Haglöfs Code of Conduct

This Code is an ethical framework with guidelines for all Haglöfs employees on how they should behave to respect each other, suppliers, customers, partners and not least our core values. The Haglöfs core values are: Curious, Reliable and Proud.

Our business is built on trust and reputation. It influences how our employees, customers and consumers perceive our brand and our products. Unethical actions of a few people can ruin our reputation and can have severe negative impact on our business. Keeping our integrity, following legal regulations and internal policies, being honest and showing respect towards each other and partners should be corner stones in all actions.

SCOPE
This Code applies to Haglöfs AB as well as its subsidiaries and affiliates.

PERSONAL RESPONSIBILITY
It is everybody’s personal responsibility to be updated on the company’s expectations on each employee. This further includes making other Haglöfs employees aware of any unethical behaviour in breach with this Code. In your everyday business activities, ask yourself:

• IS THE DECISION OR ACTION I AM GOING TO TAKE IN LINE WITH THIS CODE?
• HAVE I UNDERSTOOD THE RISK AND THE POSSIBLE IMPLICATIONS OF WHAT I AM DOING?
• AM I ACTING WITH INTEGRITY?
• AM I LEADING BY EXAMPLE?
• HAVE I CONSIDERED ANY POTENTIAL IMPACT ON HAGLÖFS REPUTATION?
• HOW WILL I FEEL IF THE ACTION I TAKE TODAY IS FEATURED IN THE NEWSPAPERS OR IN THE TELEVISION TOMORROW?  

LEGAL COMPLIANCE
Haglöfs and its employees may be subject to the laws and regulations of many countries and other jurisdictions around the world. Haglöfs shall conduct its business in strict compliance with applicable laws and regulations, including national and international laws and regulations, and expects the same from its affiliates and partners. If a provision of this Code conflicts with applicable laws, the applicable laws prevail.

HUMAN RIGHTS
Haglöfs supports and respects the Universal Declaration of Human Rights and The Conventions of the International Labor Organization (ILO). The ILO is addressed to legal entities in markets that are members of the ILO.

The aim of the ILO is to reach globally accepted labor standards, which is supported by Haglöfs by applying principles regarding:

a) Freedom of Association and Protection of the Right to Organize
b) Right to Organize and Collective Bargaining
e) Equal Remuneration
f) Discrimination (Employment and Occupation)
g) Minimum Age
h) Worst Forms of Child Labor Haglöfs refuse any relation with anti-social forces or groups that threaten to disrupt the order and safety of civil society.

HEALTHY WORKPLACE
Equality Haglöfs provides equal employment opportunity in compliance with laws and regulations to all qualified persons according to the laws and regulations, regardless of their race, color, creed, national origin, religion, age, sex, gender, sexual orientation, physical or mental health, medical condition or genetic information.

Haglöfs stands for equality in all phases of employment, including (but not limited to): recruitment, hiring and firing, opportunities for development, promotions, selection of employees for training programs and determination of wages and benefits.

Remuneration and work conditions
Both Haglöfs and its employees have a commitment to each other to make every effort to ensure high levels of performance, personal development and employability. Remuneration must be consistent with all applicable wage laws and regulations, including those relating to minimum wages, overtime hours and legally mandated benefits. Disciplinary wage deductions are not permitted unless agreed in a collective labor agreement, union contract or a rule of employment. Wages will be paid in money regularly, normally via bank account, or in exceptional cases, in cash, but never in kind. Employees will be informed about the composition of their pay and benefits in a detailed and clear manner Working hours are not to exceed the maximum set by local laws and regulations, and should not be excessive, including overtime. Overtime work shall not be forced unless agreed in a collective labor agreement, a union contract or a rule of employment.

Haglöfs will provide relevant learning opportunities to its employees, if budgets allow.

Work environment
Haglöfs aims to provide a safe and healthy work environment. Since safety and security are team efforts, we require every employee to comply with policies and common sense to ensure the health, safety and security of our workplace and workforce. Employees should not undertake work for which they are not trained, work in accordance with good safety practices and report any unsafe conditions or injuries promptly.

Discrimination
Diversity is valued at Haglöfs. All people and cultures are welcome and accepted and are to be and treated with respect, equality and dignity.

