CODE OF CONDUCT - Fiskars...This Code of Conduct (referred as “Code”) demonstrates Fiskars’ commitment to conducting its business in an ethical and responsible manner. Conducting

CODE OF CONDUCT

CODE OF CONDUCT | 32 | FISKARS GROUP

Table of contents

General policy principles 4

Compliance with laws and regulations 6

Valuing Fiskars People 9

Fiskars customers 10

Clear and precise communication 10

Maintaining our good name 12

Protection of privacy 14

Maintaining competitive advantage 16

Additional information and contacts 18

4 | FISKARS GROUP CODE OF CONDUCT | 5

This Code of Conduct (referred as “Code”) demonstrates Fiskars’ commitment to conducting its business in an ethical and responsible manner. Conducting business in the right way is our way of doing business according to our values. There is no right way to do the wrong thing. This Code helps to translate Fiskars’ values into action.

This Code applies to everyone within Fiskars, including employees, directors, officers, board members, consultants and other personnel working under Fiskars’ direction (referred to in this Code as ‘Fiskars People’) and covers all Fiskars group companies worldwide.

Fiskars People are expected to observe not only the letter, but also the spirit of the Code. Therefore all Fiskars People must be aware of, and conduct their activities in accordance with this Code and all supporting policies, even when the Code requires a higher standard of behaviour than is required by national law and local regulation.

Fiskars also expects that all of its business partners should be governed by the same or similar principles stipulated in this Code. Fiskars expects all business partners ensure that those principles are communicated to their employees and sub-contractors.

Fiskars’ Supplier Code of Conduct has been developed in order to communicate Fiskars’ ethical and sustainability expectations to our suppliers.

GENERAL POLICY PRINCIPLES

This Code of Conduct provides an introduction to Fiskars’ way of doing business and the responsibilities of Fiskars employees.

Knowing the Code of Conduct should help you to choose the right thing to do. If in doubt, ask before you act.

If you think there has been a violation of this code you must report it without delay.

We all set an example for each other and our stakeholders by being honest, fair and respectful.


CONDUCTING OUR BUSINESS RESPONSIBLY Fiskars is proud of its business heritage and believes that its excellent reputation contributes to its business success. Fiskars supports a culture of fairness, transparency, responsibility and integrity in all its business activities.

To help Fiskars People understand their responsibilities, this Code outlines the following key ethical principles:

Compliance with laws and regulationsFiskars is committed to full compliance with all applicable laws and regulations of relevant countries. As a minimum, these include laws and regulations related to employee rights, securities markets, such as disclosure obligations and insider regulation, corporate governance, taxation, fair competition, export control, product safety and intellectual property.

We must have sufficient knowledge of laws and regulations: depending on your role, you must know the laws and regulations that govern your work. There is no excuse for ignoring the law.

Understanding the spirit of the code is essential

Situational awareness means that you have to understand how to act in a particular situation even when there are no instructions available. If you are unsure about the right thing to do, consider following questions:

What was your first impression and are you comfortable with the issue or decision?

Is it legal?

Is it consistent with our Values, Code, Policies and Instructions?

How would others see and assess your actions and their consequences?

If you are still unsure, ask for advice.

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Valuing Fiskars PeopleFiskars People are Fiskars’ most valuable asset. It is Fiskars’ responsibility to ensure that it provides a safe and sustainable working environment with fair terms of employment for all employees. Respect for people and protection of human rights is paramount. In particular, Fiskars is committed to:

• Equal opportunity in all employment practices, policies and rules as well as treating all employees fairly and impartially based on competence, experience and performance, without regard to race, ethnicity, age, disability, gender or sexual orientation and/or any other characteristics protected by applicable law

• Ensuring high standards of Health and Safety management throughout all its operations worldwide

• Providing an inspiring working environment, where all Fiskars People are encouraged to engage in their own personal and professional development and growth

• Not allowing working conditions or treatment that contravene basic human rights and violate our zero tolerance for child labour, or are in conflict with laws and practices of relevant countries where these require a higher standard

• Supporting and respecting the protection of internationally proclaimed human rights as defined in the United Nations’ Universal Declaration of Human Rights, including freedom of thought, opinion, expression, religion and to peaceful assembly, protecting Fiskars People; threats, intimidation and violence in the workplace will not be tolerated

We believe everyone is created equalWe value diversity among our personnel and we are committed to treating all employees fairly and impartially.

