Supplier Code of Conduct

Northvolt AB and subsidiaries

Supplier Code of Conduct

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Table of Contents

1. Introduction

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2. Who this code applies to

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3. Roles, responsibilities and disciplinary action

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4. Human rights

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5. Health and safety

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6. Environment

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7. Ethics

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8. Implementation of the Supplier Code of Conduct9

Supplier Code of Conduct

1. Introduction

Northvolt AB (“Northvolt”) was established with a clear mission:
to build the greenest batteries in the world with a minimal carbon
footprint and the highest ambitions for recycling. Our products
are designed to accelerate the transition to a decarbonized
future and, as an organization, we know that our way of conducting business will play a crucial role in making this green transition
more inclusive and ethical.
Northvolt is committed to respecting the highest standards forhuman rights,environmental responsibility and ethical conduct inour operations and through our business relationships, including
our supply chain. Through this commitment, we believe we canhelp advance our contribution to sustainable development
The Supplier Code of Conduct (the “Code”) highlights what
we stand for and sets clear expectations for our supply chain
partners on how to fulfil our vision. The Supplier Code of Conduct
is owned by the Head of Sustainability, and has been formally
adopted by the Board.This policy is of utmost importance to our
corporate governance strategy.
The Supplier Code of Conduct seeks to align to the principles of
UN Global Compact, International Bill of Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, ILO Basic
Terms and Conditions of Employment, UN Guiding Principles
for Business and Human Rights (UNGPs), OECD Guidelines forMultinational Enterprises and OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas.

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2. Who this code applies to

3. Roles, responsibilities
and disciplinary action

Northvolt’s Supplier Code of Conduct applies to all suppliers,
contractors and sub-contractors of goods and services (hereinafter referred to collectively as “Suppliers”).

Suppliers shall ensure that their operations are not only in fullcompliance with all applicable laws and regulations, but thatthey also adhere to the internationally recognized sustainability
standards listed in the Introduction section above. This meansthat the Suppliers shall have implemented due diligence systems
in line with these international standards.
If there are discrepancies between national laws and the termsof the Supplier Code of Conduct, Suppliers must adhere to
the higher requirements. Should any requirement in this Codeconflict with the national law in any country or territory, the law
must always be followed. In such cases the supplier must notify
Northvolt immediately, before signing this Code.
The Supplier Code of Conduct sets specific conditions thatallows Northvolt to evaluate the social (including human rights),
environmental and governance performance of our Suppliers
and their supply chain. Northvolt may at any time demand that
Suppliers complete and report a self-assessment and reserves
the right to conduct audits on Suppliers and their supply chain
regarding compliance to the Supplier Code of Conduct and any
agreed upon corrective action plan.
Suppliers are responsible for conducting business responsibly
throughout their own value chain. In case of non-compliance,
including withholding audit rights or failing to meet any agreed
upon commitment, Northvolt reserves the right to terminate thecontract immediately.
Northvolt encourages Suppliers to continuously improve as theystrengthen their efforts to implement effective due diligencesystems in line with the expectations of the UNGPs and theOECD Guidelines for Multinational Enterprises. A successful
implementation of the Supplier Code of Conduct requires
an effective due diligence system which would include policy
commitments, embedding of those commitments across theorganization including through designation of roles and responsibilities, identifying risks, engaging with stakeholders, preventing
and addressing risks, tracking performance, communicating
about efforts, and enabling access to remedy where negative
impacts have occurred.

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4. Human rights
Northvolt is committed to doing business with respect for all
internationally recognized human rights in its own operations
and across its business relationships. It acknowledges potential
and real risks related to human rights that in particular areassociated with the battery value chain. Northvolt’s responsibility
is to identify, prevent, address, track, communicate and enable
access to remedy for risks and impacts to human rights and theenvironment throughout our value chain, in line with the UNGPs
and OECD Guidelines for Multinational Enterprises.
Suppliers shall have a human rights policy or committment thatsets out the supplier’s commitment to do business with respect forhuman rights across its own operations and value chain, in line with
the UNGPs and the OECD Guidelines for Multinational Enterprises.

Freedom of Association and theRight to Collective Bargaining
Suppliers shall respect the right of workers to freely and without
interference or retaliation establish and join unions or worker
representation and to bargain collectively.

