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Code of Conduct

Storskogen was founded in 2012 with a firm commitment to be the best owner of small and medium-sized enterprises. We are extremely proud of our fantastic portfolio of companies, with businesses and employees operating throughout the world. But solid, profitable companies are not created overnight and they differ widely. Therefore we have chosen to use a decentralized management model, giving subsidiaries considerable responsibility on strategic issues and significant freedom in day-to-day decisions.

For Storskogen to continue to grow and generate value with the same success, it is essential that all our subsidiaries share our business philosophy and that all employees act in line with certain group-wide principles. Our principles may be considered common sense, but the bigger we become and the more people we employ, the greater the need to clearlyset down these principles in writing. We have therefore produced this Code ofConduct, which establishes and clarifies the principles that guide us as employer sand employees in our dealings with other employees, customers, suppliers, business partners and society in general.

This Code of Conduct aims to provide day-to-day guidance to ensure that all of us always behave professionally, with integrity and good judgment, in the best interests of Storskogen and our customers. You are always welcome to contact me if you have any questions aboutour principles or the application of this Code of Conduct.

Daniel Kaplan, CEO Storskogen Group AB(publ.)

Introduction

This policy (the “Code of Conduct”) setsout the key principles of the Storskogen Group’s responsibility as a company and provides guidance on how we are expected to operate and act in our day-to-day work.

Our business model

Storskogen’s business model aims to create good long-term returns by identifying, acquiring and developing small and medium-sized enterprises. All of our companies focus on achieving good profitability, a solid cash flow and a strong position in their respective niches. We are always the principal owner and plan for our ownership to be permanent rather than setting a time limit on our investment.

Our core values

We believe that fair business practices anda long-term, successful and sustainable Storskogen will contribute to society as well as employees, owners, customers, suppliers and other stakeholders. Storskogen wants to be regarded by its stakeholders as approachable, pragmatic, skilled, committed, with a long-term and professional mindset. Storskogen aims to be a company that entrepreneurs actively seek out to sell their life's work, to work at, invest in or to do business with. Storskogen has three core values that relate to our business model and that guide us in our day-to-day operations: entrepreneurship, professionalism, and a long-term approach.

Entrepreneurship means:

-      striving to operate profitably and with a strong customer focus

-      identifying new business opportunities and innovations to ensure competitiveness in the long run

-      assuming responsibility for our companies and our employees, and contributing to the positive development of the communities in which we live and operate

Professionalism means doing everything with skill and competence,  

-      striving to achieve the best quality and always seeking improvements

-      being structured, and measuring and following up our performance

-      being humble and pragmatic, with high standards for integrity, ethics and respect for each other’s differences

A long-term approach refers to our 100-year perspective, which means

-      protecting the environment around us and setting high standards for sustainability

-      being responsible and working to see the communities in which we operate, which are often small, rural communities that depend on Storskogen’s continued activity, develop, stay competitive and living on in the best way possible.

Scope and application

This Code of Conduct applies to all members of staff (employees and consultants) and board members of Storskogen Group AB and its subsidiaries, regardless of where they are located (“Storskogen”).

The Code of Conduct reflects the principles of internationally recognized and accepted conventions and agreements on the environment, human rights, working conditions and corruption, such as the UNGlobal Compact, the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the OECD Guidelines forMultinational Enterprises. However, the content of the Code of Conduct is based on Storskogen’s own materiality analysis.

Storskogen’s Group CEO has overall responsibility for the Code of Conduct being implemented within the Storskogen Group.  Our decentralized managementmodel entails each subsidiary’s CEO taking responsibility for ensuring a suitable structure and process is in place to make certain that all members of staff are given access to, understand and act in accordance with the latest version of the Code of Conduct. This responsibility includes offering regular training on the Code of Conduct’s content. CEOs and other managers should set a good example and conduct their leadership based on our core values and the Code of Conduct.

