Code of Conduct Dalema Group

Dalema works to promote good working and environmental conditions in our supply chains. We aim to achieve this in close collaboration with our suppliers and partners. To clarify what we expect from our suppliers, Dalema has developed ethical trade guidelines. These guidelines cover basic requirements regarding human rights, labor rights, and environmental standards.

Principles
Our suppliers must deliver goods and services to Dalema in accordance with these guidelines. Suppliers must also pass these guidelines on to their subcontractors and ensure they comply.

Upon Dalema's request, the supplier must be able to document compliance with the guidelines. This can be done through self-declaration, follow-up discussions with Dalema, and/or by mapping working conditions at the production site. If Dalema wishes to investigate a subcontractor, the supplier must provide the name and contact details.

In case of violations of these ethical guidelines, Dalema will work with the supplier to create an action plan for rectifying the issues. The correction should be made within a reasonable time. Contract termination will only occur if the supplier, after repeated inquiries, is unwilling to resolve the issues. Social and environmental standards will be a key factor when selecting new suppliers.

Requirements for Our Own Operations
Dalema will continuously work to improve its own policies and practices to help ensure that suppliers adhere to our ethical trade guidelines.

Dalema, including all employees, shall never offer or accept illegal or improper payments or other forms of compensation to obtain business or personal advantages for themselves or for customers, agents, or suppliers.

Dalema and its suppliers shall avoid trading partners that operate in countries subject to trade embargoes imposed by the UN and/or Norwegian authorities.

Requirements for Conditions in the Supply Chain
Dalema's ethical trade guidelines are based on internationally recognized UN and ILO conventions and define minimum, not maximum, standards. Local laws at the production site must be respected. Where national laws and regulations cover the same issues as these guidelines, the highest standard should apply.

Forced Labor/Slave Labor (ILO Conventions Nos. 29 and 105)
1.1. There shall be no form of forced, slave, or involuntary labor.
1.2. Workers shall not be required to deposit their identity papers with the employer and shall be free to terminate their employment with reasonable notice.

Freedom of Association and Collective Bargaining (ILO Conventions Nos. 87, 98, 135, and 154)
2.1. Workers shall have the right to freely join or form trade unions and engage in collective bargaining without interference from the employer.
2.2. Trade union representatives shall not be discriminated against or prevented from carrying out their duties.
2.3. If the right to organize and/or engage in collective bargaining is restricted by law, the employer should facilitate alternative mechanisms for independent organization and negotiation.

Child Labor (UN Convention on the Rights of the Child, ILO Conventions Nos. 138, 182, and 79, ILO Recommendation No. 146)
3.1. The minimum age for employment shall be no less than 15 years and in accordance with:
i) national minimum age for employment, or;
ii) the minimum age for compulsory schooling, whichever is higher.
If the local minimum age is set at 14 years in accordance with the exception in ILO Convention 138, this may be accepted.
3.2. No child labor below the specified minimum age shall be recruited.
3.3. Children under 18 shall not perform work that harms their health, safety, or morals, including night work.
3.4. Action plans shall be developed for the gradual elimination of child labor that violates ILO Conventions 138 and 182. These plans should be documented and communicated to relevant personnel and other stakeholders. Provisions should be made for education opportunities for children until they reach the age of compulsory schooling.

Discrimination (ILO Conventions Nos. 100 and 111, and the UN Convention on the Elimination of All Forms of Discrimination Against Women)
4.1. There shall be no discrimination in employment, remuneration, training, promotion, dismissal, or retirement based on ethnicity, caste, religion, age, disability, gender, marital status, sexual orientation, trade union membership, or political affiliation.
4.2. There shall be protections against sexual harassment, threats, abuse, and exploitation, as well as against unfair dismissal on non-justifiable grounds (e.g., marriage, pregnancy, parental status, or HIV status).

Harsh Treatment
5.1. Physical punishment, physical abuse, or threats of physical abuse are prohibited. This includes sexual abuse and other forms of humiliation.

Health, Environment, and Safety (ILO Conventions Nos. 155 and Recommendation No. 164)
6.1. Efforts should be made to provide workers with a safe and healthy working environment. Dangerous chemicals and other substances should be handled properly. Necessary measures should be taken to prevent and minimize accidents and health hazards resulting from or related to working conditions.
6.2. Workers should receive regular and documented health and safety training. Health and safety training should be repeated for new hires and relocated workers.
6.3. Workers should have access to clean sanitation facilities and safe drinking water. If relevant, the employer should also provide facilities for safe food storage.
6.4. If the employer provides housing, it should be clean, secure, adequately ventilated, and have access to clean sanitation facilities and safe drinking water.

Wages (ILO Convention No. 131)
7.1. Workers' wages for a standard workweek must at least meet national minimum wage laws or industry standards, whichever is higher. Wages must always be sufficient to cover basic needs, including some savings.
7.2. Wage agreements and the payment of wages must be documented in writing before work begins. The agreement should be understandable to the worker.
7.3. Wage deductions as a disciplinary measure are not allowed.

Working Hours (ILO Conventions Nos. 1 and 14)
8.1. Working hours should comply with national laws or industry standards and should not exceed those outlined in applicable international conventions. Normal working hours should generally not exceed 48 hours per week.
8.2. Workers should have at least one day off per seven-day period.
8.3. Overtime should be limited and voluntary. Recommended overtime is 12 hours per week, for a total of 60 hours per week. Exceptions may be allowed if regulated by collective agreements or national laws.
8.4. Workers should always receive overtime pay for work beyond normal working hours (see 8.1), at a minimum in accordance with applicable laws.

Regular Employment
9.1. Obligations to workers, in line with international conventions, national laws, and regulations on regular employment, shall not be circumvented through short-term engagements (such as the use of contract workers, casual labor, or day laborers), subcontracting, or other labor relationships.
9.2. All workers have the right to a written employment contract in a language they understand.
9.3. Apprenticeship programs must be clearly defined in terms of duration and content.

Marginalized Populations
10.1. The production and use of natural resources should not contribute to the destruction of resources or livelihoods for marginalized populations, such as by seizing large areas of land, or through unsustainable water or other resource use that these populations depend on.

Environment
11.1. Measures to reduce negative health and environmental impacts throughout the supply chain should be implemented, including minimizing emissions, promoting efficient and sustainable resource use, including energy and water, and reducing greenhouse gas emissions in production and transport. The local environment at production sites must not be exploited or harmed by pollution.
11.2. National and international environmental laws and regulations must be complied with, and relevant emissions permits must be obtained.
11.3. To comply with the EU Timber Regulation 995/2010, suppliers of timber, paper, and pulp products must ensure the legality of their production and supply. They must ensure that products made of timber, pulp, or paper do not come from:
• Forest areas where traditional or civil rights are not respected.
• High Conservation Value Forests (HCVFs)
• Natural forests and peatlands cleared for conversion to plantations (e.g., eucalyptus, acacia) or other uses (e.g., palm oil, soybeans).
• Genetically modified trees – genetic modification allows the alteration of tree characteristics by inserting genetic material from another tree of the same or different species, or from another living organism.
• Species listed on the IUCN (International Union for Conservation of Nature) Red List as vulnerable, endangered, or critically endangered, or species listed by CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora), unless the products are FSC certified.

Corruption
12.1. All forms of bribery are unacceptable, including using alternative channels to ensure illegitimate private or business-related advantages for customers, agents, contractors, suppliers, or their employees, as well as public officials.

Dalema AS
Dag Leo Martinsen
CEO