Forced Labor
Suppliers shall ensure that they do not engage in any formof forced, bonded, compulsory, trafficked, modern slavery or
non-voluntary labor.
Suppliers shall provide all workers with a written contract thatclearly conveys the conditions of the employment in a language
understood by them. Suppliers shall only engage workers who
are legally entitled to work in the country, and shall ensure that
all workers (including sub-contractors) have applicable legal
documents and work permits to evidence that they are legally
entitled to work in the country. Supplier shall not impose unreasonable restrictions on movement within the workplace or uponentering or exiting company-provided facilities. Suppliers shallnot withhold workers’ original identification or travel documents.
Workers shall never be required to pay the Supplier or agent a
fee or cost for uniforms, personal protective equipment of otherexpenses need for employment. If such fees are found to havebeen paid by workers, such fees shall be repaid to the worker.

Child Labor and Young Workers
Child labor is not tolerated in any form. Suppliers shall only
employ Workers who are at least 15 years of age, or the applicable minimum legal age for employment, or the applicable age forcompletion of compulsory education, whichever is highest.
Supplier may provide legitimate workplace apprenticeshipprograms for educational benefit that are consistent with Article
6 of ILO Minimum Age Convention No. 138 or light work consis-

tent with Article 7 of ILO Minimum Age Convention No. 138.
Suppliers may employ young workers who are older than theapplicable legal minimum age but younger than 18 years ofage, provided they do not perform work that might jeopardize
their health, safety or morals, consistent with ILO Minimum Age
Convention No. 138. Suppliers shall not require juvenile workers
to work overtime or perform nighttime work.
Suppliers should demonstrate management of child labor risks
and impacts, including remediation where they have caused
or contributed to negative impacts, in policies, proceduresand practices. It is of the highest importance to always protect
children from being forced into harmful work.

Wages and Benefits
Suppliers shall pay wages and benefits at a minimum according
to applicable laws, industry standards and relevant collective
agreements, whichever is highest. Wages for a regular working
week (not including overtime pay) shall always be sufficient tomeet basic needs of personnel and to provide some discretionary income. The level of wages shall reflect the level of skills
and qualifications of regular working time regardless of gender,
national background, or other personal characteristics. Overtime
should be paid according to local regulation. Suppliers shall pay
accurate wages in a timely manner, and wage deductions shallnot be used as a disciplinary measure. Pay structure and pay
periods shall be communicated to all workers.

Non-Discrimination
Suppliers shall not discriminate based on race, caste, ethnicity
or national origin, age, gender, sexual orientation, gender identityand expression, disability, pregnancy, religion, political affiliation,
union membership, covered veteran status, protected genetic
information or marital status in hiring and employment practices.

Working Hours
Suppliers shall ensure that a regular working week is in accordance with the provisions of ILO Convention 1. Overtime should
be voluntary and be restricted to the specifications defined in
ILO conventions. The Supplier must give breaks, annual paid
leave and one day off every week unless a collective agreement
defines exceptions.

Harassment
There shall be no harsh and inhumane treatment including any
sexual harassment, sexual abuse, corporal punishment, mental
or physical coercion or verbal abuse of workers, nor the threat ofany such treatment.

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5. Health and safety

Occupational Health and Safety Management
Suppliers shall ensure that working conditions are safe andhygienic, bearing in mind the prevailing knowledge of the industry
and of any specific hazard.
Suppliers shall obtain, keep current, and comply with all required
health and safety permits. Suppliers shall provide and maintaina safe work environment and integrate sound health and safety
management practices into their business. Workers shall havethe right to refuse unsafe work and to report unhealthy working
conditions.
Suppliers shall identify, evaluate, and manage occupational
health and safety hazards through a prioritized process ofhazard elimination, substitution, engineering controls, administrative controls, and/or personal protective equipment.

Suppliers shall provide a safe and healthy environment in orderto prevent workplace accidents and injuries. Occupational
exposure to potential safety hazards and emergency situations
shall be controlled through proper design, risk assessment,
engineering controls, safe work procedures, emergency plans
and response procedures, and mandatory trainings. Suppliers
should implement a Health & Safety Management System,
including accident and near accident reporting.
Facilities and onsite accommodation for employees must
safeguard individuals’ dignity, hygiene and safety. Their conditions must comply with national laws and international healthand safety standards.

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6. Environment

Producing the world’s greenest battery is at the core of
Northvolt’s mission and competitive advantage. We continuously
assess our processes and our suppliers play a critical role inachieving our environmental and circularity ambitions. Our
Environmental Requirements can be found in Annex 1.