CEOs and other managers are also responsible for advising on issues relating to the Code of Conduct and ensuring managers’ availability to answer possible employee questions about the application of the Code. Every member of staff is responsible for complying with the Code of Conduct and asking questions in situations where the interpretation or application of this Code of Conduct is not deemed clear.Further support in interpreting the Code can also be obtained through the guidance section below.

Storskogen only wants to work with suppliers, agents, consultants and other business partners which themselves actin a way that is in line with the principles of this Code of Conduct. Storskogen has therefore also produced a Code of Conduct for Suppliers, and communicates those principles to our current and potential business partners.

Guidance

Each member of Storskogen staff isen trusted with a responsibility to use their best endeavors and common sense to determine what is the best thing to do in any given situation. In certain situations it may be felt that the Code of Conduct does not provide sufficient guidance on how a situation should be managed. In such situations, it may help to test these assertions to determine whether a situation or action is in linewith this Code of Conduct:

I believe this to be legal and ethically correct.

I would feel comfortable explaining my actions to my manager, a colleague or a third party.

I would feel comfortable with the situation if I were a colleague, stakeholder or counterparty. If this became publicly known, it would not have a negative impact on trust in or the reliability or credibility of Storskogen, its management or employees.

If the answer is yes to all of these statements, the situation or action is likely to be in line with this Code ofConduct. If there is still uncertainty over whether the situation is in accordance with Storskogen’s Code of Conduct, please seek advice from your line manager.

Compliance

Every Storskogen employee is responsible for reporting circumstances that could conflict with this Code of Conduct, or other criminal behavior, to their line manager. If, for any reason, you do not feel comfortable talking with your manager, or if despite having reported the issue or made a complaint you feel it has not been taken seriously, you canalways contact a member of Storskogen’s Group Management or report your issue through Storskogen’s external whistleblower function, which allows you to make an anonymous report: https://report.whistleb.com/storskogen.

Stuff must be able to submit information anonymously and a report made on reasonable grounds in accordance with the purposes of the Code of Conduct must never result in any reprisals or other negative consequences for the person submitting the information. Proven infringements of this Code of Conduct lead to disciplinary action, including termination of employment and/or legal action for serious violations.

This Code of Conduct has been adopted by the Board of Storskogen Group AB (publ.), and amendments and exemptions may only be granted by the board.

Compliance with the Code of Conduct will be assessed as part of the annual follow-up of internal control. The Code of Conduct will itself be reviewed annually to ensure it is suited to both the requirements and expectations of our operating environment and the development of our own organizations and business operations. The Code of Conduct will be adjusted if deemed necessary.

How the Code of Conduct relates to laws, rules and other policies

Storskogen must, without exception, comply with applicable laws and rules in all countries in which Storskogen’s companies conduct business and with existing policies in each Storskogen company. In somesituations, such as in countries with weak legislation or controls, the Code of Conduct’s requirements may be more rigorous than local legislation, customs and conventions. In such cases, we should always comply with this Code of Conduct and our own principles. The opposite applies to those cases where local legislation or regulations are stricter than our Code of Conduct. Likewise, subsidiaries are free to apply a stricter code than this Code of Conduct.

Our business principles

Business ethics and corporate governance

Zero tolerance of corruption

Storskogen shall, under no circumstances, whether directly or indirectly, accept offers of, give, demand or receive any form of bribery, undue or inappropriate benefit, service, incentive or engage in nepotism.

The risk of corruption must therefore be evaluated in each business relationship, based on factors such as businesspartners’ activities, geographical location and representatives.

Caution over gifts and benefits

Gifts, rewards and benefits should always have a clear business purpose. Storskogen shall not offer or give undue payments or other compensation to any person or other organization for the purpose of persuading the person or organization in question to establish or maintain a business relationship with our group companies. Neither shall we, either directly or indirectly, request or accept some form of undue payment or other compensation given to establish or maintain a business relationship.

No Storskogen staff shall either give or receive gifts, compensation, benefits or offers that could be regarded as constituting an undue advantage. Undue advantage means something that could affect the recipient’s business decisions.

