Code ofConduct

Codeof Conduct
Christoph, can you share yourthoughts why we need a Code ofConduct?
Integrity is a core value in our caring
and performance-oriented culture. In theCode of Conduct we set standards andexpectations to follow when it comesto behavior at the workplace. Also, ourcustomers and partners expect to know
the principles we adhere to.

We need eachcolleague asambassador ofour v­ alues and­s tandards –everyone,
every day andeverywhere.
Christoph Loos,CEOJune 2021

Would you say that the code is a­corporate document?
We all own this document. The Code ofConduct was created with input fromregions and colleagues across all functions and from diverse backgrounds. To
achieve our high ambitions in businessethics, we need each colleague to serveas an ambassador for our values andstandards – every­one, every day andeverywhere.
How does the code impact ourdaily business?
Speaking on behalf of our Executive
Board and the Board of Directors, I am
convinced that the Code of Conduct
helps us to make the right decisions inour daily business activities. Neglect
or failure to follow these basic rules forbusiness success clearly contradicts
our company culture and will not betolerated.
Thank you.

Application of theHilti Code of Conduct
This Code of Conduct outlines the legal
and ethical framework of the Hilti Group,with further definition and details to befound in our company policies. This
Code of Conduct applies worldwide
wherever and whenever Hilti engages
in business activities. It helps us to act
correctly in situations when our values
are challenged.

the same risk, so we take action toresolve any non-compliance with theprinciples of this Code of Conduct. Themeasures depend on the severity of thebreach and can range from warnings
and reminders to immediate termination,
civil action for damages and criminal
prosecution.

The Executive Board members andsenior leaders understand themselves tobe role models, acting with integrity every day. Their examples set the tone for
the Compliance Team’s work in bringing
our Code of Conduct to life.

The principles of this Code of Conduct
are binding for the Board of Directors,
the Executive Board and all employeesof the Hilti Group, including ­temporary
workers and interns to the extend­allowed under local laws. We expect
our team leaders to lead by example.

We are all aware of the possible consequences of criminal behavior in ourown countries. As a company we face

Our suppliers and business partners are
required to adhere to business principles
consistent with our own.

REGISTER
Anti-Corruption

Conflicts of Interest

Diversity and Inclusion

2

Data Protection

3

Protecting ourPassion for Products
and Resources

Fair Competition

4

Health and Safety

Discriminationand H­ arassment-FreeWorkplace

5

Environment

6

Human Rights

117

Economic Sanctions
and Money ­Laundering­Prevention

128

Product Safety andCompliance withTechnical Regulations

139

Political, Ideologicaland ­Religious
Neutrality1410 uidance for Cases
Gof Uncertainty

15Anti-Corruption
OUR COMMITMENT

We do not give, offer or receive bribes. Hilti pursues a strategy ofzero tolerance towards bribery and corruption. We win the trust ofour customers with leading edge solutions – products, services,software and systems.
We strictly abstain from offering or
giving benefits to – or receiving from,a person or institution (whether directly or indirectly), with the intention
to influence the decision process of abusiness partner, public authority orourselves.

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CODE OF CONDUCT

We may offer, give or receive reasonable gifts, hospitality or other benefits
if they are subject to customs andtraditions. Such benefits are pre-approved and/or recorded in our benefit
approval tool, where additional information can also be found. Particularly
restrictive rules apply to offering
or giving benefits to public officials.

Conflictof Interest

OUR COMMITMENT

During our daily business we must avoid situations in which
private interests (including personal or family relationships)
are in conflict or could come into conflict with our job roles orwith the interests of Hilti as a company.
We disclose actual or potential conflicts of interest to our direct manager,
allowing for an independent viewof our task portfolio and avoiding
the impression of partial businessdecisions.

The mere existence of private interests in a business situation does
not necessarily lead to a conflict ofinterest. We can solve most cases
through clear documentation of theprivate interests and transparency on
the conflict. This type of documentation benefits everyone involved: it
demonstrates our personal integrityand Hilti’s integrity as a company.

CODE OF CONDUCT

3

FairCompetition

OUR COMMITMENT

We at Hilti believe in the importance of functioning markets
and fair competition as driving forces for innovation, technological progress and continuous quality improvement. We arecommitted to act according to fair competition practices.
We will never participate in agreements or cooperative practices whose
purpose or effect is the prevention orrestriction of competition.
We limit our communication withcompetitors to legally approved
forums and scope. In our communication we must not share any information that would allow for conclusions

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CODE OF CONDUCT

to be drawn about Hilti’s current or
future market behavior. We will not improperly discriminate among customers or unduly obstruct competitors ormanipulate pricing.
When our products are in a dominantposition in the market, we follow internal guidelines to prevent the abuse ofsuch position.

