Code of Conduct

CODE OF CONDUCT

INTRODUCTION:

Hydrema is committed to carrying out its business in a sustainable way. In order to promote the longterm interests of Hydrema and its stakeholders, the company strives to maintain the highest legal and ethical standards in all its business practices. Each employee is expected to act responsibly and with integrity and honesty, and to comply with this code and its underlying policies and instructions.

CONFLICTS OF INTEREST:

Hydrema expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of Hydrema. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation.

OPENNESS:

Hydrema promotes openness and transparency, as well as continuous dialogue with its stakeholders, including customers and other business partners, shareholders, personnel, authorities, local communities and the media. Stock exchange rules and competitive considerations may, however, in some cases restrict such openness and transparency. Hydrema strives to be honest and accurate when communicating with its stakeholders, and Hydrema employees shall make their statements in accordance with this principle.

RESPECT FOR HUMAN AND LABOR RIGHTS:

Hydrema supports and respects the protection of human rights as defined in the United Nation’s Universal Declaration on Human Rights. No employee is allowed to take any action that violates these human rights principles, either directly or indirectly. Hydrema supports basic labor rights as defined by the International Labor Organization. In this respect, Hydrema upholds the freedom of association and the effective recognition of the right to collective bargaining. In the case that these rights are restricted by local law, Hydrema endeavors to offer its employees alternative means to present their views. Hydrema does not accept any form of forced or compulsory labor, or the use of child labor.

FAIR EMPLOYMENT PRACTICES:

Hydrema promotes freedom from discrimination based on race, ethnic or national origin, color, gender, family status, sexual orientation, creed, disability, age or political beliefs, or other characteristics protected by law. Hydrema fosters equal opportunity and employees are selected and treated on the basis of their competencies, abilities and merits. Hydrema does not support any form of discrimination, harassment or bullying from its employees.

OCCUPATIONAL HEALTH AND SAFETY:

Hydrema endeavors to create hazard-free workplaces for its employees, contractors, and others working in various locations by applying high standards of occupational health and safety. Hydrema strives to assure the safety of its products and solutions through its world-class product and solution development processes. Each employee is responsible for complying with the safety instructions, for using personal protection equipment when required, and for reporting on any shortcomings regarding safety instructions or protection measures.

CONFLICTS OF INTEREST:

Hydrema expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of Hydrema. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation.

ANTI-CORRUPTION:

No Hydrema company or any of its employees may, directly or indirectly, promise, offer, pay, solicit, or accept bribes or kickbacks of any kind, including money, benefits, services or anything of value. Such payments and favors may be considered bribery, which violates local legislation and internationally recognized principles for combating corruption and bribery.

ENVIRONMENT:

Hydrema’s target is to develop and produce for its customers environmentally advanced solutions and services that fulfil essential requirements, such as low emissions and high efficiency. Efforts are made to achieve sustainable development by means of raw material selection, processes, products, wastes, and emissions through the use of the latest technical advances. Each employee shall comply with the policies and instructions regarding environmental protection.

RELATIONSHIP WITH AUTHORITIES AND LOCAL COMMUNITIES:

Hydrema maintains constructive co-operation with authorities and regulatory bodies, at both local and international levels. Hydrema seeks to play a role in serving the needs of the local communities whenever possible.

INNOVATION AND PROTECTION OF PROPRIETARY INFORMATION:

Hydrema supports and encourages innovation by its employees in all areas of its activities. Hydrema’s intellectual property is one of its most valuable assets and the patents, trademarks, copyrights, trade secrets, and other proprietary information of Hydrema must be protected. At the same time, each Hydrema employee must respect the intellectual property rights of others.

ACCURACY OF ACCOUNTING RECORDS:

Hydrema accounting records must be accurate and reliable in all materialrespects. Unrecorded funds are prohibited. The records cannot contain anyfalse, misleading, or artificial entries. We try to the best of our ability to live up to the accounting standards that apply to Hydrema andensure this by using independent external auditors.

COMPETITION AND FAIR DEALING:

Competition laws aim to protect consumers and businesses against unfair business practices. Each employee shall comply with those laws. Actions such as participation in cartels, abuse of a dominant position in the market place, or the exchange of price or other commercial information between competitors, are prohibited. Hydrema employees should be sensitive to competition concerns when attending occasions where competitors, or potential competitors, can be present.