Impartiality and conflicts of interest

Storskogen staff shall act in the best interests of Storskogen. All business relationships must be impartial and business decisions must be taken without reference to any private relationships or benefits. Activities that could lead to or appear to be a conflict of interest between the personal interests of a member of staff and Storskogen’s business must therefore always be avoided. In cases where a member of staffintends to enter into an agreement with a party where there is a risk of the situation being regarded as, or appearing to be, a conflict of interest, decisions must always be taken by an independent party higher up in the organization. This means, for instance, that decisions must be taken by the business area's executive director instead of the CEO of the relevant company.

Healthy competition

Storskogen’s success must be based on our professionalism and free and fair competition in all aspects of our business. We must not exchange information, enter into agreements or declarations of intent with our competitors, customers or suppliers that unduly influence themarket and breach applicable competition legislation.

Product quality and customer satisfaction

Storskogen shall deliver products and services of consistently high quality and reliability, with product safety being the highest priority. Storskogen shall provide its customers with correct product information and only make promises about our products and services that we can live up to. Satisfied and loyal customers are vital to Storskogen’s reputation and when faced with choices, we should choose the option that we believe provides customers with the best result.

Responsible taxpayer

Tax laws and rules must be complied with in all countries in which Storskogen operates. Storskogen must act as a responsible taxpayer and not undertake unethical tax planning.

Transparent and accessible communication

Storskogen must provide accurate, relevant, fact-based and prompt information at the right time regarding the company’s activities, performance and financial position. All stakeholders must be treated equally and Storskogen’s communication must take place in accordance with applicable laws and agreements. Those who communicate on social media in their professional roles always represent their company and Storskogen. All communication must therefore be in line with our values and be consistent with how we communicate via other channels. All employees must draw a clear line between their private and professional online and social media presence.

Storskogen members of staff must treat all confidential information received with great care and with the level of security required by law and agreements.

Business-related issues are handled by each individual subsidiary. Questions about Storskogen Group may be referred to info@storskogen.com.

Accounting and reporting

All financial transactions must be recorded in the accounts in accordance with generally accepted accounting policies.

Political involvement

Storskogen is politically neutral, which means that Storskogen does not make political donations or become involved withpolitical parties. Neither the name Storskogen Group nor each subsidiary’s business names, or any resources under the Group Company’s control, may be used to promote the interests of political parties or candidates.

A good employer and neighbor

Storskogen’s success is based on us being an attractive employer that can offer interesting career and professional development opportunities at healthy and safe workplaces. Storskogen must therefore make sure it has good work environments from a physical, mental health and social point of view. Success is also based on positive long-term relationships with key players in Storskogen’s operating environment, including government authorities, suppliers and employee organizations.

Equality and diversity

The relationship with and between Storskogen’s staff shall be based on mutual respect. Storskogen endeavors to achieve an inclusive workplace culture and believes diversity is key to this.Employees must therefore be recruited, promoted and compensated exclusively on the basis of their qualifications for the job and entirely without reference to race, age, national or social background, gender, transgender identity or expression, sexual orientation, ethnicity, religion or other beliefs, politicalopinions, trade-union membership, marital status, or disability that does not impede the performance of their work.

Storskogen endeavors to achieve equality in the workplace, with great diversity and an equal gender balance in its businessoperations. We do not tolerate any form of discrimination. No employee may under any circumstances be subjected to corporal punishment or other forms of physical, sexual or psychological punishment, harassment or coercion, and we take robust action against any violations of this.

Human rights

Storskogen endeavors to ensure fundamentalhuman freedoms and rights are respected and protected. This means that, at the very minimum, we must comply with internationally recognized principles such as those in the UN Global Compact and the Universal Declaration of Human Rights.We shall act responsibly and robustly if our own business or any of our business relationships are discovered to have a link to a potential or actual violation of human freedoms and rights.

Child labor and/or forced labor are strictly prohibited in all of Storskogen’s businesses. In addition, we do not tolerate child labor at any suppliers, their subcontractors or businesspartners.

