupt

activities.

• Germ AB:s supplier shall comply with applicable competition and antitrust laws and

regulations. This means, among other things, not to engage in price fixing, bid rigging or

customer allocation.

• Germ AB does not accept facilitation payments in any form.

Implementing and monitoring

• Germ AB may conduct remote audits on suppliers or on the supplier’s premises upon

request.

• Violations against the Code will be handled immediately with a corrective action plan.

Negligence of correcting the violation or repeated violations may jeopardize the supplier’s

business relationship with Germ AB.

• Germ AB want the supplier to audit their sub suppliers in the same way and the results of

these audits shall be presented to Germ AB upon request.

• All Suppliers are recommended to achieve and maintain certification on the International

Organization for Standardization (ISO) 14001 Environmental Management System

Standards: the ISO 9001 Quality Management Standard. Suppliers who have certifications

to similar standards or who are working to obtain initial certification must submit the

alternate certificate.

Raising concerns

Should you or your employees believe that the terms of the Code of Conduct are not adhered to or

that Germ AB is not acting in accordance with its own Code of Conduct then we encourage you to

raise your concerns to Germ AB:s Supplier Quality Management at Germ AB All communication

regarding these matters will be handled confidentially.