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DemantGroup
Name of Policy
Code of Conduct• Demant Group

Code of Conduct is also available inour compliance app.
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December 2022
Demant - Code of Conduct 2022

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Letter fromthe CEO
Dear Demant employees,
Every day, we strive to deliver innovative
audio and hearing technologies andservices to help improve people’s healthand hearing. We are let into people’s lives
and are involved in some of the mostimportant aspects of life by enabling
people to communicate and be actively
engaged in social settings. Caring for otherpeople’s well-being and our society has
always been the core of our business, so
being in this line of business is indeed a
big responsibility.

I believe that high ethical standards play asignificant role in ensuring our continued
growth and success. We do notcompromise on our commitment tointegrity.

This Code of Conduct sets the minimum
standards and ethical principles applicable
to all employees. The Code of Conduct
serves as a guideline and point ofreference for anyone faced with dilemmas,
doubts or concerns.

Thank you for your support.

If you have concerns about our ethicalbehaviour, it is possible to raise your voice
via our whistleblower hotline.
I kindly ask you to study this Code of
Conduct carefully, and live by its principles
in your daily activities.

Søren Nielsen
CEO

Demant - Code of Conduct 2022

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The Demant
Code of Conduct
This Code of Conduct describes the way
we do things.
It is the framework and sets the minimum
standards and ethical principles applicable
to all employees regardless of location andnature of work.
This Code of Conduct provides everyone
with a common understanding of how we
conduct business. Whenever in doubt ofcorrect business behaviour, please consult
your manager, local legal or Group Legal& Compliance atGroupcompliance@demant.com

We adhere to the laws of each countries inwhich we operate, including the Foreign
Corrupt Practices Act and the UK BriberyAct.
We conduct business in line with the UN
Global Compact principles and relevantinternationally recognised standards. We
adhere to quality regulations and conduct
responsible marketing.
Global Policies can be found on
www.demant.com, our compliance app
as well as on our internal sites.
At Demant, we have a whistleblower
hotline. If an employee or third party
suspects or observes a violation of thisCode of Conduct, we trust him or her toreport any concerns or violations as soon
as they arise. This Code of Conduct
includes information on how to raise
concern.

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Table of contents
Anti-Corruption

5Compliance with Competition Law

6

Fraud

7

Data Privacy

8

Human Rights

9

Environment

10

Workplace Environment

11

Business Partner Relations

12

Export Controls and Sanctions

13

Raise Concern

14

Definitions used in the Code of
Conduct

15

Demant - Code of Conduct 2022

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Anti-Corruption
Demant is against any form of direct orindirect corruption and bribery with theaim of securing an improper advantage.
We are committed to avoid such practices.
We want to avoid conflicts of interests
where personal interests may result in
corruption or may be perceived as such.
We do not tolerate facilitation payments,
and we will not pay protection or extortion
money in any country unless there is athreat to our health and safety. Facilitation
payments are small payments or gifts
offered to public officials and intended tosecure or speed up routine governmental
actions, which you are already entitled to,
or to obtain unlawful preferential
treatment.
Business interactions, such as providing or
receiving hospitality, gifts, grants,
sponsorships or donations, are consideredpart of doing business and maintaining
relationships. However, such payments
can be perceived as having undue
influence on business decisions. You mustnever offer, provide or accept suchpayments in order to win or retain
business under improper conditions.

What is expected of you?
• Whenever you face dilemmas or you are in doubt about how we do things, please consult our Demant Group Policy on
Anti-Corruption for further explanations, Q&As etc. This policy is available on our legal compliance SharePoint site and in
our compliance app.
• Never directly or indirectly engage in any type of bribery. Contact your manager immediately if you are offered or asked to
pay a bribe.
• Facilitation payments are prohibited. If you are met with a demand to make a facilitation payment, you may only make thepayment under extraordinary circumstances if there is a threat to your health and safety. In such a case, ask for
documentation that payment has been made, report the incident to your manager and record the payment in the books foraccounting purposes.
• Ensure that circumstances that might suggest a conflict of interest are transparent and never involve yourself in commercial
activities if they contain a financial or personal advantage.
• Ensure that any gift or hospitality given or received has a legitimate business purpose, is of moderate value and isreasonable, appropriate and proportional to the relationship in each case.
• Do not give or receive cash or cash equivalents to facilitate an undue advantage.
• Special care must be taken with anything of value given to public officials, as such transactions are illegal in most countries.

