Rules & Regulations
dormakaba Supplier Code of Conduct │Validity 01.09.2021│Version: 5.2

dormakaba Supplier Code of Conduct
dormakaba is committed to very high standards of sustainability, business ethics andintegrity, as reflected in dormakaba`s Code of Conduct (the “Code”). The Code isapplicable to all dormakaba affiliated companies and employees, and this Supplier Codeof Conduct (also hereinafter referred to as “Supplier Code”) is a natural outgrowth of it
and reflects dormakaba’s desire to extend its commitment to high standards ofsustainability, business ethics and integrity to its material suppliers, service providers
and other business partners including their affiliates, officers, directors, agents,employees, representatives, subcontractors, and consultants (the “Supplier”). The
Supplier Code is therefore made available to our Suppliers with the goal of strengthening
our mutual understanding of how sustainable business should be practiced on a day-today basis.
dormakaba expects all of its Suppliers and their sub-contractors to adhere to equivalentstrict working standards and business ethics. This Supplier Code states our generalprinciples and sets our minimum expectations regarding the actions our Suppliers taken
on behalf of our company and our clients.
Suppliers are obliged to ensure that these obligations are already in place. In addition,
dormakaba and the Supplier may agree on further standards in supply relatedagreements.
Where compliance with the Supplier Code could lead to a conflict with or a violation of
applicable laws and regulations, the Supplier shall promptly notify dormakaba of thesituation, and explain how it intends to resolve the conflict while operating in aresponsible manner that complies as closely as possible with the letter and the spirit of
the Supplier Code.
dormakaba offers its employees and its customers, suppliers and other business
partners, an independent, impartial, and publicly accessible whistleblowing portal topoint out securely and anonymously acc. ISO 27001 potential legal or serious
compliance incidents. All dormakaba supplier are encouraged to share this possibility
with their employees and business partners or introduce an alternative whistleblowing
tool. dormakaba grievance mechanism is permanently 24/7 available underhttps://www.dormakabagroup.com/en/investors/corporate-governance/whistleblowing
or directly under www.bkms-system.com/dormakaba.
This Supplier Code of Conduct has been set in place originally on October 1st, 2016 andwill remain valid according to the latest version until further notice. It will apply throughout
the dormakaba group and its entire supply base.
A.

HUMAN RIGHTS
In accordance with the afore mentioned statements, dormakaba requests the following
business practices from Suppliers at all times, without exceptions:•••to respect the personal dignity, privacy, and rights of each individual;
to refuse to employ or make anyone work against his or her will;
to prohibit behavior including gestures, language, and physical contact, that issexual, coercive, threatening, abusive or exploitative behavior.

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Rules & Regulations
dormakaba Supplier Code of Conduct │Validity 01.09.2021│Version: 5.2
B.

