Uponor

Code of Conduct

This Code of Conduct has been approved by the Board of Directors of Uponor Corporation. It is  applicable to all Uponor Group companies worldwide (jointly and severally “Uponor”) and employees, managers, officers and directors thereof (jointly and severally “Employee(s)”).  Uponor’s vision, core purpose and values – Connect, Build, Inspire – are embedded in this Code  of Conduct. 

Ethics, Laws and Regulations 

Uponor shall strive for long-term business growth by generating genuine added value to its  customers. Employees shall always follow ethical and legal standards in the conduct of business.  Employees shall act professionally, responsibly, honestly, and observe the highest standards of  integrity. Employees shall comply with this Code of Conduct and other relevant Group Policies,  Guidelines and Instructions, as well as all related policies, guidelines and instructions of the  Uponor Division in which the Employee works. 

Uponor and Employees shall comply with the spirit and the letter of applicable international and  national laws and regulations wherever Uponor conducts its business. Among these are laws  and regulations promoting fair competition; governing publicly traded securities; safeguarding  Uponor intellectual property; addressing corporate governance; protecting individual privacy;  safeguarding against corruption; dealing with product safety; as well as human rights and labour laws. 

Uponor and Employees shall respect human rights defined, for example, in the United Nations’  Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights. As a signatory party to the United Nations’ Global Compact, Uponor and all Employees are committed to supporting the Ten Principles thereof on human rights, labour, environment and  anti-corruption. 

Conflicts of Interest, Gifts and Bribes 

Employees shall avoid any conflict between their interests and the interests of Uponor. This  includes, but is not limited to, giving, soliciting or receiving of personal gifts or hospitality by  Stakeholders, other than reasonable gifts or hospitality of a minor value, on an occasional basis, in the ordinary course of Uponor’s business and as acceptable under applicable laws. 

(“Stakeholders” refer to Employees, customers, suppliers, shareholders, governmental and non governmental organisations and other parties that have a contractual relation with Uponor or  may have influence over or may be influenced by Uponor.) 

All facilitation payments or unofficial benefits to a public official or government to get an  approval or permit, or to otherwise facilitate a business transaction or activity, shall be strictly  prohibited. Uponor prohibits all bribery and refrains from participating in any money-laundering,  tax evasion and financing of illegal activities. Uponor and Employees are to ensure that all  charity, donations and sponsorships are appropriate and approved in accordance with the applicable laws and internal rules.

Uponor Confidential Information, Data and Other Assets 

Uponor’s trade secrets and proprietary information are valuable business assets of Uponor and  their use and protection are of utmost importance. In particular, trade secrets and other  confidential information must be protected by ensuring confidential use of such information  and, where appropriate, by seeking additional protection through registration of intellectual  property rights. 

Employees who receive or learn of any confidential information of Uponor, or of any other party  having a business relationship with Uponor, shall keep such information confidential and may  not, for other than Uponor’s acceptable business purposes or as required by applicable laws,  disclose any such information to third parties (including friends and family members). 

Uponor promotes openness, transparency and continuous dialogue with the Stakeholders and  media. Employees shall follow Uponor’s social media guidelines and act responsibly in all  communications. The protection of confidential information, rules on publicly traded securities (insider information) and competitive considerations may, however, restrict that transparency  and shall be, at all times, complied with. 

Uponor’s accounting data shall be accurate and reliable in all material respects. Unrecorded  funds are prohibited, and the records shall be done in a timely manner. Uponor’s financial and  non-financial reporting and records shall not contain any false, misleading or artificial entries or  information. 

Any kind of theft, fraud, embezzlement or other misuse of Uponor’s assets is prohibited. Uponor’s financial, digital and other assets shall be used in a responsible manner and for their intended  and legitimate purposes. Employees shall secure and protect all Uponor’s assets, including but  not limited to inventory, equipment, premises, data and intellectual property. 

Environment 

Uponor is committed to protecting the environment and conducting its business in a responsible  and environmentally sustainable way. Uponor expects Employees to comply with  environmental laws and regulations and to promote actions that reduce environmental impact  of Uponor’s own operations and of the whole value chain. 

Politics 

Uponor does not participate in politics and does not support political parties or groups  financially or otherwise. Employees participating in political activities shall do so as private  persons only and not as representatives of Uponor. 

Employees 

Uponor supports labour rights as defined by the International Labour Organization and the  labour/employment laws of the countries in which Uponor operates as well as upholds the  freedom of association and the effective recognition of the right to collective bargaining. 

Should these rights be restricted by local law, Uponor endeavours to offer its Employees  alternative means to present their views. 

Uponor is a responsible employer and committed to building a welcoming and inclusive working  environment with equal opportunities. No discrimination based on, for example, race,  nationality, age, religion, disability, gender, sexual orientation, union membership or political  activity is allowed. Uponor does not allow child, compulsory or forced labour or engage  suppliers that do so. Uponor does not tolerate any form of harassment, abuse or bullying from  or towards its Employees. 

Uponor strives to provide fair compensation as well as a safe and healthy workplace for all  Employees. Each Employee is responsible for complying with safety instructions, using personal  protection equipment when required and reporting any shortcomings in relation to those. 

Customers and Suppliers 

Uponor is committed to enabling its customers to succeed, as this will support Uponor’s own  success. Uponor strives for mutual satisfaction and good faith in all its agreements, high quality  of products and services offered, fair pricing, and excellent after-sales service. Uponor shall treat  all Stakeholders with the same mindset Uponor deploys when approaching its own customers. 

Uponor’s suppliers are expected to meet ethical, social, environmental and quality standards  set forth in Uponor’s Supplier Code(s) of Conduct. 

Uponor conducts its business according to all applicable competition/anti-trust, export control  and customs laws and regulations in all its operations. 

Implementation 

Uponor promotes the implementation and monitoring of this Code of Conduct through efficient  communication of its contents and meaning to Employees. Any questions about this Code of  Conduct shall be addressed to the General Counsel of Uponor. Any suspected violations of this Code of Conduct shall be reported to one’s supervisor, the General Counsel, local or Group HR and/or the internal auditor (contact information to be found on Uponor Intranet) or via  anonymous internal/external reporting channel and shall be duly handled by the management. 

Any suspected violation shall be investigated and resolved in full confidence and discretion. 

Employees are encouraged to contact their supervisor in case of unclear situations. Uponor shall  ensure that there are no adverse work-related consequences or any form of retaliation against  any individual reporting on a Code of Conduct violation in good faith. 

Actions inconsistent with this Code of Conduct must be promptly corrected and they are  subject to disciplinary actions, including termination of employment and payment of damages. Certain violations of criminal nature may additionally lead to criminal procedures.