Discriminationand HarrassementFree Workplace
OUR COMMITMENT

We at Hilti do not tolerate any form of discrimination orharassment.
We do not tolerate any unjust or prejudicial treatment of a person based on
their actual or perceived association
with a certain identity or characteristic. This includes genetic heritage,ethnicity, color, age, gender identity,disability, sexual orientation, religion,
nationality or any other characteristic.
We condemn all forms of harassment,
whether verbal or physical conductthat degrades or shows hostility oraversion.

We do not use derogatory comments,
slurs, inappropriate jokes, stereotypes
and insults. We do not share pictures,cartoons, or electronic messages
that are degrading to a colleague orcustomer.
We ban sexual harassment and sexual
advances from our working environment. If we experience or observe any
kind of discrimination or harassment it
is reported via our “SpeakUp” hotline.

CODE OF CONDUCT

5Diversity andInclusion
OUR COMMITMENT

We are committed to fostering an open, respectfuland collaborative culture. We establish an inclusive and d­ iverse workforce with equal opportunities.
We value, welcome and leverage different strengths, perspectives
and experiences – regardless of ethnicity, nationality, genetic h­ eritage,­sexual identity or orientation, age, disability, political or religious beliefs.
We are open-minded and respectful
and acknowledge different perspectives. We seek the contributionof people with different identities,
backgrounds, and perspectives in
our hiring process and in all subsequent interactions. We encourage­colleagues to bring their uniquestrengths to work and be authentic.
To achieve that – we actively listen to6

CODE OF CONDUCT

each other and we make others feel
welcome to voice their opinions, to try
and understand each other better andto create a sense of belonging.
We perform at our best in a caring andinclusive culture that creates enthusiastic customers and building a better
future.

DataProtection
OUR COMMITMENT

While we engage with our customers and business partners, wenever compromise their privacy in our corresponding records.
We protect the personal data of our colleagues in all our internalprocesses.
For our products and services, we strive to deliver on the promiseof digitalization. We seek to adhere to all applicable privacy lawsof the markets in which we operate, and reflect on data protection,
security and privacy in our product and service design phase.
We collect, store, process and use
personal data solely for legitimate
business purposes or if legallyrequired, and always in accordancewith the applicable laws or with theconsent of those affected.
We implement high standardsof information security for all
our products and services. This
includes adequate technical andorganizational measures to ensure
the security of our assets, employee
details or data entrusted by thirdparties.
During product and service
development, we consult withdata protection representatives
to e­ nable privacy by design.

Protectingour Passion &Resources
OUR COMMITMENT

We safeguard our technical know-how and confidential businessinformation which provides us competitive advantage and is
unknown outside Hilti. We diligently abstain from infringing on theintellectual property rights of others. We treat business assets withcare and in line with internal policies.
Even if we are very proud of our knowhow, a new product or innovation, we
do not share it until it has been adequately protected legally or officiallyreleased. In case we need to shareconfidential information, we consultinternally with the Intellectual Property
or Legal Departments about possible
protection mechanisms before weshare it.

8CODE OF CONDUCT

We take care when we deal with Hilti’s
business assets and make sure not todamage, misuse or waste such assets.
Company resources and data areintended only for company purposes.

Health & Safety
OUR COMMITMENT

We are committed to providing a safe and healthy working environment for our colleagues, contractors and visitors. We provide
our customers with solutions for improving health and safety inthe workplace and building safety.
We all bear responsibility for occupational health and safety within ourfacilities as well as for our activities atour customers’ sites. This means wewear adequate personal protective
equipment at work, during productdemonstrations, and we respect thesafety rules of our customers whenon site.

With our innovative products anduser training sessions, we actively
contribute to the health protection
and accident prevention of our customers. At the same time, we offer ourcustomers products and solutions toincrease building safety for their ownclients.

CODE OF CONDUCT9Environment
OUR COMMITMENT

We strive to reduce the ecological footprint of our operations andproducts, through our environmental objectives and operational
improvements, and we promote environmental awareness andprecautionary measures.
During product development we
identify opportunities to minimize thepotential environmental impact ofHilti products, operations or services.
Beyond that we try to prevent andanticipate if our products may havenegative environmental effects.

10CODE OF CONDUCT

To do that we continuously strive
to reduce energy and raw material
consumption, waste, water usage,
emissions and noise – in the way
we may best contribute to it. We
share environ­mental best practices
across our operations and integrate­circularity principles into productdesign and supply.

