Code of conduct

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ContentIntroduction

Representing Mycronic

Our values

Human and labour rights

Business ethics

Environment

Being a listed company

Information and use of communication media

Reporting non-compliance – Whistle blowing

Business partner supplement

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Approved at Board meeting 2017-05-06.

Introduction

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This Code of Conduct ensures high ethical standards regarding business conduct whilst protecting human rights, promoting fair employment conditions, ensuring safe working conditions, and responsible management of environmental issues.

In addition to compliance with all relevant laws, regulations and standards in all of the

countries in which we operate, all Mycronic companies and employees shall comply with

the Code of Conduct even if it stipulates a higher standard than required by national laws

or regulations. Mycronic requires business partners, including suppliers, sales agents and

distributors, and their subcontractors to comply with the Code of Conduct and to verify

compliance by providing information and allowing access to their premises.

The Code of Conduct is a summary of the standards and principles of conduct expected

of all employees. The Code of Conduct is supplemented by more detailed policies and

directives in defined areas which can be found in the Mycronic Global Management System

(GMS). The Code of Conduct shall be applied throughout the Mycronic’s operations,

worldwide, as well as by Mycronic business partners through agreement.

Lena OlvingPresident and CEO

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Representing MycronicEMPLOYEESYou as a Mycronic employee have an important role to play in maintaining Mycronic’s repu-

tation as a highly trustworthy and professional company. Our vision and values can only be

fulfilled if we all understand that we must represent the company in a way that meets high

ethical standards. By doing so, we maintain and build respect in the businesses where we

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act and we create a working environment which we all can be proud of. You will inevitably

be confronted with complex situations where you feel you do not get a clear answer from

the Code of Conduct. When this is the case, you are expected to discuss the matter with

your nearest superior or to seek advice from the Corporate HR department.

Acts in violation of the Code of Conduct may cause damage to the company’s reputation

and may lead to legal action against the company and its employees. It may also be a

breach of the terms of employment, which is based on confidence and loyalty, and may

lead to labour law actions.

BUSINESS PARTNERSYou as a Mycronic business partner have an important role to play in maintaining Mycronic’s

reputation as a highly trustworthy and professional company. Mycronic requires business

partners, including suppliers, sales agents and distributors, and their subcontractors to

comply with the Code of Conduct and to verify compliance by providing information and

allowing access to their premises. For further information, please see page 22.

Our vision and values can only be fulfilled if we all understand that we must represent the company in a way that meets high ethical standards.

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I/We• drive sustainable profitability.• deliver to promises and have a

high sense of urgency.• grasp opportunities with business

and customer value in focus.• strive for excellence and

continuous improvement.

This Code of Conduct together with our company values guide us how to conduct our business Passion for

Business

Our values

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I/We • interact with people with respect

and trust.• share knowledge and learn from

others.• take responsibility for common as

well as local good.• embrace change and have a global

perspective.

Passion for Technology

Passion for People

I/We • deliver with dedication on target:

cost, scope and quality and time.• use the best solution, whether

bought or developed.• drive technology leadership and

innovation in key areas.• work closely with customers and

partners worldwide for our mutual success.

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Open and honest communication

Human and labour rights

Mycronic values the free flow of thoughts, ideas, questions, and concerns. Mycronic encourages employees to raise work-related issues or concerns with the nearest manager as soon as possible after they arise. When necessary, the employees should feel free to raise the issue with the manager’s manager. If you

Mycronic shall support and respect the protection of internationally proclaimed human rights and labour rights. All workers deserve a fair and ethical workplace and shall be treated with dignity and respect.

are not comfortable contacting any manager in the organisation, contact a Human Resources representative, who will manage the issue or concern and determines next steps. It is also possible to report anonymously through an external law firm (see paragraph regarding Whistle-blowing).

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Equal employment opportunities and non-discrimination

Our understanding of diversity means respecting that every individual is unique. Differences in the dimensions of ethnicity, race, gender, sexual orientation, age, physical abilities, religious and political beliefs and

professional backgrounds are expected, accepted and valued. Diversity for us at Mycronic also means that these differences are encouraged and that our employees have equal opportunities in work life.

Fair employment conditions

Employees shall understand their employment conditions. Pay and terms shall be fair and reasonable, and comply at a minimum with applicable laws or industry standards, whichever is higher. Working hours shall

comply with applicable laws. Corporal punishment, physical, mental, sexual or verbal abuse or other cruel or abusive disciplinary practices in the workplace shall be prohibited.

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Child labour prevention

Child labour is not tolerated. No person who is below the minimum legal age for employment shall be employed or engaged.

Anti-harassment and abuse

Mycronic is committed to pro-viding a workplace free of harassment and abuse. Any form of harassment, corporate punishment, bullying, physical, mental, sexual or verbal abuse or other cruel or abusive disciplinary practices in the workplace are prohibited.

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Freedom of association

We respect the right of all employees to form or join a trade union and to bargain collective or individually. Representatives for trade unions shall not be subjected to any discriminiation.

Health and safety

Mycronic shows commitment to health and safety and works for pro-actively eliminating accidents, illnesses and injuries. Sound safety practices are important in all Mycronic workplaces. To protect

Mycronic employees, the public, and our communities, we con-duct no activity without the proper safety precautions and we produce no product without proper safeguards.

