Code of Conduct

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Boers & Co Code of Conduct

Introduction

Boers & Co Precision Solutions (Boers & Co) has been in Manufacturing and Assembly of precision parts and components since 1895. We are a leading manufacturer located in the southwestern part of the Netherlands in an area where the High Tech industry is always close by. All employees of Boers & Co are constantly focused on innovations for better operations for the benefit of our end users and our stakeholders.

Being such a company means that Boers & Co has a responsibility as a corporation to customers, employees, investors and the public. This Corporate Social Responsibility (“CSR”) includes compliance at all times with all relevant statutory as well as respecting ethical values and acting responsibly for our business and the social environment. By supporting and acting in line with the United Nations’ Global Compact, Boers & Co has undertaken to consider its principles in the areas of human rights, labour, environmental protection and anticorruption.

Furthermore, Boers & Co meets the labour standards laid down in the conventions of the International Labour Organization (ILO) and the Dutch Labour Organizations.

Boers & Co has also set itself binding guidelines in its Code of Conduct for acting in a responsible and sustainable manner.

In line with the CSR strategy pursued by Boers & Co, the company expects its suppliers (i.e. all contracting parties that supply goods, materials or services), and business partners (including business partners with an intermediary and/or representative function that act in the interests of or on behalf of Boers & Co in a sales support capacity, such as consultants, agents, trading representatives, authorized dealers/importers, joint venture and syndicate partners etc.) and their employees to act responsibly and undertake to observe the basic principles outlined in this Boers & Co Supplier and Business Partner Code of Conduct.

If the suppliers or business partners involve third parties (e.g. subcontractors or representatives) in their business dealings with Boers & Co, Boers & Co expects these third parties to also observe the principles laid down in this Boers & Co Supplier and Business Partner Code of Conduct.

Boers & Co Precision Solutions

Content

Introduction

Corporate Social Responsibility

Human Rights

Human Treatment

Equal opportunity and non-discrimination

Environmental protection

Safety in the workplace

Minimum wages

Transparent Business Relationships

Protection of Data, Business Intelligence and Company Assets 6

Data protection

Protection of know-how, patents, trade and business intelligence (Intellectual Property)

Handling company assets

Consequences of violating the Boers & Co Supplier and Business Code of Conduct

Information references

Endorsement Code of Conduct Boers & Co Precision Solutions

Corporate Social Responsibility

Corporate Social Responsibility involves a duty to comply with all official and applicable regulations and resolutions in force. Boers & Co expects its suppliers and business partners (henceforth referred to as Boers & Co suppliers) to particularly observe the following basic principles:

Human Rights

Boers & Co suppliers respect the regulations in force worldwide to protect human rights as a fundamental and general requirement. This also involves Boers & Co suppliers refraining from the use of forced labour or child labour. Suppliers and business partners comply with the rules laid down in ILO Convention 138 concerning the minimum age of employment for children and in ILO Convention 182 concerning the Prohibition and Immediate Elimination of the Worst Forms of Child Labour.

Human Treatment

Boers & Co suppliers have disciplinary policies and procedures stating there is to be no harsh and inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of employees, nor the threat of any such treatment.

Equal opportunity and non-discrimination

Boers & Co suppliers do not discriminate on grounds of national or ethnic origin, race, sexual orientation, political affiliation, union membership, religion, views, age, disability, marital status or any other legally protected characteristics, unless the law requires otherwise. Employees with disabilities will be provided with the job working environment required for them to perform their job function.

Environmental protection

Boers & Co suppliers take responsibility when it comes to environmental protection concerns and comply with all applicable legislation relating to the environment and sustainability. They use natural resources sparingly and minimize harm to the environment. All required environmental permits, approvals and registrations are to be obtained, maintained and kept current. Suppliers will make continual progress towards eliminating and reducing waste of all kinds, including water and energy, at source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re- using materials.

Hazardous Substances

Boers & Co suppliers should use materials in their products which do not contain any hazardous, ozone-depleting substances, asbestos or nuclear-contaminated substances at any time. Materials applied are compliant with the various European Union Legislations and regulations imposed.

Conflict Materials

Boers & Co suppliers should agree with EU regulations on Conflict Minerals, according to the following: Suppliers are expected to supply materials to Boers & Co that are “Conflict Free” and to adopt policies and management systems with respect to conflict minerals and to require their suppliers to adopt similar policies and systems.

For example; Tin (Sn) and Gold (Au) applied in parts supplied to Boers & Co should not originate from the Democratic Republic of Congo (DRC) or an adjoining country. Tungsten (W) and Tantalum (TA) are not applied in Boers & Co products.

Product Safety

Boers & Co suppliers comply with all applicable legal product-safety regulations and requirements, particularly legal requirements pertaining to safety, labelling and packaging of products as well as to the use of dangerous substances and materials.

Working-hours

Boers & Co suppliers’ working-hours are not to exceed applicable legal limits. Suppliers will provide employees with all legally mandated leave, including maternity leave, paternity leave, compassionate leave and annual leave.

Safety in the workplace

Boers & Co suppliers comply with the relevant legal regulations for health and safety in the workplace. They support the further development and improvement of working conditions. Employees are to be provided with appropriate, well-maintained, personal protection equipment where necessary.

Minimum wages

Boers & Co suppliers ensure that their employees are commensurately remunerated. Salaries and other benefits shall be paid to employees in compliance with all applicable local wage laws and Labour Organizations and/or collective bargaining and the respective job market, including those relating to minimum wages, overtime hours and legally mandated benefits.

Transparent Business Relationships

Openness and transparency are key to credibility and trust in business practice. Boers & Co expects suppliers and business partners to particularly observe the following basic principles:

Free competitions

Boers & Co suppliers comply with the applicable antitrust legislation. In particular, they do not enter into any anti-competitive agreements with competitors, suppliers or customers. If they are in a dominant position in the market, they do not abuse this position.

Export Control

Boers & Co suppliers and business partners ensure that they comply with all applicable legal and fiscal provisions for importing and exporting goods, services and information.

Money laundering
Boers & Co suppliers only enter into business relationships with business partners whose integrity they are convinced of. They ensure compliance with applicable legal provisions on money laundering.

Business Information

Boers & Co suppliers publish business information and report on their business activities truthfully and in line with statutory regulations.

Protection of Data, Business Intelligence and Company Assets

Confidential Data, Business Intelligence, Intellectual Property and Company Assets have to be protected. Boers & Co expects suppliers and business partners to particularly observe the following

basic principles:

Data protection

Boers & Co suppliers observe all statutory regulations to protect the personal data of employees,

customers, suppliers and other parties concerned.

Protection of knowhow, patents, trade- and business intelligence (Intellectual Property)

Boers & Co suppliers respect the know-how, patents, trade and business intelligence of Boers & Co

and third parties and do not pass such information on to third parties without the explicit prior

written consent of Boers & Co.

Handling company assets

Boers & Co suppliers respect Boers & Co tangible and intangible assets and do not use them for unfair or non-business purposes. They ensure that their employees, as well as any third party they involve in the business relationship (such as subcontractors or representatives), neither damage nor misuse Boers & Co assets, i.e. use these assets contrary to Boers & Co’s interests.

Consequences of violating the Boers & Co Supplier and Business Code of Conduct

Boers & Co supplier or Business Partner is aware that there will be legal consequences for violating the Boers & Co Supplier and Business Partner Code of Conduct if the established basic principles are not adhered to.

If so, Boers & Co reserves the right to take appropriate measures such as legal action and/or terminate the business relationship with this supplier or business partner.