Siemon Code of Conduct

Siemon and its affiliates worldwide (“Siemon”) are committed to respecting labor and human rights in all its operations. We believe that all people are entitled to the same fundamental rights and freedoms, regardless of their race, religion, gender, nationality, or any other characteristic. We are committed to this policy and to working with others to promote human rights and environmental sustainability around the world. Specifically, we are committed to providing a safe and healthy work environment for all employees, and we believe that all workers have the right to be treated with dignity and respect. Siemon is committed to ethical business practices which means dealing honestly, respectfully, and being mindful of our obligations to our employees, customers, suppliers, and to the community and environment. Siemon fully embraces Environmental, Social and Governance (ESG) principles and is fully committed to the Responsible Business Alliance Code of Conduct (RBA), United Nations Global Compact (UNGC) and Science Based Targets initiative (SBTi).

We regard ESG as a companywide initiative that requires our employees to acknowledge and implement policies and systems that have a meaningful positive impact on environmental and social wellbeing within our control and influence. We strive to work with people who share our values, lead by example, and continually improve.

Labor and Human Rights

Siemon believes that respecting human rights is essential to our success as a business. We are committed to working with others to promote human rights around the world. Siemon’s policy when recruiting, hiring, training, promoting, and terminating employees shall not discriminate based on race, color, religion, sexual orientation, veteran status, pregnancy, age, national/regional origin, marital status, ancestry, gender, mental or physical disability, or any other characteristic as protected by federal or local law. Siemon will reasonably accommodate all applicants and employees so long as doing so does not create an undue hardship. We expect our employees to adhere to the Responsible Business Alliance code of conduct (RBA) as well as the United Nations Global Compact (UNGC), and to share our commitment to upholding the human rights of all employees and treating them with dignity and respect in the following ways.

Freely Chosen Employment

Siemon shall not use forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery or human trafficking. This includes transporting, harboring, recruiting, transferring, or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. As part of the hiring process, all workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment. All work must be voluntary, and workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given. Siemon can only hold documentation if such holdings are required by law. In this case, at no time should workers be denied access to their documents. Workers shall not be required to pay Siemon’s agents or sub-agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.

Young Workers

Child labor shall not to be used. Siemon shall not employ anyone under the age of sixteen (16). Workers under the age of 18 must not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

Working Hours

Workers should not labor more than the maximum hours of daily work set by local and national laws and regulations. Any overtime work should be voluntary and paid in accordance with existing local and national laws and regulations. Workers should not work more than 60 hours in a single work week, including overtime, except in emergency or unusual situations. Every effort will be made to ensure workers have at least one day off per sevenday week.

Wages and Benefits

Siemon shall compensate its employees for all overtime worked at the legal payment rate and provide its employees with a pay stub or similar documentation. Wages and benefits paid for a standard working week must meet local and national legal standards, including those relating to minimum wages, overtime hours and legally mandated benefits.

Humane Treatment

Siemon shall establish disciplinary policies and procedures in support of the humane treatment of workers and the requirements shall be clearly defined and communicated to workers. There shall be no harsh or inhumane treatment including violence of any sort, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, verbal abuse or any other conditions that contribute to a hostile work environment; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to all employees.

Non-Discrimination/Non-Harassment

Siemon shall abide by local laws and regulations regarding workers’ contracts. Workers shall be granted any annual leave, sick leave and maternity/paternity leave as legally required without any negative repercussions and shall maintain employee records as required by local and national laws and regulations in accordance with Company policy. Siemon shall maintain and utilize employment policies and practices that do not discriminate based on race, religion, sexual orientation, veteran status, pregnancy, age, national/regional origin, marital status, ancestry, gender or mental or physical disability or any other characteristic as protected by all applicable laws and regulations. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

Freedom of Association

In conformance with local law, Siemon shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Employees and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation, or harassment.

Diversity

Siemon seeks to develop a workforce that reflects the diversity of the communities and customers we serve all over the world by embracing diversity in all its forms- race, gender, thought, and experience. We promote a culture of diversity, equity, and inclusion within our workforce and source materials and services from suppliers who share our values.

Health and Safety

Siemon is committed to providing a safe work environment for its employees, where precautionary measures are taken against accidents and occupational hazards. Siemon shall provide training, procedures and ongoing health and safety education to employees, to minimize harm to health, environment and property.

Occupational Safety

Siemon shall identify and assess health and safety hazards (chemical, electrical and other energy sources, fire, vehicles, and fall hazards) and mitigate, which includes eliminating the hazard, substituting processes or materials, controlling through proper design, implementing engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and providing ongoing occupational health and safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-maintained, personal protective equipment, and educational materials about risks to them associated with these hazards. Siemon shall provide a healthy and safe working environment for all workers and comply with all health and safety laws and regulations, employ best practices for occupational health and safety in compliance with ISO45001, emergency preparedness, occupational injury and illness, ergonomics, machine safety, sanitation, food and housing. Reasonable steps must also be taken to remove pregnant women and nursing mothers from working conditions with high hazards, remove or reduce any workplace health and safety risks to pregnant women and nursing mothers, including those associated with their work assignments, and provide reasonable accommodations for nursing mothers.