ANTI-FRAUD:

Hydrema does not tolerate fraudulent behavior or activities, such as embezzlement, fraud or theft. Such violations will lead to immediate termination of employment and are subject to criminal sanctions.

IMPLEMENTATION:

Hydrema takes an active approach to the application of this code and promotes its implementation through the effective communication of its contents to its employees. Hydrema monitors the application of this code internally. Suppliers and business partners are an important and integral part of the total value chain of the products and services of Hydrema. They are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as Hydrema. Hydrema promotes the application of this code by monitoring the actions of its suppliers and business partners. In the case that questions arise regarding the interpretation of, or compliance with, this code, Hydrema Legal Affairs should be contacted. The application of the code will be reviewed from time to time by the Board of Management, which may decide on necessary revisions or interpretations.

REPORTING VIOLATIONS:

Any Hydrema employee becoming aware of a potential violation of this code must report any information through Hydrema whistleblower scheme. Hydrema will investigate all reported matters with discretion. Hydrema shall not take any adverse actions, as a result of such reporting, against any employee reporting in good faith what he or she believes to be a violation of this code.

SANCTIONS:

Violation of this code may lead to a warning, termination of employment and payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.

CONFLICTS OF INTEREST:

Hydrema expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of Hydrema. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation.

ANTI-CORRUPTION:

No Hydrema company or any of its employees may, directly or indirectly, promise, offer, pay, solicit, or accept bribes or kickbacks of any kind, including money, benefits, services or anything of value. Such payments and favors may be considered bribery, which violates local legislation and internationally recognized principles for combating corruption and bribery.

ENVIRONMENT:

Hydrema’s target is to develop and produce for its customers environmentally advanced solutions and services that fulfil essential requirements, such as low emissions and high efficiency. Efforts are made to achieve sustainable development by means of raw material selection, processes, products, wastes, and emissions through the use of the latest technical advances. Each employee shall comply with the policies and instructions regarding environmental protection.

RELATIONSHIP WITH AUTHORITIES AND LOCAL COMMUNITIES:

Hydrema maintains constructive co-operation with authorities and regulatory bodies, at both local and international levels. Hydrema seeks to play a role in serving the needs of the local communities whenever possible.

INNOVATION AND PROTECTION OF PROPRIETARY INFORMATION:

Hydrema supports and encourages innovation by its employees in all areas of its activities. Hydrema’s intellectual property is one of its most valuable assets and the patents, trademarks, copyrights, trade secrets, and other proprietary information of Hydrema must be protected. At the same time, each Hydrema employee must respect the intellectual property rights of others.

ACCURACY OF ACCOUNTING RECORDS:

Hydrema accounting records must be accurate and reliable in all materialrespects. Unrecorded funds are prohibited. The records cannot contain anyfalse, misleading, or artificial entries. We try to the best of our ability to live up to the accounting standards that apply to Hydrema andensure this by using independent external auditors.

COMPETITION AND FAIR DEALING:

Competition laws aim to protect consumers and businesses against unfair business practices. Each employee shall comply with those laws. Actions such as participation in cartels, abuse of a dominant position in the market place, or the exchange of price or other commercial information between competitors, are prohibited. Hydrema employees should be sensitive to competition concerns when attending occasions where competitors, or potential competitors, can be present.

ANTI-FRAUD:

Hydrema does not tolerate fraudulent behavior or activities, such as embezzlement, fraud or theft. Such violations will lead to immediate termination of employment and are subject to criminal sanctions.

IMPLEMENTATION:

Hydrema takes an active approach to the application of this code and promotes its implementation through the effective communication of its contents to its employees. Hydrema monitors the application of this code internally. Suppliers and business partners are an important and integral part of the total value chain of the products and services of Hydrema. They are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as Hydrema. Hydrema promotes the application of this code by monitoring the actions of its suppliers and business partners. In the case that questions arise regarding the interpretation of, or compliance with, this code, Hydrema Legal Affairs should be contacted. The application of the code will be reviewed from time to time by the Board of Management, which may decide on necessary revisions or interpretations.

