PARTNER CODE OF CONDUCT

Kemppi is committed to conducting its business in compliance with all applicable laws and regulations, act upon the highest ethical standards and treat others with respect and integrity. This Kemppi Partner Code of Conduct (“Code”) illustrates the values according to which Kemppi operates globally. Kemppi expects all its Partners to adopt and comply with the ethical business standards, policies, and values defined in this Code.

Business Conduct

We expect you to:

• comply with all applicable laws and regulations

• compete fairly and ethically and within the framework of applicable completion laws

• ensure you and third parties acting on your behalf do not offer, give, or accept improper or corrupt payments, including facilitation payments, improper gifts, entertainment, gratuities, favors, donations, or any other improper transfer of value. In particular, you will not engage in any form of bribery or kickback scheme or otherwise offer any incentive to Kemppi employees to obtain or retain any business

• comply with all laws that prohibit money laundering or financing for illegal or illegitimate purposes

• respect our and third parties' intellectual property and confidential information conduct your business in accordance with applicable trade compliance laws and regulations, including embargoes and sanctions, customs regulations, import and export regulations, export controls, customs valuation, country of origin, and preferential trade'

• implement systems, controls, and policies to promote compliance with applicable laws and this code, including training, monitoring and auditing mechanisms.

• to monitor and consider all global and/or local sanctions (including but not limited to any sanctions administered by the authorities of the US, the UN, the EU, the UK, or other relevant sanctions authority) and refrain from directly or indirectly offering, marketing, selling or delivering any products or services to any customer (including both entities and/or individuals) to whom such offering, marketing, selling, or delivering would be in violation of any sanctions in force, international treaties, or any national laws

Human rights

In accordance with the UN Universal Declaration of Human Rights and the core conventions of the International Labour Organization (ILO), we expect you to:

• respect fundamental human rights

• treat people with dignity, decency, and respect, and avoid any kind of discrimination,harassment, intimidation, oppression or exploitation of your employees never use any form of forced or child labor

• respect freedom of association and collective bargaining

• respect the privacy of the personal information to which you have access and process personal information only for legitimate business purposes and in compliance with applicable laws

• pay compensation to your employees that comply with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits.

Environment and safety

We expect you to:

• seek to lower your environmental footprint

• provide safe and healthy working conditions for your employees and contractors

• comply with Kemppi's safety requirements when working at or visiting Kemppi's premises and undertake necessary safety training.

Kemppi's commitments to its Business Partners

In relation to our Business Partners, we will:

• select and treat our Business Partners fairly and objectively at all times

• conduct our business ethically

• adhere to the terms and conditions of our agreed contractual obligations and address any exceptions in a timely manner to ensure that our suppliers' sustainability credentials are part of our supplier selection process, and, where appropriate, sustainability criteria are used in the award of contracts

• seek to ensure that our Business Partners understand and comply with this Code.

Compliance with this Code

We may ask you to verify your compliance with this Code through a self-assessment questionnaire, certification, third-party assessment or on-site audit. Notwithstanding any provision in any agreement between you and us, if you do not follow the requirements set out in this Code, we will discuss with you how you should improve your performance, and further, in the event you have materially breached this Code, we reserve the right to terminate such agreement(s) and/or defer any outstanding business and transactions with you.

We encourage you to report any concern or activity which violates this Code to Kemppi. Any such report will be treated as strictly confidential and as anonymous as possible