HumanRights
OUR COMMITMENT

We strive to avoid adverse human rights impacts
throughout our business operations and in the communities in which we engage. We are vigilant to ensure ourbusiness and supply chain are free of modern slavery,
complying with the core international labor standards
and operating with integrity.
We also pay close attention that our business partners
respect human rights.
We work against discrimination, forced, trafficked and childlabor and are working to establish and maintain safe and healthy
working conditions throughout our operations and supply chain.
We respect the right to freedom of association and collective
bargaining.
As we respect human rights across the company, we expect oursuppliers and business partners to adhere to business principles
consistent with our own. We let independent partners assess us
and our suppliers in this regard.

CODE OF CONDUCT

11

Economic Sanctions
and Money Laundering
Prevention
OUR COMMITMENT

We comply with applicable customs regulations, export controls,
and trade sanctions laws. We support the fight against money
laundering and terrorism financing within our operational reach.
We report misconduct and prohibited
activities and highlight the potential
repercussions of non-compliance withtrade sanctions to our colleagues. To
stay compliant, we evaluate our business partners, customers, products,services, supply chain, transactions
and geographic locations dependingon the nature of the operation.

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CODE OF CONDUCT

To limit the risks of money laundering,
we avoid cash transactions whereverpossible. We also collect all relevant
information from a customer andbusiness partner at the on-boarding
stage. We have a constant dialog withour banking partners to review topics
that arise from their risk assessment.

Product Safety andCompliance withTechnical Regulations
OUR COMMITMENT

We ensure the regulatory conformity of our products. We comply
with laws and technical regulations for our products or services ineach country where we sell.
As experts, we strengthen the confidence in our products through professional
product demonstrations and training sessions.
We design and test products according to appropriate worldwide standards for
product safety, and other compulsory regulatory requirements, for their intended
purpose.
CODE OF CONDUCT

13

Political, Ideolo­gicaland Religious Neutrality

OUR COMMITMENT

In the light of our company ʼs cultural heritage, we maintaina political, ideological and religious neutral workplace.
We focus on our business when weare at work.
As a company we do not support political, ideological or religious groupsof any kind around the world. Whilediscussions regarding work and working conditions are always permitted,

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CODE OF CONDUCTas colleagues we do not promote ourpolitical or ideological opinion nor ourreligious conviction in the workplace,or on social media, as Hilti represen­tatives. We do not bring politicalsymbols or advertisement materials
to the office.

Guidance
for Cases ofUncertainty
In this Code of Conduct we commit to principles that we all must
adhere to. It can happen that we are confronted with a situation
where we may not be clear on how to act in accordance withthese principles. Here are the key questions we may use in suchcases of uncertainty:
1. Would I feel comfortable if information about my actions were investigated by law enforcement authorities,competition authorities or other thirdparties?
2. Would I feel comfortable if I saw myactions online or on TV, or if I readabout them in the newspaper?

3. Would I feel comfortable if I had
to explain my actions to my TeamLeader?
4. Would my Team Leader or colleague
be following the compliance rules ifthey acted the way I do?
5. Would I feel comfortable if I told oneof my family members about myactions?
If the answer to any of these questions is “no,” you may not engage inthe planned action!

CODE OF CONDUCT15Behavior when ­Aware or Suspiciousof Violations
Employees are encouraged to immediately report violations of this Codeof Conduct or any applicable laws
and regulations, if in good faith. Thismeans that the employee should have
objective reason to believe that theinformation disclosed, and any related
allegations, are substantially true.
Employees who, in good faith, report
known or presumed violations will beprotected from retaliation. Any kind ofreprisal against employees who reportviolations in accordance with theseprinciples is a clear and severe breachof this Code of Conduct and will besanctioned accordingly.
Disclosures whose purpose is to falsely accuse colleagues or Team Leaders
will not be tolerated. Such behavior
also represents a clear and severe
breach of this Code of Conduct andwill be sanctioned accordingly.

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CODE OF CONDUCT

To report known or presumed violations and obtain support and answers
on compliance issues, employees
can reach out to the following contact
persons:
1. Team Leaders
2. HR Business Partners
3. Local Compliance Officers
4. Chief Compliance Officer,
cco@hilti.com
5. SpeakUp Whistleblowing Hotline
In the case of especially severeviolations (e.g. sexual harassment,criminal acts or violations of antitrustlaws), Hilti employees shall make useof the “SpeakUp” external ­compliancehelpline. The contact data for thiscan be found using the short link­“Compliance” on REDi or scan thisQR code:or as wallpaper on local blackboards
in plants, warehouses, repair centers,etc.
The external compliance helpline andthe Chief Compliance Officer will treat
the identity of employees who disclose
the known or presumed violations
as strictly confidential, to the extent
legally possible. Exceptions may benecessary for legal reasons after theresults of internal investigations orregarding the personal rights of otheremployees.

June 2021