REPORTING VIOLATIONS:

Any Hydrema employee becoming aware of a potential violation of this code must report any information through Hydrema whistleblower scheme. Hydrema will investigate all reported matters with discretion. Hydrema shall not take any adverse actions, as a result of such reporting, against any employee reporting in good faith what he or she believes to be a violation of this code.

SANCTIONS:

Violation of this code may lead to a warning, termination of employment and payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.

Jan Werner Jensen

ADM. Direktør / Managing Director

CONFLICTS OF INTEREST:

Hydrema expects full loyalty from its employees. Employees must avoid situations where their personal interests may conflict with those of Hydrema. This means, for instance, that employees are not allowed to accept gifts or entertainment from a stakeholder, except for a gift or entertainment of a minor value given on an occasional basis, providing it does not create a conflict of interest situation.

ANTI-CORRUPTION:

No Hydrema company or any of its employees may, directly or indirectly, promise, offer, pay, solicit, or accept bribes or kickbacks of any kind, including money, benefits, services or anything of value. Such payments and favors may be considered bribery, which violates local legislation and internationally recognized principles for combating corruption and bribery.

ENVIRONMENT:

Hydrema’s target is to develop and produce for its customers environmentally advanced solutions and services that fulfil essential requirements, such as low emissions and high efficiency. Efforts are made to achieve sustainable development by means of raw material selection, processes, products, wastes, and emissions through the use of the latest technical advances. Each employee shall comply with the policies and instructions regarding environmental protection.

RELATIONSHIP WITH AUTHORITIES AND LOCAL COMMUNITIES:

Hydrema maintains constructive co-operation with authorities and regulatory bodies, at both local and international levels. Hydrema seeks to play a role in serving the needs of the local communities whenever possible.

INNOVATION AND PROTECTION OF PROPRIETARY INFORMATION:

Hydrema supports and encourages innovation by its employees in all areas of its activities. Hydrema’s intellectual property is one of its most valuable assets and the patents, trademarks, copyrights, trade secrets, and other proprietary information of Hydrema must be protected. At the same time, each Hydrema employee must respect the intellectual property rights of others.

ACCURACY OF ACCOUNTING RECORDS:

Hydrema accounting records must be accurate and reliable in all materialrespects. Unrecorded funds are prohibited. The records cannot contain anyfalse, misleading, or artificial entries. We try to the best of our ability to live up to the accounting standards that apply to Hydrema andensure this by using independent external auditors.

COMPETITION AND FAIR DEALING:

Competition laws aim to protect consumers and businesses against unfair business practices. Each employee shall comply with those laws. Actions such as participation in cartels, abuse of a dominant position in the market place, or the exchange of price or other commercial information between competitors, are prohibited. Hydrema employees should be sensitive to competition concerns when attending occasions where competitors, or potential competitors, can be present.

ANTI-FRAUD:

Hydrema does not tolerate fraudulent behavior or activities, such as embezzlement, fraud or theft. Such violations will lead to immediate termination of employment and are subject to criminal sanctions.

IMPLEMENTATION:

Hydrema takes an active approach to the application of this code and promotes its implementation through the effective communication of its contents to its employees. Hydrema monitors the application of this code internally. Suppliers and business partners are an important and integral part of the total value chain of the products and services of Hydrema. They are expected to conduct their businesses in compliance with the same high legal and ethical standards and business practices as Hydrema. Hydrema promotes the application of this code by monitoring the actions of its suppliers and business partners. In the case that questions arise regarding the interpretation of, or compliance with, this code, Hydrema Legal Affairs should be contacted. The application of the code will be reviewed from time to time by the Board of Management, which may decide on necessary revisions or interpretations.

REPORTING VIOLATIONS:

Any Hydrema employee becoming aware of a potential violation of this code must report any information through Hydrema whistleblower scheme. Hydrema will investigate all reported matters with discretion. Hydrema shall not take any adverse actions, as a result of such reporting, against any employee reporting in good faith what he or she believes to be a violation of this code.

SANCTIONS:

Violation of this code may lead to a warning, termination of employment and payment of damages. Additionally, certain violations of a criminal nature can lead to criminal sanctions, such as fines or imprisonment.

Jan Werner Jensen

ADM. Direktør / Managing Director