No discrimination is tolerated on any basis and we also have zero tolerance towards harassment and bullying.

Safety at work is everyone’s responsibility and it is important to inform management about any safety issues.

Fiskars strives to provide a safe and inspiring working environment for all its employees. No compromises in safety at work are allowed and it is every employee’s duty to act if any safety issues are identified.

Fair treatment is not just a matter for managers and leadersAll Fiskars employees should treat each other with respect and there is no room for degrading behavior. If you hear or see anything that can be considered harassment or bullying, it’s your duty to act, always and without delay.


The success of our customers is the key to our success

Fiskars customersFiskars customers range from individual shoppers at our stores and online, wholesale accounts, major hospitality and institutional customers, distributors and licensees.

Fiskars is committed to ensuring that every customer can expect the highest quality of customer care and to be treated in a courteous and friendly manner.

Clear and precise communicationIt is a fundamental principle for Fiskars that all communication must adhere to all relevant legislation, regulations and standards and be undertaken in an open and objective manner. Fiskars is committed to ensuring that only true and correct information is communicated and that non-public information is not disclosed. Responsible and appropriate communication, made at the appropriate time, is essential to protect Fiskars’ reputation and its business.

We aim to create long-term customer relationships and, therefore, we need to exercise fairness in all relationships with our customers. There is no room for unfair quick wins.

We aim to exceed our customers’ expectations. By doing this we can become a preferred partner to our customers.

Any action which can be perceived as corruption is often judged as corruption.

It is your responsibility as an employee to avoid any situation which can be seen as such. Corruption causes business decisions based on dishonest and unfair criteria.

As a company we always promote open and fair competition.


Maintaining our good nameFair dealing

Fiskars must not seek competitive advantages through illegal or unethical business practices. All Fiskars People are expected to deal fairly with others. No one should take unfair advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.

Free and open competition

Fiskars embraces free and open competition. Competition law aims to protect free competition in the market, by regulating the relationships with business partners and competitors. Although there is no one uniform set of competition laws that apply in all countries, certain basic principles apply everywhere to prohibit collusive or unfair business behaviour that restricts free competition.

Anti-bribery and corruption

Corruption is the abuse of entrusted power for private gain. It is considered to be one of the biggest threats to market and social development. Corruption disrupts competitive markets, misallocates resources and can lead to violation of human rights. It undermines the rule of law and trust in business and its leaders. It is therefore Fiskars’ responsibility as a company and Fiskars People’s responsibility as individuals who represent the company, to prevent corruption in all its forms, including bribery, facilitation payments and inappropriate gifts, hospitality and favours.

Conflict of interest

Fiskars will not tolerate any situation where the personal activities and interests of Fiskars People conflict or appear to conflict with the best interests of Fiskars. This includes situations where an employee’s judgment is likely or appears to be influenced by the possibility of personal financial gain or where an external engagement adversely impacts the individual’s ability to fulfill his or her duties to Fiskars.

Export control

Export controls and regulations restrict trade or export activities with certain countries, entities or individuals in order to put pressure on the targets to discourage them from violating international law or human rights, prevent proliferation of weapons of mass destruction and/or limit flows of weapons or goods that could be used for military purposes. Fiskars supports such objectives.

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

Fiskars’ practises relating to gifts and hospitality is included within Fiskars Anti-Corruption and Anti-Bribery policy.

The Policy covers Fiskars Corporation and all its subsidiaries and associate companies worldwide. It also covers every individual working in or with Fiskars, at any level or grade and wherever located.

Fiskars expects that all of its business partners should be governed by the same or similar principles stipulated in the Policy.

Fiskars also expects all business partners ensure that those principles are communicated to their employees and subcontractors.