Emergency Preparedness and Industrial Hygiene

Siemon shall continually identify and assess potential emergency situations and their impact minimized by implementing emergency plans and response procedures including emergency reporting, employee notification and evacuation procedures, worker training, and drills.

Occupational Injury and Illness

Siemon shall have first aid equipment available at appropriate locations throughout the facility. At least one employee in each location shall be trained in basic first aid. Siemon shall have in place procedures and systems to prevent, manage, track and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate the return of workers to work.

Physically Demanding Work

Siemon shall identify, evaluate, and control worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful manual operations.

Machine Safeguarding

Siemon shall evaluate production and other machinery for safety hazards. Physical guards, interlocks and barriers or e-stop sensors are to be provided and properly maintained where machinery presents an injury hazard to workers.

Sanitation, Food, and Housing

Siemon shall provide workers with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities.

Health and Safety Communication

Siemon shall provide workers with appropriate workplace health and safety information and training in a language the worker can understand for all identified workplace hazards to which workers are exposed, including but not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Appropriate health and safety training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise any health and safety concerns without retaliation.

Environment

Siemon shall operate its facilities in an environmentally responsible manner that is in accordance with or exceeding applicable statutory and international law and standards. Siemon shall implement management systems such as ISO 14001 or the Eco Management and Audit System (EMAS). Siemon, where possible, shall use sustainable energy solutions in its manufacturing and distribution processes, producing environmentally and consumer-friendly products. Siemon shall provide training and education on sustainable solutions that reduce its energy consumption, save on costs, and decrease greenhouse gas emissions.

Environmental Permits and Reporting

Siemon shall recognize that environmental responsibility is integral to producing world-class products and identify the environmental impacts and minimize adverse effects on the community, environment, and natural resources within its manufacturing operations and throughout its supply chain, while safeguarding the health and safety of the public. Siemon shall obtain, maintain and keep current all required environmental permits, approvals and registrations and follow all operational and reporting requirements and regulations. Siemon shall apply best efforts to provide Health Product Declarations (HPDs), Declare labels and shall respond to requests relating to material composition, safety and environmental compliance.

Pollution Prevention and Resource Reduction

Siemon shall work to minimize or eliminate the discharge and emission of all pollutants and generation of waste through adding pollution control equipment and, where possible, modify production, maintenance and facility processes to lessen or eliminate negative environmental impacts, employ conservation practices to minimize the use of natural resources, like water, fossil fuels, minerals and virgin forest products. Siemon shall use material substitution, material re-use, conservation and recycling to further environmental protection.

Hazardous Substances

Siemon shall ensure that chemicals and other materials that are hazardous to humans and the environment are properly identified, labelled and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Solid Waste

Siemon shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste.

Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion byproducts generated from operations are to be characterized, routinely monitored, controlled, and treated as required prior to discharge. When applicable, Siemon shall conduct routine monitoring of the performance of its air emission control systems. Siemon should prohibit the use of ozone depleting chemicals (ODCs) in its operations and supply chain. All airborne industrial emissions/pollutants shall be minimized and shall fully comply with applicable regulations and permits.

Materials Restrictions

Siemon shall maintain effective systems to ensure full product and material compliance with all applicable environmental and safety regulations and standards, including but not limited to RoHS, REACH, IEC, NEC, CPR and other applicable national and regional regulations, as well as all requirements stated in Siemon engineering specifications.

Water Management

Siemon shall seek opportunities to conserve water; and control channels of contamination and shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge. When applicable, Siemon shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

Energy Consumption and Greenhouse Gas Emissions

Siemon shall establish a corporate-wide greenhouse gas (GHG) reduction goal. All relevant Scopes 1 and 2 GHG emissions are to be tracked, documented, and publicly reported against the GHG reduction goal. Siemon shall include Scope 3 in its GHG reduction goals in accordance with the Science Based Targets initiative (SBTi). Siemon shall look for methods to improve energy efficiency and to minimize energy consumption and associated GHG emissions.

Business Ethics and Compliance

Siemon employees shall conduct business interactions to the highest standard of ethical behavior and in accordance with applicable laws and regulations.

