This Code sets forth the basic standards of ethical and responsible business conduct that must be followed by both management and employees in our daily work at WIP Industries Romania. The standards are based on values that are critical to our success. These principles are not intended to be exhaustive, but to address the essential areas, and to serve as guidance in daily work.

1 Responsibility

We have a responsibility towards our clients, employees, the environment, and resources. We act lawfully, we respect each other, and we value honesty and transparency.

Liability for the company's property

Liability for the company's property means that we, as employees, should manage the company's resources with care. We are responsible for WIP Industries Romania's property. We must report risk of losses or possible losses to management. All property is returned to WIP Industries Romania in the event of termination of employment.

Confidential and sensitive information

It is important that all information about WIP Industries Romania, its employees and customers is handled with care and with confidentiality.

All written agreements concluded by the company are archived. Other business and transactions related documents are saved. Special care should be taken on documents that may have an impact on future litigation, audits or other investigations.

External activities

Do not engage in external assignments that may create loss for the company or are in conflict with the company's interests. WIP Industries Romania employees are not allowed to engage in political or religious activities that may in any way harm the company's operations or reputation. It is important to obtain approval from the Managing director before taking up assignments as a board member of an external company.

Caring for the environment

We work in accordance with environmental laws and regulations in the country (countries) in which we operate. We - as company and individual employees, should strive to reduce our environmental impact and use natural resources wisely.

We discuss openly with authorities, suppliers and customers how we, in our cooperation with them, can improve our processes for protecting the environment.

We work to increase resource efficiency by reducing the consumption of energy and raw materials in our production and by finding ways to increase the recycling of materials.

Respect for the law and fair business

We prohibit all actions which might breach applicable norms of law. We also reject all forms of active or passive corruption whether in domestic or international transactions. We support free and fair competition. We do our very best to always outperform our competitors in honest way.

We treat our customers with respect and honesty. We are open and truthful in our business relationships.

Our business relationships are based on objective criteria, which means that we may not offer, issue, request or receive gifts, payments, entertainment or services, to or from existing or potential partners, that might be aimed to affect business transactions and that exceed normal hospitality standards.

Marketing, sales and sponsorship

Marketing, sales and sponsorship activities shall not be discriminatory or be part of any political or religious context. WIP Industries Romania refrains from any form of financing political parties or activities, even if allowed under local law. WIP Industries Romania is neutral in political preferences. We do not make financial contributions to political parties or individual politicians.

WIP Industries Romania also takes a neutral position on matters of faith. We do not make financial contributions to faith communities or religious representatives. Employees cannot receive paid leave for political or religious commitments.

2 Togetherness

As a team we pull in the same direction. Our “we mentality” requires effective, two-way communication to help each other grow, solve problems and share in the success. We care for colleagues and community.

Respect for others

Respect for others is an absolute prerequisite for the professional and personal development of each person. It implies an acceptance of pluralism and other cultures and of people of all origins. It is expressed in a readiness to listen to others, to inform, to explain, and to engage in dialogue.

Solidarity

Solidarity is based on a sense of individual responsibility at work, which prevails over self-centered thinking. It encourages team work and bringing out the best in each person, in order to achieve the objectives of the company.

Responsibility and engagement in society and community

Responsibility and engagement in society and community is our fundamental principle. We, as company and individual employees, should engage and contribute positively to development in the communities we operate.

Sponsorship

Sponsorship and other financial contributions in the places where WIP Industries Romania operates should support culture, sport, education or other social activities.

3 Dedication

Dedication requires a willingness to learn and a resilience to overcome obstacles, as well as a commitment to provide work of the highest quality.

Loyalty

Loyalty requires honesty and fairness in dealing with superiors, colleagues, subordinates and third parties dealing with the company. It implies the adherence to the guidelines and internal rules of the company or department.

Integrity

Integrity is the quality of being honest and having strong moral principles in all professional activities. It means that no individual may compromise the interests of the company entrusted to that individual in favour of his or her own private interests – whether in dealing within the company or in dealing on behalf of the company with third parties.

