Code of Conduct for Suppliers and Service Providers

Purpose

Festi and its subsidiaries (N1, Krónan, ELKO, Bakkinn vöruhótel and Festi fasteignir) have established a code of conduct for their own companies, suppliers and service providers which is based on the Group's Sustainability Policy

The purpose of the rules is to create a reliable and stable procurement environment for the Group and to support its sustainability goals. By making clear demands for ourselves, our suppliers and service providers, we want to influence the supply chain to conduct even more responsible and sustainable production and business.

Responsibilities and scope

The Board of Directors and the Executive Management team of Festi approve this code of conduct and they apply to all companies within Festi as well as all suppliers and service providers of the Group. These rules are reviewed annually, published on Festi's website and presented to management and employees as part of their implementation as well as if changes occur.

If stricter requirements are imposed by Festi's subsidiaries, they take precedence over these rules.

Festi and its subsidiaries companies reserve the right to conduct assessments of suppliers and service providers in the light of this code of conduct. In the event of suspicion of a breach by the supplier of this code of conduct, action will be taken according to documented corrective procedures. Serious and/or non-corrective serious infringements may result in the termination of the business relationship with the involved party.

Requirements for suppliers and service providers

Festi requires that suppliers and service providers always comply with laws and regulations that apply to their operations. In addition, Festi imposes the following requirements on suppliers and service providers by ESG category*:

1. Environment
  • Recognise the climate impact of their own operations and implement concrete measures to reduce greenhouse gas emissions in their operations.
  • Are aware of other environmental impacts of their activities and seek to reduce their negative impacts responsibly.
  • Deliver waste to recycling facilities, sorted according to relevant criteria and regulations at any given time.
2. Social
  • Respect internationally recognised human rights, such as the United Nations Convention on Human Rights and the United Nations Convention on the Rights of the Child, and reject all human rights violations, such as forced labour.
  • Respect the freedom of association and collective bargaining rights of employees at any given time.
  • Create a working environment that promotes equality and inclusion and does not tolerate bullying, violence, harassment or discrimination of any kind.
  • Ensure a safe and healthy working environment for its employees.
3. Governance
  • Practice healthy business practices and work against any form of corruption.
  • Establish a code of conduct that is accessible to employees.
  • Communicate respectfully and respect confidentiality of confidential information.

*ESG stands for Environmental, Social and Governance; see guidance from Nasdaq

Version 1.0, adopted December 12, 2023

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Further information

Why is Festi establishing a Code of Conduct for suppliers and service providers?
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Festi and its subsidiaries wish to have a positive impact on their supply chain in order to conduct more responsible and sustainable production and trade, promote healthy business practices and combat any form of corruption.

By establishing clear protocols for suppliers and service providers, the Group defines its requirements for the supply chain.

What happens if the supplier or service provider does not confirm the Code of Conduct?
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The confirmation form is used to create an overview of counterparties that have validated the Code of Conduct. Whether a supplier or service provider has confirmed or not will be taken into account when developing business relationships.

What is the procedure for potential violations of the Code of Conduct for suppliers and service providers of Festi and its subsidiaries?
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Should Festi receive information of a possible breach of the Code of Conduct for Suppliers and Service providers, the Director of Procurement or the appropriate contact at the operating company for the supplier or service provider in question, shall follow the following procedures in cooperation with the Director of Legal Affairs at Festi:

  1. Examine the data or the information in support of a possible infringement and take a position on their credibility.
  2. Formally seek the position of the supplier or service provider which the information concerns, should the information be considered credible.
  3. Assess the severity of the alleged violation, incl. whether and what remediation is needed.
  4. Seek cooperation with the supplier or service provider for improvements if relevant.
  5. If the amendments are not met or are not sufficient according to Festi's reasonable judgment, Festi or the relevant operating company reserves the right to terminate the cooperation with the supplier or service provider immediately.

In processing information about alleged breaches of the Code of Conduct for Suppliers and Service Providers, Festi will ensure fair handling of the supplier or service provider and respect their right of objection.

What happens when the Code of Conduct has been confirmed?
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Establishing a Codes of Conduct for suppliers and service providers is the first step in the company's journey to positively impact its supply chain. Companies that have confirmed the Code of Conduct will then at a certain point be asked to answer a questionnaire for a value chain assessment.