Health and safety

We continually strive to ensure a good work environment in physical, mental health and social terms. At the very minimum, we must comply strictly with national health and safety laws and the health and safety provisions arising out of agreements and/or collective agreement sentered into. It is the responsibility of each CEO to ensure that all employees are familiar and comply with the applicable rules, policies and processes on health and safety in their area of work and receive the necessary training and protective equipment. It is the responsibility of every member of staff to comply with these rules and to not take health and/or safety risks at work, and to rectify and report situations or circumstances at the workplace that could pose such a risk.

Remuneration

All employees shall be paid correctly and fairly based on individual performance and contribution to each group company’s success. Storskogen endeavors to prevent unfair differences in pay between genders. Pay and benefits must comply with applicable legislation and collective agreements. We abide by the applicable industry standards where collective agreements exist.

Freedom of association

All Storskogen employees are entitled to the freedom of association. This means that Storskogen employees must be free to exercise their legal right to be a member of, organize or work for organizations that represent their interests as employees.

Society

Storskogen’s companies have strong links to local communities and the businesses are often based in small towns. Storskogen aims to develop and make use of local skills. Storskogen also endeavors to make a positive, sustainable contribution to the communities in which it operates.

Minimize negative environmental impacts and future-proof companies

Storskogen believes that an intelligentapproach to environmental sustainability is essential for its subsidiaries’ continued growth, development and profitability. Storskogen shall there fore actively strive to minimize its direct and indirect environmental impact. This means that an environmental perspective must be included in important decisions to create long-term value for Storskogen’s customers, employees, shareholdersand society in general. We must also ensure that we systematically measure, monitor and report our targets and performance on relevant environmental factors. As an owner, we should make sure key environmental factors are addressed and followed up in our subsidiaries’ strategies and processes. Besides contributing to our goal of minimizing our negative environmental impact, this is also an area where we can find future business opportunities. Together with its subsidiaries and their customers, Storskogen can promote the emergence of new and improved solutions and products that will also make a positive contribution to the development of society.

Resource efficiency and energy consumption

Storskogen and its subsidiaries aim to increase resource efficiency for all types of resources and input goods andensure that we optimize our energy consumption. As well as reducing the negative environmental impact on society, our experience is that these measures almost always have a positive impact on costs and profitability.

Transportation and travel

Storskogen aims to use the most environmentally sustainable method of transportation, thereby also cutting carbon emissions. This also applies to those subsidiaries that provide transport services.

We try to reduce the amount of business travel and increase the number of digital meetings. As well as cutting the negative environmental impact from travel, the employees’ personal sustainability also increases as a result of general time-saving, which we hope is leading to a better work-life balance. Every member of staff chooses the most appropriate mode of transport for business travel, taking particular account of cost, time, safety and environmental factors.

Purchase of goods and services

Storskogen strives to choose goods and services with a low environmental impact. Relevant environmental factors should therefore be considered in connection with purchasing and procurement.

Waste

Storskogen aims to reduce the total amount of waste and maximize the amount of recycled materials within the Group. Each subsidiary and member of staff contributes to this by utilizing opportunities for reuse, recycling and waste sorting. Hazardous waste is managed in ways that minimize the risk of negative environmental impact.

Every Storskogen employee is responsible for reporting circumstances that could conflict with this Code of Conduct, in addition to any criminal behavior, to their line manager. If, for any reason, you do not feel comfortable talking with your manager, or if despite having reported the issue or made a complaint you feel it has not been taken seriously, you can always contact a member of Storskogen’s Group Management or report your issue through Storskogen’s external whistleblower function, which allows you to make an anonymous report: https://report.whistleb.com/storskogen.

Daniel Kaplan (daniel.kaplan@storskogen.com)

Amelie Nordin (amelie.nordin@storskogen.com)

Louise St Cyr Ohm, General Counsel (louise.stcyrohm@storskogen.com)

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