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Compliance with Competition Law
Competition laws are intended tostimulate free markets and enhance
productivity, innovation and value forcustomers. We are committed to
conducting our business in full compliancewith applicable competition and antitrust
laws.
Failure to comply with competition laws
could have serious consequences for
Demant and its employees, such as
damage to our reputation, large fines (upto 6% of Group revenue), exclusion frompublic contracts, lawsuits andimprisonment.

What is expected of you?
• Special care must be taken by employees dealing with customers and distributors (e.g. in sales), competitors (e.g. throughindustry associations and fairs) and management and especially when employees are involved in pricing and commercial
strategies. Always familiarise yourself with our Demant policies.
• Do not engage in illegal arrangements that may damage competition, e.g. by dividing markets with competitors.
• Never disclose or exchange competitive material or engage in discussions that could be perceived as an attempt to illegally
coordinate competitive behaviour.
• Do not disclose to competitors any commercially sensitive information about pricing, discounts, bonuses, sales terms orsimilar.
• Bid for contracts and tenders independently from and without any agreements or arrangements with competitors.
• If Demant holds a leading market position, never act in a way that could be perceived to abuse this position (e.g. by selling
products or services below cost or by charging excessive prices).
• During any investigation by the competition authorities, follow the advice given by Group Legal & Compliance and neverattempt to destroy any evidence or documents or obstruct the investigation.

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FraudWe do not tolerate any form of fraud,
including theft, embezzlement, money
laundering or misuse of Demant’s
property.

What is expected of you?
• Use Demant funds solely for company purposes.
• All reimbursements must be accurately reported and documented.
• Do not accept or authorise payments without the correct underlying documentation or invoice.
• Keep accurate records of all transactions.
• Refuse cash payments or cheques issued by an unknown third party.

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Data Privacy
Demant is entrusted with personal data on
our employees, customers, users andbusiness partners, and we are committed
to protecting such personal data throughhigh-level security measures andresponsible policies. All collection andprocessing of personal data must be inaccordance with laws and regulations.
This includes GDPR (EU/EEA) and CCPA &HIPAA, etc (US).
Failure to comply with the rules may not
only have serious consequences for the
persons whose data we possess,but may also result in large fines for
Demant (up to 4 % of Group revenue), if
the rules are violated.

What is expected of you?
• Personal data and other legally protected categories of data must be treated responsibly, and all applicable data protection
laws and regulations as well as our internal IT Security Policy must be adhered to.
• Respect the purpose of the data: Consider the original purpose of the collection of the data and do not use it for otherpurposes without consulting your local privacy expert.
• Never keep personal data longer than necessary.
• Ensure that only authorised people have access to data on a need-to-know basis.
• Treat data in a safe manner: From collection, processing, storing, sharing to finally disposing of it.
• Immediately report any suspected data breaches by following the Data Breach Response
Procedure.

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Human Rights
Demant is committed to internationallyrecognised human rights standards,
relevant laws and regulations aimed at
protecting and promoting human rights
globally and at work. Wherever we
operate, we strive to meet or exceed local
human rights standards. Should national
legislation and international human rights
principles conflict, we adhere to the higher
standard.

What is expected of you?
• Do your utmost to never discriminate based on gender, ethnic origin, race,
religion, age or sexual orientation.
• Adhere to laws and regulations relating to labour conditions, ensure that
employees and other workers are compensated fairly and ensure a goodworking environment.
• Participate in the development of a culture that supports and respects
human rights.

Demant - Code of Conduct 2022

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Environment
Demant is committed to complying with allenvironmental rules and regulations. We
use materials efficiently and strive to
reduce waste in our entire supply chain.
We work to increase the amount ofsustainable materials in our operations
and production. We limit the use ofhazardous substances in products andprocesses. We monitor, evaluate and aim
to reduce our overall climate impact,
including, but not limited, to our energy
consumption and CO2 emissions.

What is expected of you?
• Ensure the efficient use of Demant resources and contribute to energy saving
and efficiency objectives, including the reduction of water consumption,
natural resources consumption and waste.
• Work continuously towards making the smallest possible detrimental impact
on the environment and the workplace.
• Encourage our business partners to act in an environmentally conscious way
and to comply with environmental laws and regulations.

Demant - Code of Conduct 2022

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Workplace Environment
We see it as our duty to take good care of
our employees by ensuring that our
workplaces are operated in a safe andsound manner. We encourage genderequality and respect for diversity, and we
strive to treat all employees fairly andequally. Demant respects freedom of
association and the right to collective
bargaining. Demant will not accept any
form of slavery or human trafficking, use ofcompulsory labour or the employment ofchildren. Demant is committed torespecting employee privacy.