FAIR LABOR CONDITIONS AND CHILD LABOR
dormakaba expects its business partners to ensure fair labor conditions to all Employees
and managers, including part-time and temporary workers as well as casual workers
such as day labor workers (the “Employee”). Therefore, Suppliers have to adhere to thefollowing provisions:
The Supplier will provide a working environment free of discrimination, harassment,
intimidation, or coercion relating directly or indirectly to age, gender, race, color of skin,nationality, social or ethnic origin, language, sexual orientation, marital status, religion orstate of health or disability for every Employee. Furthermore, the Supplier will comply
with these provisions in any aspect of employment (e.g., recruitment, promotion, andremuneration).
The Supplier will respect the rights of Employees to freely associate and bargain
collectively. This means that the Supplier’s Employees have the freedom to join, or not
to join, an association of free choice as well as establish an association of free choice,to organize and to bargain collectively and individually in accordance with local laws andregulations.
The Supplier will compensate Employees fairly and refrain from offering excessively low
wages (“wage dumping”), as exploitive behavior in this respect is at odds with thedormakaba principles. Salaries shall be paid regularly. The compensation shall bemerchantable and in accordance with relevant national statutory minimum wage rates.
The Supplier is expected to offer its Employees working conditions in compliance withall applicable laws and mandatory industry standards pertaining to regular working hours,and overtime hours, including for breaks, rest periods, holidays, maternity, and paternity
leaves. The Supplier shall not require a regular work time over 60 hours per week,including overtime. Employees shall be allowed at least one day off after six consecutive
days of work, and any overtime worked shall be voluntary and compensated at premiumrate.
The Supplier will not use any forced, compulsory, bonded (including debt bondage) orindentured labor; involuntary or exploitative prison labor; slavery or trafficking of persons
is not permitted. Following the ILO Forced Labour Convention, No. 29, the term forced,
or compulsory labor shall mean all work or service which is compelled from any person
under the menace of any penalty and for which the said person has not offered himself
voluntarily.
There shall be no unreasonable restrictions on Employees’ freedom of movement.
Supplier may not hold or otherwise destroy or conceal, confiscate, or deny access by its
Employees to their personal documents (originals) such as passports, work visa/permits,
citizenship, etc. unless required by law. Employees shall be free to leave work at any
time or terminate their employment without penalty if reasonable notice is given as per
the Employee’s contract. Employees migrating for the purpose of work shall not berequired to pay recruitment fees or other related fees for their employment, as this canlead to situations of debt bondage. Should victims of human trafficking be found in theSupplier’s operations, they must be provided with adequate access to remedy.
The Supplier will not tolerate or use child labor in any stage of its general activities otherthan in accordance with all applicable laws and regulations; with regard to minimum

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Rules & Regulations
dormakaba Supplier Code of Conduct │Validity 01.09.2021│Version: 5.2
employment age, Supplier will follow the principles of the UN Global Compact and theILO Minimum Age Convention, No.138. A child in this context is a person younger than
15 years of age, or 14 years of age in accordance with the exceptions for developing
countries as set out in Article 2.4 in the ILO Convention No. 138 on Minimum Age.
If national legislation has set a higher minimum age, this age will apply.
C.

OCCUPATIONAL HEALTH AND SAFETY
The Supplier will provide a safe and healthy workplace for all of its Employees. Thatmeans, the Supplier will take measures to prevent workplace violence and harassment,accidents on building sites, in plants and at any other workplaces. Complainants
reporting harassment are protected from retaliation and reprisals and unsafe anddangerous conditions will be eliminated immediately. Therefore, hazards and effects ofactivities, products and services will be assessed and appropriate measures to eliminate
or minimize the risks and their effects will be implemented.

D.

ENVIRONMENTAL RESPONSIBILITYThe Supplier is committed to environmental protection and will conduct its business inan environmentally sensitive way.
D.1 Hazardous Substance Management and Restrictions
If the Supplier uses hazardous substances, it shall comply with all applicable laws andregulations prohibiting or restricting the use or handling of specific substances (e.g., toxicgases like chlorine). To ensure safe handling, movement, storage, recycling, reuse anddisposal, the Supplier shall identify and manage substances that pose a hazard if
released to the environment and comply with applicable labeling laws and regulations
for recycling and disposal.
D.2 Waste Management
The Supplier shall manage and dispose of non-hazardous waste generated fromoperations as required by applicable laws and regulations. The Supplier shall minimize
environmental pollution and make continuous improvements in environmental protection.
dormakaba encourages the Supplier to communicate to its management, Employees,
and contractors its commitment to improving the environment, and to provide training onsuch commitment.

E.

RIGHT TO AUDIT
dormakaba reserves the right to audit any of its Suppliers by appointment in order toconfirm that the requirements set out in this Code of Conduct are in force. Failure topermit such an audit may result in termination of any supply contract with dormakaba
and its subsidiaries.

F.