Environmental Responsibility
and Management Systems
Suppliers shall maintain an effective environmental policy and environmental management system, consistent with ISO 14001 or
EMAS, that promotes environmental responsibility and enables
continuous improvement of their environmental performanceand impact. Northvolt reserves the right to ask for evidence of,and the possibility to audit, the environmental management
system.

ClimateA S S E S S I N G I M PAC T S , R I S KS A N D O P P O R T U N I T I E S

Suppliers shall assist Northvolt in the evaluation of the products
and services they deliver, including all data to perform life cycle
assessment as well as end of life scenarios to follow. In addition,
suppliers shall provide information regarding their carbon
footprint and calculation methodology.
Suppliers shall develop appropriate metrics and targets tomeasure climate performance, including but not limited to theannual corporate greenhouse gas (GHG) emissions (covering
GHG protocol scopes 1, 2 and 3), product GHG intensity or use ofrenewable energy. Where this information is not publicly available, Northvolt may request annual climate performance data.
Suppliers shall conduct a climate risk assessment or climate
scenario analysis of the facilities and supply chain relevant for
Northvolt’s products. The climate risk assessment shall be inline with the methodology of the Taskforce for Climate-related
Financial Disclosures (TCFD) and include Climate Physical Risk
and Climate Transition Risk categories of the TCFD. Suppliers
shall notify Northvolt of any potentially severe risks identified
through the risk assessment and of any steps taken to minimize
identified risks. Suppliers shall share the outcome of theassessment with Northvolt upon request.
D E CA R B O N I Z I N G O P E R AT I O N S A N D VA L U E C H A I N

Suppliers shall strive to reduce the climate impact of theiroperations and value chain. Suppliers shall implement andcontrol effective actions to reduce their reliance on fossil fuels.
Renewable energy shall be prioritized. Northvolt may communicate supplier specific decarbonization targets in contracts with
suppliers and third parties.

Resource Efficiency and Circularity
Suppliers shall implement and control effective actions to reduce
their use of energy, water, raw material and packaging materials.
Suppliers shall implement a circularity perspective to minimize
use of virgin materials as far as possible.

Emissions and Waste Handling
Suppliers shall control and implement actions to reduce
emissions to air, water and waste of all types. Waste handlingmanagement for hazardous and non-hazardous material must
be developed and monitored.

Protection of Biodiversity
Suppliers shall protect natural ecosystems and seek opportunities for biodiversity conservation linked to their activity. Suppliersmust understand the connections that its business may havewith biodiversity loss and, as relevant, act to safeguard biodiversity. Suppliers shall develop appropriate metrics and targets tomeasure performance.

Material Compliance
Suppliers shall ensure that the products delivered to Northvolt
fulfill legal requirements, do not contain banned or restricted
substances, and are accompanied with correct documentation,such as a Safety Data Sheet for chemical products.
In addition, suppliers shall declare information regarding thechemical composition of the materials and products according
to the Northvolt List of Declarable and Restricted Substances.
Full material declarations shall be shared with Northvolt whenrequested.

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7. Ethics

As provided for in Northvolt’s anti-corruption policy (the“Anti-Corruption Policy”) Northvolt has a zero-tolerance policy
towards any and all forms of bribery, corruption, extortion, money
laundering, and embezzlement. Suppliers shall adhere andreject all corrupt practices, including but not limited to facilitation
payments and receipt or giving of gifts. Suppliers are responsible
for ensuring that their employees, subcontractors and otherrepresentatives comply with the Anti-Corruption Policy whenacting in relation to, or on behalf of Northvolt. The Anti-Corruption
Policy is available at https://northvolt.com/articles/code-ofconduct/.
Personal interest or relationships shall not influence Suppliers
in decision making. Suppliers shall be proactive in managing
potential conflicts of interest in collaboration with Northvolt.
All business dealings should be transparently performed andaccurately reflected in Suppliers’ financial records. Standardsof fair business, advertising and competition should be upheld.
Suppliers shall provide notification to Northvolt of counterfeit
product(s) when warranted.

Privacy
Suppliers shall comply with privacy and information security
laws and regulatory requirements when personal information iscollected, stored, processed, transmitted, and shared. Suppliers
shall commit to protecting the reasonable privacy expectationsof personal information of everyone they do business with.

