Page 7 - Hedengren-Code-of-Conduct-2024-002

We only work with reputable business partners and other third parties who are committed to
counteract corruption and bribery in accordance with our principles.
We also do our part in preventing money laundering and financing of terrorism with the means
available to us. Money laundering involves assets with unclear origin, whereas in the financing of
terrorism, legally obtained funds may be used, in which case the intended use of the funds is
suspicious.

Gifts and hospitality
We ensure that the gifts and hospitality we provide and receive always support a clear business
objective and that they are properly recorded, of reasonable value (not more than 200€), and
appropriate to the nature of the business relationship. Frequently giving or receiving gifts or benefits
that are unjustifiable in nature or quantity is prohibited. Receiving and giving monetary gifts is
prohibited, regardless of the amount and currency of the monetary gift.

Fair competition

We are committed to ethical, fair, and viable competition and to complying with antitrust, competition
and advertising legislation and regulations everywhere we do business.
Cooperation between competitors is prohibited as a rule. Hedengren Group companies have
different roles in the market and in some situations, cooperation with competitors may be permitted.
We do not accept prohibited cooperation between competitors and, for example, do not discuss
prices, productization, market sharing, future schemes, or other trade secrets with our competitors.
We avoid unnecessary contact with our competitors and when dealing with them, we only deal with
permitted matters.

We comply with international sanctions

We comply with international sanctions and the restrictions imposed by them on the export and
import of products. Hedengren Group companies do not do business, directly or indirectly, with any
person or entity that is included in an EU or a US OFAC (Office of Foreign Assets Control) sanctions
list, and we do not do business directly or indirectly with any country or territory subject to these
sanctions.

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