4 Drive

We welcome new challenges, which makes us grow and develop; as individuals and as company. We pride ourselves on our flexibility, adaptability, courage and innovation.

Professional commitment

Professional commitment means mobilising to the best of one’s ability, the knowledge and know-how of the individual and also calls for training to keep both up to date. It requires personal commitment and a willingness to take on the tasks assigned and to acquire knowledge necessary to do the job. It implies the effective contribution of each person in caring particularly for the environment and for worker health and safety.

We will ensure that employees have the necessary knowledge to be able to take responsibility in their daily work and involve them in the process of continuous improvement.

All employees are responsible for their own professional skills and competences and that these are kept up to date.

5 Common sense

Common sense means simplicity, to stay humble and to remember our roots.

Employees understand their roles

We will ensure that all employees understand their roles, what is expected of them and what responsibilities they have – and we all take responsibility for informing ourselves about the issues related to our own work situation, what is expected of us and also things related to the department and the company.

Laws, regulations and industry rules

We shall comply with laws, regulations and industry rules in the market in which we operate. Each employee is responsible for seeking appropriate advice for relevant legal requirements and other legal issues.

WIP Industries Romania does not accept employment in another business without the special consent of the nearest manager.

Our fundamental principle

Our fundamental principle is that we, as company and individual employees, should engage in business-supporting activities in a fair and honest manner.

The computers should not be used for unethical purposes. All material produced on or shipped from WIP Industries Romania's computers is considered WIP Industries Romania's property.

We strive for simplicity, clarity of information and in the execution of tasks. We must be cost conscious in designing solutions. We respect decisions and internal regulations and we are free to submit questions, comments or improvement ideas.

Conflicts of interest

Conflicts of interest - is considered to arise when an employee's personal, social, financial, political or religious activities can potentially interfere with the employee's loyalty or objectivity with respect to the company. Employees should avoid any situation involving a potential conflict of interest.

6 People

Our inclusive culture promotes our values and encourages everyone to contribute and have a voice, focusing on the positive. We champion Equality and Diversity and have zero tolerance for any form of discrimination.

Responsibility for employees

We, as company and individual employees, should comply with the UN Universal Declaration of Human Rights. We work in accordance with the labour law and regulations that apply in our country and in other countries if applicable.

Employee rights

We must scrupulously ensure that employees’ rights are respected. We promote an active dialogue with our employees. We refrain from any form of recourse to forced labour, compulsory labour, or child labour – whether directly or indirectly or through subcontractors; When installing relations with new suppliers in the value chain, we always verify their approach to child labour and compliance with IWAY and sign a "Self declaration" on this topic. The procurement also ensures that we have the right to conduct an IWAY audit with the supplier.

WIP Industries Romania shall comply with applicable laws and collective agreements, such as pay and working hours, which are expected of us as an employer. Inconsequential pay must not occur.

Freedom of association

We shall respect the right of all employees to exercise their legal rights to form, join or refrain from joining recognised trade unions.

Diversity

We shall guarantee the same conditions of employment and opportunities for qualified persons, without distinction or discrimination on grounds of sex, age, nationality, ethnicity, religion or nationality.

Harassment and bullying is not tolerated, either face to face or in written, electronic or verbal form. We treat each other with respect and dignity.

No employee shall be subjected to corporal punishment or physical, sexual, psychological or verbal harassment or abuse. We will strive for a work environment where everyone is treated equally and where diversity is valued.

Worker health and safety

WIP Industries Romania adopts all measures necessary to ensure the best possible protection against health and safety risks in the workplace. We will ensure that our employees have the necessary knowledge to be able to work safely in their daily work in WIP Industries Romania. It is prohibited to distribute, possess or use drugs and alcohol at our workplace.

We are responsible for protecting ourselves, our colleagues, the workplace, society and the environment by reporting any unacceptable health or safety conditions, taking protective measures and minimizing any damage. We will work for continuous improvements in health and safety at work