Axentia Technologies Code of Conduct

Laws and Ethics

1. Axentia, its employees, management and board of directors have an obligation to respect
   and comply with the laws and regulations that apply in the countries in which Axentia
   operates.
2. However, the code goes beyond laws and regulations. The Code describes the basic ethical
   principles that guide the decisions and actions made by Axentia’s employees, management
   and board of directors.
3. In addition to the Code, our actions are also governed by our common values.
4. Axentia also adheres to the principles of agenda 2030, the UN Universal Declaration of
   Human Rights and the ILO Core Conventions on Human Rights at Work and the OECD
   Convention against Bribery.
5. The code describes a minimum level, which means that it should be followed even if it
   provides for a higher level than local legislation.

Corruption

1. Axentia and its employees may never provide gifts or benefits to customers, suppliers,
   government agencies or other decision-makers for the purpose of obtaining or retaining
   business.
2. Axentia employees may also not accept gifts or benefits from customers, suppliers or other
   parties that could affect the objectivity of their decision-making.
3. The submission or receiving of gifts and benefits of lesser value may be permitted in certain
   cases, provided that Axentia’s rules are followed.

Money laundering

1. Axentia never accept, facilitate or in any way support activities that involves money
   laundering.

Conflict minerals

1. Axentia has a clear policy that distances itself from conflict minerals from conflict-affected or
   high-risk areas and places demands on our suppliers not to supply us with such metals.
2. Suppliers to Axentia are expected to take reasonable steps to ensure that parts and products
   delivered to Axentia do not originate from conflict-affected or high-risk areas, i.e. do not
   contain conflict minerals that benefit armed groups or contribute to human rights violations.

Competition

1. Axentia shall always act in accordance with current competition law legislation. Axentia shall
   not exchange information or enter into contracts or agreements with competitors,
   customers or suppliers in a manner that risks hindering, restricting or distorting competition
   in the market.

Conflicts of interest

1. It is expected that employees at Axentia avoid situations that may involve conflicts of
   interest between the employee and Axentia. All decisions should be made and based on
   what is best for the company and not on personal considerations or relationships.
2. Co-ownership of customers, suppliers or competitors must be notified in writing and granted
   by Axentia’s CEO. Notification is also valid for employees’ ancillary tasks, provided that side-
   line work may involve a conflict of interest. There is no obligation to notify when acquiring
   listed shares to a lesser extent.

Environment

1. Axentia’s services, products and processes shall be designed in such a way that energy,
   natural resources and raw materials are used efficiently and that the amount of waste and
   residues is minimised.
2. Axentia works to prevent and constantly reduce the negative consequences the company’s
   operations can have on the environment. Axentia strives to conduct its business in an
   environmentally sustainable manner and shall comply with or exceed the requirements set
   out in laws, regulations and international agreements regarding the reduction of emissions
   into air, land and water.
3. Suppliers to Axentia are expected to inform Axentia about particularly hazardous substances
   in goods, parts and products delivered to Axentia, so-called SVHC substances or candidate
   substances where there is an obligation to make an SCIP notification.

Working conditions and working environment

1. Axentia respects the right of workers to organise themselves in any employee organisation
   and to negotiate collectively.
2. No employee may be discriminated against or harassed on the basis of age, gender, religion,
   sexual orientation, disability, political opinion or ethnicity.
3. Axentia is a drug-free workplace. No one, whether co-worker, hired or other person, is
   allowed to perform work when they are under the influence of alcohol or drugs.
4. Axentia works consciously and systematically for a good working environment, both physical
   and psychosocial. The overall goal is to achieve a safe and healthy workplace that promotes
   employee and company development. In the case of accidents, zero incidents are pursued as
   targets. Axentia will actively work to continuously improve the work environment and
   regular follow-ups of work environment management should take place both locally and
   centrally.

Communication and Information

1. Axentia strives to have transparent, open and proactive communication with all
   stakeholders, without disclosing confidential or sensitive information that could harm the
   company or the company’s customers.
2. Axentia respects each person’s right to express themselves and have opinions. However, the
   dissemination of confidential information or information detrimental to Axentia or Axentia’s
   customers may constitute a breach of the obligation to loyalty in the employment contract.
   The obligation to loyalty means that the employee must put the employer’s interests ahead
   of his own and that the employee has a duty of confidentiality in matters related to the
   work. This applies in all contexts – not only during working hours, but also outside of work,
   for example when the employee as a private person writes on social media.
3. Only specially appointed spokespersons have the right to speak on behalf of Axentia and
   express the company’s official positions on various issues.

Confidential Information

1. All employees are expected to pay particular attention to the fact that confidential
   information about Axentia – for example in terms of strategies, processes, systems,
   customers, suppliers, contracts, services and other business activities – is protected and not
   disclosed to anyone unauthorized.
2. In cases where Axentia employees come into contact with confidential information with the
   customer, this information should be protected and not provided to any unauthorized
   person. Axentia’s employees may not access, copy, reproduce or use the customer’s
   information other than to perform the agreed services of the customer.

Suppliers’ Relationship to the Code

1. Axentia shall actively work to ensure that suppliers follow the principles set out in the Code.
   Repeated or serious violations of the principles of the Code may result in the end of business
   cooperation with the relevant supplier.

Codes of Conduct at Axentia’s Customers

1. Since Axentia’s employees often work in close relationships with customers in the
   customer’s premises and sometimes also in the customer’s IT system, it is of great
   importance that Axentia employees follow the customer’s code of conduct, safety
   instructions and other rules of conduct.
2. If the Code and the customer’s corresponding Code of Conduct differ, Axentia employees
   should use the rules that are most restrictive.

Violation of the Code

1. Everyone is encouraged to report suspected violations of applicable laws and regulations or
   the Code. All reports are investigated. Axentia does not accept any discrimination or other
   negative consequences for persons who have reported suspected violations in good faith.

Whistleblowing

What is whistleblowing?
A common definition is a person who blows the whistle on something that doesn’t feel right. It is often about irregularities that take place in the workplace within a private or public company, an organization or an authority. The whistleblower can be anyone who has a close relationship with the organisation, such as an employee, former employee, subcontractor, supplier, customer, shareholder, board member, job applicant or trainee.

A personal grievance or complaint is not a whistleblowing case. Whistleblowing must be about a misconduct of major public interest. It can also be illegal, unethical, or harmful activities that can negatively affect others, such as:

1. Betrayal or corruption
2. Harassment, bullying and discrimination.
3. Violations of health and safety standards
4. Damage to the environment or property
5. Deliberate violations of the law

A personal complaint can be about a colleague’s behaviour, that you feel unfairly treated or that the company has violated the Employment Protection Act. Such complaints do not belong to the whistleblower channel but should be handled by the HR department.

In order to maintain an independent and independent report management, we use an external email function (gmail) for our whistleblower service. All reports and messages received are handled in a manner that ensures the confidentiality of your identity. Your report will be handled by authorized persons who guarantee that each case is handled in accordance with the Act on the Protection of Persons Who Report Misconduct Act (2021:890).

Please use the following email address

whistleblowaxentia@gmail.com

If you wish to report verbally, send a message to the above address and you will be contacted to book a time and place.