What is expected of you?
• Do not discriminate or harass, including sexual harassment.
• Treat colleagues with respect and fairness.
• Act if you witness health or safety issues at work or if you experience or witness psychologicalhealth issues for you or your colleagues.

Demant - Code of Conduct 2022

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Business Partner Relations
Demant is committed to responsible
sourcing and collaboration with third
parties. We expect business partners
to adhere to all applicable laws,
regulations and our Demant Third Party
Compliance Code.
Customer complaints are addressed
effectively.

What is expected of you?
• Your interactions with business partners must be transparent.
• When selecting suppliers and vendors, do not let your decisions be influenced by gifts,
favours or entertainment that can amount to bribes and kickbacks.
• Ensure that adequate due diligence is conducted in relation to third parties prior to engaging
with them.

Demant - Code of Conduct 2022

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Export Controls
and Sanctions
In many countries, governments haveestablished domestic controls to restrict
the access to items needed for
manufacture of weapons of mass
destruction as well as sanctions to prevent
financing of terrorism and illegal activities.
Such controls may include the requirement
to obtain an authorisation for the export ofitems that can be used for both civil andmilitary purposes.

What is expected of you if you work in Demant functions that deal with sanctioned countries?
• Familiarise yourself with our processes and policies on export controls and sanctions. If in doubt, contact your local legal
advisor or Group Legal & Compliance.
• Always check if the exported goods in question are subject to export control regulations.

Demant must always observe and respectapplicable laws, regulations and internal
procedures relating to export bans, export
restrictions and financial sanctions on
specific countries, persons, entities or
sectors.

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Raise Concern
Concern may be raised through local
channels, e.g. your manager, HR, yourlocal legal advisor, Group Legal &Compliance or by using our whistleblower
hotline.
The whistleblower hotline is global andcan be used in different languages. File areport online through the hotline on
www.demant.com, via Inside or directly
via an app on your mobile device. In theUS, a report may also be filed via phone.

We encourage our employees to raise their concerns on serious and sensitive improper
actions that:• fail to comply with this Code of Conduct,• fail to comply with applicable laws and regulations, and/or• affect the health and safety of employees,
if such actions are relevant for the Demant Group or any individual country.

The system guarantees confidentiality
and anonymity. All data provided will be
subject to data privacy regulations.
Demant will ensure that there will be nodiscriminatory or retaliatory actions
against employees who file a complaint
with or raise concern to the company ingood faith.
For more information, please consult our
Demant Group Wistleblower Policy.

Download our compliance app for iOS
and Android for further information andreporting.

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Definitions usedin the Code of Conduct
Bribery
Bribery is an offer of any gift, loan, fee,
reward or other advantage to or fromany person as an inducement to dosomething which is dishonest, illegal
or a breach of trust in the conduct of
the company’s business.
Conflict of Interest
Conflict of interest typically occurs
when the personal activities of
employees, members of their families
or friends clash with the interestsof the company and thus impair theemployee’s ability to make unbiased,
arm’s length decisions on behalf of thecompany.
Corruption
Corruption is the abuse of entrusted
power for private gain.

Facilitation Payment
Facilitation payment (sometimes also
called “grease money”) usually refers
to situations where a small sum ofmoney is offered to lower-level public
officials to secure or expedite theperformance of a routine governmental action (such as processing
paperwork for visas, permits,
certificates or licences, loading or
unloading cargo, mail delivery,
releasing goods held in customs or
obtaining utility services, water or
power).
Fraud
Fraud is the deliberate deception
intended to secure financial or
personal gain or to deprive anotherindividual or party of their valuables.
Hospitality
Hospitality means any payment of
lodging and accommodation,transport and travel associated with abusiness conference, meeting or eventor tickets to social events, including
sports events, shows, concerts andsimilar entertainment.

Gifts
Gifts means any payment, present or
pecuniary advantage offered,promised, given or received to obtain
an undue business advantage, e.g.
wine, food baskets, gift cards,
memberships, discounts, cash etc.
Third Party
Any individual or legal entity withwhom the Demant Group collaborates
or who acts on behalf of Demant,
including, without limitation, suppliers,
distributors, contractors,
manufacturers, vendors, consultants,
customers, agents, business partners,
public and private hospitals,
universities and institutions as well as
non-governmental organisations.

Public Official
Public Official means:a.
Any appointed officer or any director
i. at any level of national, regional or
local government (e.g. employees ofcustoms and immigration
authorities),
ii. with any entity owned, managed
or otherwise controlled by any
government or political party,iii. with any public internationalorganisation, such as the United
Nations or the European Union,
including any department or agency
thereof, andb.
any candidate or officer employed bya political party.

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