Business Integrity

Siemon employees shall avoid situations that create an actual or perceived conflict of interest and shall not engage in a transaction where their interest conflicts with that of Siemon. Siemon has a zero-tolerance policy that prohibits any and all forms of bribery, corruption, illegal payments or gratuities, extortion and embezzlement, and shall comply with all trade laws and controls when exporting and importing, and conduct all business communications, activities and transactions honestly, ethically and lawfully. Siemon employees shall comply with the US Foreign Corrupt Practices Act, the UK Bribery Act, and all other applicable anti-bribery laws that govern where they do business.

No Improper Advantage

Siemon employees shall not engage or participate in corrupt activity such as paying or accepting bribes or accepting kickbacks in any form. Gifts of a nominal value may be exchanged on special occasions as a token of appreciation and partnership. All such gifts are considered to be the property of the receiving organization. Any meals or entertainment with Siemon employees should occur infrequently, avoid lavish expense, always remain within bounds of professional conduct and be in full compliance with applicable personal and corporate tax regulations and Siemon’s Corporate Travel policy.

Disclosure of Information

Siemon shall ensure all business dealings are transparently performed and accurately reflect Siemon’s business books and records. Information regarding Siemon’s labor, health and safety, environmental practices, business activities, structure, financial situation, and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the business or supply chain are unacceptable.

Fair Business, Advertising and Competition

Siemon employees shall comply with all applicable laws and regulations relating to competition and should therefore never engage in price fixing, market sharing, bid rigging or customer allocation.

Protection of Identity and Non-Retaliation

Siemon shall maintain programs that ensure confidentiality, anonymity, and protection of whistleblowers, unless prohibited by law. Siemon has a process for their personnel to be able to raise any concerns without fear of retaliation.

Responsible Sourcing of Minerals

Siemon shall maintain a conflict-free supply chain that is in full compliance with conflict minerals regulations such as the US Dodd-Frank Act by sourcing products and materials from non-conflict sources.

Privacy

Siemon employees shall commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Siemon shall comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

Tax Compliance, Fraud and Money Laundering

Siemon shall comply with all tax obligations and not engage in transactions that evade tax obligations or facilitate tax evasion. Siemon shall commit to preventing and detecting fraud, which is defined as any intentional deception or misrepresentation that is used to gain an advantage. Siemon shall maintain full compliance with US trade and finance sanctions and shall prevent money laundering and terrorist financing and will not engage in such transactions.

US Export Controls

Siemon shall comply with US Export Controls per https://www.trade.gov/us-export-controls.

Intellectual Property

Intellectual property rights of others, including Siemon and its affiliates must be respected. Siemon employees shall handle proprietary technology and knowledge in a way that protects Siemon’s intellectual property rights. All Siemon information shall be safeguarded by non-disclosure agreements.

Management Systems

Siemon affirms our commitment to compliance and continual improvement in accordance with international standards ISO 9001-; ISO 14000, and ISO 45001. We publicly report on selected Key Performance Indicators related to ESG and have an established process to assess compliance and performance relating to regulatory requirements, environmental impact, health and safety, labor practice and ethics risks associated with our operations on a regular basis. Training and communication are integral parts of these systems. We adhere to a regular audit and assessment program that encompasses both internal and external audits. We have a process for timely identification and correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews. We expect our employees to share and demonstrate this commitment in the following ways.

Management Accountability and Responsibility

Siemon shall have a management system in place that affirms commitment to corporate social and environmental responsibility, identifies and holds responsible named executives that oversee the status and effectiveness of these systems and compliance with all applicable laws, regulations, and Siemon requirements, both for its internal operations and throughout its supply chain.

Legal and Customer Requirements

Siemon shall establish a process to identify, monitor and understand applicable laws, regulations, and customer requirements, including the requirements stated herein.

Risk Assessment and Risk Management

Siemon shall assess and manage risk within its products, policies, and procedures regarding legal compliance, the environment, health and safety, labor, and ethics, and shall put training programs in place.

Improvement Objectives

Siemon shall maintain written performance objectives, targets and implementation plans to improve its social, environmental, and health and safety performance, including a periodic assessment of its performance in achieving those objectives.

Training

Siemon shall establish programs for training managers and employees to implement Siemon’s policies, procedures, and improvement objectives and to meet applicable ESG, legal and regulatory requirements.

Communication

Siemon shall actively engage its employees and overall supply chain to communicate and reinforce the importance of ESG principles, international standards ISO 9001, ISO 14000, and ISO 45001 and compliance with these requirements.

Worker Feedback, Participation and Grievance

Siemon shall solicit and encourage employee feedback, participation, and implement a grievance process that allows anonymity. There should be a timely response and documentation of resulting investigations and any corrective actions.

Audits and Assessments

Siemon shall conduct periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of this Code, and Siemon requirements related to social and environmental responsibility.

Corrective Action Process

Siemon shall establish a process for timely correction of deficiencies identified by internal or external audits, assessments, inspections, investigations, and reviews.

Documentation and Records

Siemon shall create and maintain documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy, proprietary information and intellectual property.