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Business ethics

Anti-corruption Mycronic applies no tolerance for corruption. This means that we must not under any circumstances be engaged in, encourage or tolerate extortion and/or bribery through payments or other

Avoiding conflict of interest

At Mycronic, we make business decisions based on the best interests of the Mycronic Group rather than personal considerations. A conflict of interest arises in any situation where there is a potential for divided loyalties between your personal interest and your obligations to Mycronic. Typically, such conflicts arise

benefits to public officials or private sector employees with the aim of obtaining or retaining business or any other advantage.

when an employee uses his or her position at Mycronic to advance a personal financial interest or performs outside work that is inconsistent with Mycronic’s business interest. Activities constituting an actual conflict of interest are never acceptable. Avoid activity involving even the appearance of such a conflict.

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EnvironmentWe shall strive to develop, produce and offer products and services with excellent sustainability performance and contribute to the sustainable development of society. This means that we shall treat natural resources with care and respect in order to preserve environment and avoid environmental loads.

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Compliance obligations

Resource efficiency

Mycronic shall comply with environmental laws, rules and regulations in all the countries in which the company operates. All required environmental permits, approvals and registrations shall be obtained, maintained and kept current and their operational and reporting requirements shall be

Mycronic products and processes shall be designed in such a way that energy, natural resources and raw materials are used efficiently, and waste and residual products are minimized. The use of resources and generation of waste of all types, including water

followed. Suppliers and partners play an important role in the procurement of parts and sub- systems for our products. There- fore our way of managing environ-mental matters is reflected in our procurement process through the “Supplier Code of Conduct” and other requirements and guidelines.

and energy, shall be reduced or eliminated at the source or by practices such as modifying design, improving production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

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Hazardous substances

Materials restrictions

Chemicals and other materials posing a hazard if released to the environment shall be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.

Mycronic shall adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances in products and manufacturing, including labeling for recycling and disposal.

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Precautionary principle

Mycronic shall avoid materials and methods posing environmental and health risks when suitable alternatives are available. Risks related to present and future substances and operations shall be evaluated to minimize the negative environmental impact.

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Being a listed company

As a Swedish listed company, Mycronic follows Swedish insider legislation. According to Swedish legislation, everyone who receives or has access to insider information must respect the non-disclosure obligation and is responsible for following Mycronic’s insider and communication policies. This general disclosure prohibition applies to all individuals, employees or any others, who hold insider information.

Insider information refers to all types of non-public information and/or knowledge of circumstances which could have an effect on the share price if they became publicly known. Persons holding non-public information which would have an expected impact on the shareprice are not permitted to trade in Mycronic shares as long as they hold this information.

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Information and use of communication mediaInformation about the company is internal and confidential, unless publicly released through annual reports, press releases, Mycronic’s website and social media channels or through product marketing or other material for public use. Employees are encouraged to share published information, but shall not share unpublished information with others outside the company unless there is a business reason to do so.

Company information of a technical, commercial or marketing character is of a particularly proprietary and sensitive nature. This information may also include inside information. Anyone entrusted with such

information must be familiar with the confidentiality requirements and procedures regarding such information, and always ensure that the company’s interests are preserved.

We must all be aware of the risk of unintentional exposure of information, for example when discussing company matters with colleagues while travelling or in the social media sphere. Information which is detrimental to Mycronic can violate your obligation to exercise loyalty to the company as outlined in your employment agreement.

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Reporting non-compliance – whistle blowingThe Code of Conduct plays an essential role in creating a culture of responsibility and commitment to Mycronic’s values. It is the responsibility of Mycronic's managers to implement this Code of Conduct and inform their employees of their rights, duties and responsibilities.

All employees are expected to report to the nearest manager any observed or suspected violation of law or Mycronic Code of Conduct.

In case of violations concerning accounting and financial reporting, insider trading, corruption or other areas of vital importance to

Mycronic’s business or the health and safety of individuals, violations may be reported to the Swedish law firm Wistrand Advokatbyrå by sending an email to report@wistrand.se.

The law firm will ensure that confidentiality is maintained for the whistle blower. The reported violation will be investigated and judged in conjunction with a fair and rigorous application of this Code of Conduct. No one shall ever be discriminated against or punished for reporting in good faith any suspected or observed violations of the law or the Code of Conduct.

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Compliance Mycronic requires the Partner, and its subcontractors involved in Mycronic operations, to comply with this Code of Conduct through agreement. Upon request, a partner must provide information and/or allow access

Business partner supplement

to its premises to Mycronic and/or their representative. The Partner must verify to Mycronic’s reasonable satisfaction, that the Partner and its subcontractors comply with the Code of Conduct.

The Code of Conduct is applicable to all Mycronic operations and to any party that contributes to Mycronic products, services and other business activities (“Partner”). The Partner is responsible for controlling its own supply chain and shall encourage compliance with environmental and ethical standards and laws and human rights by any approved subcontractors of goods and services that are used by the Partner.

Obligation to inform

Responsible supply chain

It is the responsibility of the Partner to ensure that its employees and subcontractors involved in Mycronic operations are informed about and comply

Mycronic has a Supplier Code of Conduct that clarifies the expectations we have on suppliers with regard to ethics, human rights, working conditions,

with the Code of Conduct. The Partner shall inform Mycronic in writing immediately if they discover a breach of the Code of Conduct in their own operations.

environment and management systems. This helps us promote the values for which Mycronic stands, safeguards quality and reduces risks in the supply chain.

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