Intellectual Property
Intellectual property rights are to be respected; transfer oftechnology and know-how is to be done in a manner that
protects intellectual property rights.

Responsible Sourcing of Minerals
As part of their broader human rights and environmental due
diligence, Suppliers shall exercise due diligence on relevant
minerals and relevant materials in their supply chain, which ata minimum includes conflict minerals (tin, tantalum, tungsten,gold), and battery minerals (cobalt, nickel, lithium, manganese,graphite). In line with the OECD Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas, Suppliers shall take effective measures toreasonably assure that minerals in the products, parts, components, and materials they produce do not directly or indirectly
harm human rights or contribute to conflict. Suppliers shall
exercise due diligence on the source and chain of custody ofthese minerals and make their due diligence measures available
to Northvolt upon request.

Whistleblowing and Grievance Mechanisms
Suppliers are expected to provide or cooperate in remedy incases where they have caused or contributed to harming humanrights or the environment, in line with the expectations of the
UN Guiding Principles on Business and Human Rights and theOECD Guidelines for Multinational Enterprises. In cases whereSuppliers are directly linked to identified harm, they should take arole in enabling access to remedy.
As part of this expectation, Suppliers shall establish an operational-level grievance mechanism that fulfills the effectivenesscriteria set out in Principle 31 of the UN Guiding Principles on
Business and Human Rights. As set out in the commentary tothat Principle, Suppliers shall take effective steps to ensure that
individuals who raise a concern – including in a “whistleblower”
fashion – shall not fear negative repercussions or any other formof reprisal due to having raised the concern.

Supplier Code of Conduct

8. Implementation of the
Supplier Code of Conduct

Suppliers shall ensure compliance with this Code and implement
appropriate management systems to do so. Northvolt encourages
Suppliers to continuously improve their management systems
related to the areas described in the Code.
Suppliers are expected to regularly report to Northvolt regarding
their ongoing due diligence efforts, including risk findings andperformance. This may be accompanied by an audit initiated by
Northvolt.
A suspected breach of this Supplier Code of Conduct shall be reported to a manager at Northvolt or via Northvolt’s Whistleblowing
system in accordance with Northvolt’s Whistleblowing Guidelines
available at www.northvolt.com/articles/whistleblowing/

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Supplier Code of Conduct

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Annex 1: Environmental Requirements
Annex 1: Environmental Requirements

Type of Supplier
These requirements apply to Suppliers (including contractors and agents) of equipment, materials and chemicals, parts and components and services.

Equipment

Materials &ChemicalsPart &
Components

Environment Policy and Environmental Management System in compliance with or equivalent to ISO 14001.

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Measuring, documenting and, upon request by Northvolt, reporting on:* Energy consumption (MWh), intensity (consumption per unit produced), and sources.
* Water consumption (m3) and intensity (consumption per unit produced).
* Emissions to air, water and land as well as procedures for treatment/abatement.
* Waste for disposal and recycling (mt.), including hazardous and non-hazardous classifications.
* Carbon footprint (mt. CO2 eq. according to the Greenhouse Gas Protocol “GHG” – Scope 1 and 2) and the calculation methodology.

✔

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Environmental impact – Company level

Environmental impact – Product level
Compliance with Northvolt’s General Technical Specifications✔

Northvolt’s Equipment Energy Balance template and Utility Matrix template (links)✔

Material balance diagram with clear boundary definitions & potential emissions to air, water, land and work environment within the scope in which they
operate, emissions points (including from continuous operations, storage & maintenance) and levels without abatement.

✔

Upon request, carbon footprint (CO2 eq. according to the GHG Protocol) associated with the manufacturing of the product and the calculation methodology
or provide the information necessary for its calculation.

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Upon request, partners shall provide information for a Life Cycle Assessment ("LCA") according to ISO 14040/14044.

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Material compliance✔

Safety Data Sheets in compliance with EU and applicable national regulations.
Full material declaration, if requested.

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Compliance with the registration, notification, labelling or any other requirement in REACH EC 1907/2006, RoHS EC 2011/65 and CLP EC 1272/2008, as
amended.

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Compliance with "Northvolt List of declarable and restricted substances".

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Due diligence process according to the OECD's Due Diligence Guidance for Responsible Supply Chains of Minerals.

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Obligation to inform
Inform, without delay, if a significant environmental incident occurs as a result of the execution of activities for or on behalf of Northvolt.