BUSINESS ETHICS
F.1

Honesty and good Faith

In all commercial transactions with dormakaba, as well as with their own Suppliers,
subcontractors and Employees, our Suppliers are expected to act in an honest and goodfaith manner, across all aspects of their operations, both internally and externally. The
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Rules & Regulations
dormakaba Supplier Code of Conduct │Validity 01.09.2021│Version: 5.2
Supplier will conduct its business in an ethical manner in accordance with all applicablelaws, rules, and regulations. In particular, the Supplier will:•••F.2refrain from any and all forms of extortion and bribery;
adhere to anti-trust and other competition laws, e.g., not participating in pricefixing or bid-rigging anddisclose to dormakaba available information about conflict of interest, including
disclosure of any financial interest of a dormakaba employee in any aspect of
the Supplier’s business.

Gifts

All illegal benefits to third parties directly or indirectly, whether public authorities or in theprivate sector, are forbidden. The converse applies in respect of receiving such benefits.
Facilitation payments are forbidden as well as the offer or acceptance of a gift in cash orcash equivalent. We expect our Suppliers to work according to all international antibribery and anti-corruption standards.
F.3

Confidentiality

The Supplier and its Suppliers and sub-contractors will protect all confidential
information provided by dormakaba and its respective business partners. They must at
all times protect any personal data from misuse and comply with all applicable dataprotection laws and regulations.
G.

BUSINESS CONTINUITY PLANNING
The Supplier shall implement and maintain policies to mitigate the risk of businessdisruptions by exposures to risks including, but not limited to, terrorism, crime, software
viruses, cyber-attacks, business threats, labor disputes and strikes, disease, pandemics,
natural disasters and major accidents.

H.

PROCUREMENT BY SUPPLIER
dormakaba expects the Supplier to obtain confirmation from each of its sub-Suppliers
providing goods or services directly or indirectly to dormakaba that the sub-Supplier acts
in compliance with this dormakaba Supplier Code of Conduct.

I.

COMPLIANCE WITH APPLICABLE LAWS, RULES & REGULATIONS
dormakaba Suppliers are expected to comply with all applicable laws, rules andregulations. This means laws, rules and regulations that apply to Supplier’s location, but
may also include the laws, rules and regulations of other locations depending on thenature of the transaction engaged in with the dormakaba affiliate and where that affiliate
is located.
dormakaba is also committed to comply with relevant laws and regulations requiring
disclosure of and avoiding the use of conflict minerals. All goods delivered to dormakabashall comply with these conflict mineral regulations. Conflict minerals are minerals, suchas tin, tantalum, tungsten and gold, originated from conflict-affected areas in order tofinance armed conflicts or that are being mined under serious human rights violations.

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Rules & Regulations
dormakaba Supplier Code of Conduct │Validity 01.09.2021│Version: 5.2
J.

IMPLEMENTATION & COMPLIANCE
dormakaba expects its Suppliers to self-monitor their compliance with the Supplier Code,that is published in latest version on the dormakaba corporate homepage. In the case ofany serious breach of this Supplier Code by the Supplier, dormakaba shall review its
arrangements with the Supplier. dormakaba reserves the right to terminate its business
relationship with any Supplier who is unwilling to comply with this Supplier Code.

K.

GOVERNMENT, MEDIA AND INVESTORS RELATIONSThe Supplier shall not instigate any form of publicity or make any statement or
submission to investors, the media or government referring to dormakaba, without firstobtaining prior written permission from dormakaba (except where required byGovernment or under the law). The Supplier must submit any such request to dormakaba
Group Communication Department for appropriate authorization.

L.

SUPPLIER CONFIRMATIONThis Compliance Declaration must be signed by a duly authorized representative (owner,director or higher) of the respective company and returned to sender within 15 working
days of receipt. Wherefore, by its authorized signature below, Supplier confirms receipt
of a copy of the dormakaba Supplier Code of Conduct and agrees to comply with its
terms henceforth.

Supplier Name:
Signature 1: _________________________________________________________

Print Name: __________________________________________________________

Title: ______________________________(readable in print)_________________________________

Supplier Address:__________________________________________________________________

Date: ______________________________

optional
Signature 2: ________________________
Print Name: _________________________(readable in print)

Title: _______________________________________________________________

Date: ______________________________

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