Supplier Code of Conduct

1. Borenius Attorneys Ltd (”Borenius”, the ”Firm”, “we” or “us”) is a leading independent Finnish law firm. We work together with other highly regarded law firms across the globe that share our commitment to excellent service and quality.

2. We are committed to conducting business and providing legal advice in accordance with the highest legal and ethical standards. The integrity of our vendors, as well as our product and service suppliers and other business partners (“Suppliers”, individually the “Supplier”) is critical to the success of the Firm.

3. Borenius’ Board has decided to issue this Supplier Code of Conduct (the “Supplier CoC”) in order to increase our Suppliers’ awareness of this important matter. The Supplier CoC reflects our commitment to abide all regulations and to uphold all ethical standards. We require for all parties doing business with Borenius should accept this Supplier CoC.

4. This Supplier CoC outlines the minimum standards Borenius requires its Suppliers to comply with when doing business with Borenius in addition to observing all laws and regulations governing their activities.

5. This Supplier CoC forms an integral part of all contracts concluded between the Supplier and Borenius. In addition to Suppliers who have a direct contractual relationship with Borenius, this definition also includes the Suppliers’ sub-suppliers and sub-contractors as well as any consultants or partners that are in business relationship with the Supplier in order to deliver products or services to Borenius.

1. Business and Ethical Conduct

6. The Supplier must be committed to ethical conduct in the spirit of internationally recognised standards, i.e. the Supplier must act in a manner that is generally considered ethical, in all of its operations.

7. The Supplier must adhere to this Supplier CoC or its own equivalent code of conduct, whichever is stricter, as well as to all other relevant and applicable laws and regulations including all applicable export control laws and international trade sanctions.

8. The Supplier and its employees must take all reasonable care to ensure that no one participates in any practices, which could be prohibited under applicable laws or generally considered unethical, on behalf of the Supplier. The Supplier is required to ensure that all of its contractors, partners, consultants and other sub-parties are obliged to adhere to the aforementioned practices.

3. Corruption and Bribery

9. The Supplier’s directors and employees as well as any third parties acting on its behalf may not offer, give or receive any gift or payment that is or could be construed as a bribe, or make or accept any improper payments, including facilitation payments, to obtain new business or retain existing business. The provision of any incentives to Borenius employees, their family members or friends for the purposes of conferring improper personal or business related advantage are prohibited.

10. Reasonable business courtesies, including gifts and corporate hospitality (e.g. entertainment, business lunches and small gifts) that comply with applicable laws and regulations are permitted.

4. Responsible Employer

11. The Supplier must ensure that its employees are above the applicable minimum age (in line with the ILO convention 138 on child labour). Child labour in any form is prohibited, and if the Supplier employs someone who is under 18 years old, their work must not jeopardise their education, health or safety.

12. The Supplier must treat all employees fairly and respectfully. Employees must have the right to organise, belong to a union and bargain collectively. Any form of involuntary labour is prohibited.

13. The Supplier should not discriminate against some of its employees. Proportionate treatment that aims to promote de facto equality, or to prevent or remove the disadvantages attributable to discrimination, is allowed.

14. The Supplier is required to pay wages defined by applicable laws and regulation, including collective agreements, and apply working hours that comply with applicable law and collective agreements.

15. The Supplier must take care of matters related to occupational health and safety in line with applicable law, and establish internal occupational health and safety policies and procedures that are communicated to all employees. The Supplier must report and investigate all health and safety incidents.

5. Conflicts of Interest

16. The Supplier should avoid any interaction with Borenius’ employees that may conflict or appear to conflict with that employee’s duty to act in the best interests of Borenius. The Supplier must disclose all conflicts of interests or circumstances that could give the impression that a conflict of interest exists in its engagement with Borenius.

17. The Supplier must inform Borenius if a Borenius’ employee or a Borenius employee’s immediate family member holds a financial, material or other interest in the Supplier. The Supplier must also inform Borenius if a Borenius’ employee or a Borenius employee’s immediate family member holds a managerial position at the Supplier or works for the Supplier and such employment creates a conflict of interest or could give the impression that one exists.

6. Fair Competition

18. The Supplier competes in a fair manner in compliance with all applicable competition laws and regulations, e.g. by not entering into any agreements with its competitors to raise prices or to restrict the availability of products.

7. Environment

19. The Supplier must comply with environmental regulations and standards that apply to their operations, and the Supplier must observe environmentally conscious practices at all locations where it operates.

8. Product and safety

20. All products and services used in the course of the business relationship between the Supplier and Borenius must meet the quality and safety criteria specified in applicable regulation and relevant contract elements. The Supplier must manage the product safety risks throughout the entire supply chain. The Supplier must use raw materials of known origin and ensure the traceability of raw materials and finished products. Furthermore, the Supplier must ensure that delivered products are safe for people and the environment if used as intended.

9. Reporting

21. The Supplier is required to report any non-compliance with this CoC to Borenius immediately. The Supplier and any of its employees may report their concerns confidentially to:

22. The Supplier must provide Borenius with access to all relevant information and documents required to verify the Supplier’s conformance with the Supplier CoC upon request.

10. Misconduct

23. Should Borenius find that the Supplier does not meet the requirements and expectations set out in this Supplier CoC, Borenius will offer guidance to correct the issues or to improve the Supplier’s procedures. The Supplier must then promptly take corrective actions promptly as advised by Borenius.

24. Should the Supplier have, in the reasonable opinion of Borenius, materially violated the Supplier CoC, Borenius is entitled to terminate its business relationship with the Supplier with immediate effect.

11. Governing Law & Disputes

25. This Supplier CoC is governed by Finnish law, excluding its choice of law rules or principles.

26. Any dispute, controversy or claim arising out of or relating to this Supplier CoC will be finally settled by arbitration in accordance with the Arbitration Rules of the Finland Chamber of Commerce. The number of arbitrators shall be one. The seat of arbitration shall be Helsinki, Finland.

12. Approval

27. By agreeing to work with Borenius, the Supplier confirms that it and its affiliates comply with the Supplier CoC. The term “affiliate” refers in this Supplier CoC to any company that is controlled by the Supplier or which controls the Supplier or which is controlled by the same entity or entities as the Supplier.

Version: 2020/06