Code of Conduct

This Code of Business Conduct and Ethics (the “Code”) applies to business partners of Direct Hardware Supply ApS (“DHS”) of Denmark.

For the purpose of this Code, ‘business partners’ means buyers, suppliers and joint-venture partners. The Code shall cover all employees of our business partners, including permanent, temporary and agency-provided employees.

DHS has adopted the Code to set out its expectations for the conduct of all business partners, in their dealings on behalf of, or in relation to DHS. The Code does not cover every issue that may arise but sets out basic principles as a guide in carrying out business activities with integrity and good faith in relation to the ethical, social and environmental performance of business partners, employees and suppliers.

The Code is a core element of our partnerships and is incorporated into all contracts with our business partners. At DHS, we are fully dedicated to upholding the principles outlined in the Code.

1. General Expectations

We expect our business partners to be aware of and act in conformity with all applicable laws, rules, and regulations. In cases where these laws conflict with the specific standards outlined in this Code, the highest possible standard should be applied.

Business partners are responsible for following this Code and should apply due diligence measures to ensure that high-risk sub-suppliers comply with either this Code or a comparable framework ensuring the same minimum standards.

If a business partner intentionally or repeatedly fails to meet the expectations of this Code or in a clear and significant manner, refuses to engage in due diligence, or demonstrates a lack of commitment to addressing issues identified during audits, DHS reserves the right to terminate the business relationship.

1.1. Trade compliance and export controls and sanctions

Compliance with international trade regulations and export controls and sanctions is a cornerstone of the Code. These measures reflect our commitment to ethical business practices and global accountability. It is essential for our business partners to stay informed about the trade restrictions that apply to their business activities and specific products.

Before exporting products, sharing technical information, or transmitting software across borders, it is crucial to investigate export license requirements.

Our business partners must ensure that products are not exported to prohibited countries, entities, or individuals listed in government sanctions or export control lists. This also entails Advokatpartnerselskab Skt. Clemens Stræde 7 Postboks 623 8000 Aarhus C info@clemenslaw.com www.clemenslaw.com Tlf. 87 32 12 50 CVR-nr. 32 67 65 61 an obligation for our business partners to apply due diligence when selecting third parties and request equivalent standards and obligations to their third parties and business partners.

Furthermore, business partners are responsible for ensuring that all necessary export licenses are obtained before the export of controlled goods, technologies, or services.

1.2. Data privacy

Adhering to data privacy regulations is a fundamental principle of our Code. It is therefore essential for all our business partners to stay informed about the data privacy laws and regulations that apply to their activities and the specific data they handle. These rules can vary by region and continuously evolve due to changes in technology and global standards. Ensuring compliance with data privacy is critical to maintaining integrity.

Before collecting, sharing, or transferring personal data across borders, it is crucial to assess and confirm the requirements for doing so, including obtaining necessary consents or ensuring the proper legal basis is in place e.g., contracts and relevant law.

1.3. Whistleblower protection

Whistleblower protection regulations is another vital aspect of our Code. Therefore, it is important for all employees and business partners to be aware of the frameworks and policies
that govern the reporting of misconduct or unethical actions. Compliance is essential to maintaining a culture built on openness and accountability.

1.4. Human Rights, Including Labor Rights

We expect our business partners to prevent and mitigate negative impacts on human and labor rights as outlined in the International Bill of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. Below are specific examples of the minimum standards we expect from our business partners.

Child Labor

Business partners must prohibit child labor and ensure that no one under the age of 15 (or 14 where legally permitted) or below the minimum age for completing compulsory education is employed. Young workers (aged 15-18) must be safeguarded from hazardous work or work that interferes with their education. If child labor is discovered, actions taken must prioritize the child's welfare.

Conflict-Affected Areas and Conflict Minerals

If operating in or sourcing from conflict-affected regions, business partners must conduct due diligence to avoid links to funding armed actors.

Discrimination

Business partners must provide a workplace free from discrimination and ensure fairness in their workplace practices. Discrimination based on race, ethnicity, gender, age, disability, religion, sexual orientation, or social status is strictly prohibited.

Freedom of Association and Collective Bargaining

Business partners must respect workers’ rights to join or not join lawful organizations or unions. Where restrictions apply, alternatively, independent representation must be provided. Discrimination against worker representatives is not permitted.

Harassment and Disciplinary Measures

Business partners must treat employees with respect and prohibit all forms of harassment, abuse, or coercion. Disciplinary measures must be transparent and documented. Imposing monetary fines on employees is not permitted.

Health and Safety

Business partners must ensure safe and healthy working conditions and apply preventive measures against workplace hazards. Continuous improvements in relation to workplace safety through e.g., management systems, training, and goal setting are expected.

Hiring Practices and Forced Labor

Business partners must provide written employment contracts in understandable language to the employees and prohibit forced labor, human trafficking, and the withholding of identification documents or wages. Employees must have freedom of movement and the right to terminate their employment after a reasonable notice.

Remuneration

Business partners must comply with wage laws, including minimum wages, overtime, sick leave, piece rates and other elements of compensation required by law. Wage statements detailing hours worked and compensation must be provided at the end of each pay period.

Working Hours

Business partners must prevent employees from exceeding the applicable limits on regular and overtime hours set by law, industry standards or collective agreements.

1.5. Environment

Business partners must prioritize environmental care, comply with all relevant environmental regulations, and maintain the necessary licenses to fulfill the purpose of their business.

Environmental Impact

Partners are expected to minimize environmental impact by:

Taking a precautionary approach to climate change related to their activities, products and services Using resources efficiently and replacing hazardous materials when possible.
Having a precautionary approach to the use of resources and materials.
Safely managing hazardous substances during production and disposal and finding a substitution whenever this is possible.
Protecting biodiversity and promoting the sustainable and efficient use of land, natural resources and energy (e.g., recycling whenever possible).
Establishing control mechanisms for the prevention of pollution from hazardous substances, waste and effluents and air emissions.
Providing emergency response plans for environmental risks.
Providing access to immediate measures to protect human health and the environment.
Adhering to the "polluter pays" principle.

1.6. Anti-Corruption

DHS upholds a zero-tolerance policy on corruption. Business partners must not engage in any form of bribery, fraud, extortion, facilitation payments, or money laundering.

Partners must implement measures to prevent employees, agents, or suppliers from violating anti-corruption laws. This can be done by ensuring that all transactions and expenses are always recorded accurately and fairly. Never create incomplete, false or misleading entries and be aware of suspicious behavior that could indicate or point at corruption. Partners must notify DHS of any sanctions imposed upon them.