Harassment
Sexual harassment or harassment based on; race, gender, religion, national origin, age, sexual orientation, gender identity or expression is not tolerated at Haglöfs AB or any Haglöfs subsidiary or organized company function. Examples of the types of improper behaviour and prohibited conduct include:

• Unwelcome sexual advances
• Requests for sexual favours
• Obscene gestures
• Displaying sexually graphic magazines, calendars or posters
• Sending sexually explicit, racially offensive e-mails or voice-mails
• Other verbal or physical conduct of a sexual or offensive nature

BUSINESS ETHICS
Haglöfs will conduct our business honestly and ethically wherever we operate in the world. No illegal or unethical behaviour in business relations is tolerated. Examples of the types of improper behaviour and prohibited conduct include:

• Employees shall avoid excessive gifts, gratuities, fees, bonuses and entertainment in order to attract or influence business activity
• No bribes, kickbacks or other similar remuneration shall be given to any person or organization in order to attract or influence business activity Employee shall not reveal business confidential information to anyone, except those within the company whose positions require use of the information. This also includes information revealed in internet based social media.
• Employees shall during business trips be an ambassador for Haglöfs core values and therefore avoid excessive use of alcohol or take part in activities of sexual nature including visits to sex clubs or similar entertainments.

Conflicts of Interest
Haglöfs expects its employees to make business decisions and take actions that are in the best interest of Haglöfs. A conflict of interest exists any time an employee is involved in an activity that could affect such employee’s objectivity in making decisions for Haglöfs. Examples of activities that might create a conflict of interest include:

• Accepting outside employment with our organization’s suppliers, customers or competitors
• Having a financial interest in them (except for minor holdings in a publicly traded company)
• Hiring of family members and/or having a direct reporting relationship with family members
• Doing business with family owned or family related companies

Anti-trust, Competition, Anti-Bribery and Anti-Corruption
In conducting business with individuals and organizations, we expect our employees to always be fair and impartial. Bribery and corruption are never acceptable. A gift or favour should never be given or accepted if it might create a sense of obligation, compromise one’s professional judgment or create the appearance that it might. Giving or accepting valuable favours, gifts or entertainment could be construed as an improper attempt to influence someone and adversely affect the business relationships we have so carefully built. Favours, gifts and entertainment can include (but are not limited to) meals, hotels, discounts, loans, cash, services, tickets, use of vehicles or vacation facilities, transportation or anything of value. Our business relationships must be based entirely on sound business decisions; employees must always use good judgment and if they have questions or concerns, express these.

Employees who suspect a situation of unethical business decisions or actions shall immediately inform the administrating (controlling or parental) company (ASICS) through ASICS Global Whistle Blowing Line.

DRUG ABUSE
Haglöfs takes drug and alcohol abuse as a serious matter and will not tolerate it. We prohibit the use of drugs or alcohol at the work place or on company premises during working hours. Haglöfs will support employees with alcohol- or drug problems to look for professional help.

INTELLECTUAL PROPERTY & IT
Each employee is responsible for the proper use, protection and conservation of Haglöfs’ assets and resources and should use those assets in the manner intended, according to the following guidelines:

• Do not use Haglöfs’ assets for your personal benefit or the benefit of anyone other than Haglöfs
• Use common sense. The occasional personal phone call or email from your workplace is acceptable. Excessive personal calls or email is a misuse of assets

Assets include not only the physical space, but also securities and cash, office equipment and information systems as well as business critical information. It also includes software, patents, trademarks, copyrights and other proprietary information.

Haglöfs endeavours to maintain a sound IT environment. In order to achieve this, it is inevitable that an ethical behaviour is demanded of all employees using our IT services. Haglöfs reserves the right, without warning, to block unethical websites. Haglöfs considers it unethical when an employee:

• Attempts to access network resources without the right to do so
• Attempts to hide his or her user identity
• Attempts to disrupt or interrupt the intended use of the network
• Manifestly wastes available resources (personnel, hardware or software)
• Attempts to damage or destroy computer-based information
• Encroaches the private lives of others
• Seeks to offend or humiliate others
• Visits websites with content considered inappropriate and/or unethical

CONSEQUENCES OF VIOLATIONS

Haglöfs encourages open and honest communication. Any employee who, in good faith, raises a concern or reports misconduct is complying with this Code. Taking action against someone who brings an issue forward is strictly forbidden. Anyone found to have retaliated against another individual is acting against this Code.

The consequences for violating this Code will depend upon the facts of each situation, but may range from a verbal warning to disciplinary action which may include termination of employment.