Protection of privacyFiskars respects, and is committed to, safeguarding the privacy of our customers as well as the privacy of Fiskars People. It is Fiskars’ policy to follow applicable laws and regulations governing privacy and data protection in all countries where Fiskars operates.

Fiskars takes privacy protection issues seriously and employees’ right to privacy is protected.

Laws and regulations regarding privacy protection may vary from country to country.

The importance of protecting privacy is increasing and the harmonization of legislation within the EU concerning both employees and consumers is underway. Fiskars is following this change closely and will act accordingly.


Maintaining competitive advantageIntangible assets and information security

Intellectual property refers to creations of the human mind that are protected by various national laws and international treaties, including copyrights, patents, trademarks, trade secrets, designs, logos, know-how and other intangible industrial or commercial property.

Fiskars’ intellectual property is among its most valuable assets. Fiskars is committed to safeguarding its trade secrets and intellectual property and defends any challenge, misuse or misappropriation of them vigorously.

In the same way that Fiskars expects others to observe Fiskars’ rights, Fiskars is committed to avoiding unlicensed or unauthorised use or misappropriation of intellectual property that validly belongs to others.

It is important to safeguard Fiskars’ confidential or business-critical information as any unauthorised use may seriously harm Fiskars’ business.

Fiskars respects the trade secrets and intellectual property that suppliers, customers or other partners have entrusted to Fiskars for business purposes. It is the responsibility of Fiskars People to protect and maintain the confidentiality of such information.

Tangible assets

Fiskars is committed to managing and safeguarding its assets no matter where they are located, stored, used or shown. All Fiskars People must protect company assets, such as equipment, inventory, supplies, cash and information, by treating company assets with the same care you would if they were your own. Company assets and resources may only be used to conduct company business.

Fiskars People must not use company assets other than for legitimate business or other authorized purposes.

ACT IN THE BEST INTEREST OF THE COMPANY

Do not compete with Fiskars in any form

Do not allow your personal, financial or political activities to influence or be perceived to influence the way you do your job at Fiskars

Do not conduct personal business deals with your friends or family on behalf of Fiskars

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RELATED DOCUMENTS

Supplier code of conduct

Anti-corruption and Anti-bribery policy

Violations Response policy

WE HOLD EACH OTHER ACCOUNTABLE FOR THIS CODE

Ethics and compliance questionsIf you ever have an ethics question or a concern about whether something meets our Code of Conduct, policies or legal requirements, please speak up.

You are encouraged to consider who has the responsibility or control over the issue, who would have the information needed to answer your question and also who you feel comfortable approaching. You can contact your supervisor, colleague, your human resources function, or legal function, for example.

Whistle blowing practisesViolations against our Code erode the confidence we have built within our organisation and with our shareholders, customers and other stakeholders. A failure to follow the Code can also put your colleagues and our business at risk. Therefore, it is your obligation to report any suspected violations of Code to your manager, HR, Corporate Compliance Officer or Legal Function without delay.

You can also contact the Ethics and Compliance Helpline. Fiskars CoC Violation Response policy defines how the investigation of suspected violation will be conducted.

There will be no adverse workrelated consequences for any persons reporting suspected violations in good faith. Fiskars prohibits retaliation, in any form, against anyone who, in good faith, reports violations or suspected violations of Code of Conduct, policies or applicable law, or who assists in the investigation of a reported violation.

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Training and communicationCode of Conduct training is mandatory for all new employees and it must be part of their induction programme. Refresh trainings are organised regularly to bring forth current topics and to strengthen ethical culture among Fiskars People.

ContactsFor additional information and advice please contact your manager, HR, or Corporate Compliance Officer and Legal Function at [email protected]

Fiskars Corporation Hämeentie 135 A PO Box 130 FI-00561 Helsinki, Finland Tel +358 204 3910 www.fiskarsgroup.com

Fiskars Corporation P.O. Box 130, FI-00561 Helsinki, Finland Tel +358 204 3910 | www.fiskarsgroup.com | [email protected]

Documents

CODE OF CONDUCT - Fiskars...This Code of Conduct (referred as “Code”) demonstrates Fiskars’ commitment to conducting its business in an ethical and responsible manner. Conducting