SUPPLIER CODE OF CONDUCT

1. Introduction

Uponor’s top tier offering, including safe drinking water delivery, energy-efficient radiant heating and cooling and reliable infrastructure, enables a more sustainable living environment. Uponor’s purpose, strategy and values shall be reflected in everything that Uponor does. By applying principles of sustainable sourcing, Uponor procures goods and services with high ethical standards by focusing on achieving the best value through a transparent, fair and competitive process with high economic and environmental considerations. Therefore, Uponor’s Procurement Mission Statement of creating and sustaining competitive advantages through innovative supply chain strategies supporting Uponor’s needs while building long-term partnerships with suppliers shall be reflected in all of Uponor’s sourcing activities.

All Uponor suppliers are anticipated to closely cooperate with Uponor, to consider Uponor as one of the preferred customers and to support Uponor to fulfil its purpose, strategy and values. Uponor has high expectations for its suppliers and for building a good working relationship with them. The suppliers are to adhere to the agreed contractual terms and conditions and to duly report should any exceptions appear. Uponor’s promises to its customers are subject to the information and input it receives from its suppliers and that is why it is of utmost importance that the suppliers are committed to this collaboration.

“Uponor” refers to Uponor Corporation and any or all of its affiliated legal entities, as the case may be.

Information in this document is subject to changes by Uponor any time without notice. The most recent and updated version is available on Uponor Group’s website. Thus copies of this Supplier Code of Conduct are considered uncontrolled and not automatically updated.

2. General requirements

Uponor expects its suppliers, their employees, directors, contractors, sub-suppliers and suppliers (any and all hereinafter referred to as “supplier(s)”) to not only comply with all applicable laws and regulations, including but not limited to International Conventions, regulations and decisions of the relevant authorities and organisations (such as the UN and EU in the context of e.g. trade compliance) but also with this Supplier Code of Conduct. The suppliers are responsible for demonstrating their compliance with the requirements set forth in this Supplier Code of Conduct, or, in their own equivalent Code of Conduct.

In case of differences or discrepancies between the requirements of laws and regulations and this Supplier Code of Conduct, or, between the supplier’s own Code of Conduct and this Supplier Code of Conduct, the supplier must adhere to whatever is stricter.

3. Ethical business practices

Uponor expects all of its suppliers to comply with ethical business practices.

Suppliers are not allowed to participate in or support any form of corruption or bribery. This includes also paying, asking, accepting or mediating bribes, facilitation payments or alike. Similarly, suppliers shall avoid providing, asking, accepting or mediating excessive business entertainment, gifts or invitations. Any hospitality should be moderate and in direct connection with a business event and purpose. Suppliers shall also prevent any sort of conflict of interest situations for their part and act responsibly especially as far as dealing with public officials or governmental bodies are concerned.

Suppliers are not allowed to be involved in any form of money laundering or financing of illegal activities. Suppliers shall participate in all offering processes and negotiations with ethical manners. They shall compete fairly, act in compliance with applicable antitrust and competition laws and refuse to enter into discussions or agreements with competitors concerning pricing, market division or similar forbidden or suspicious activities.

Suppliers shall protect individual privacy by complying with relevant data privacy and security regulations. They shall also protect any confidential and sensitive information with adequate measures and irrespective of the owner or discloser of that information. Should Uponor’s assets be under supplier’s custody or control, supplier shall protect those with adequate measures.

4. Human and labour rights

Uponor expects its suppliers to respect internationally recognized human rights set forth in the International Bill of Human Rights. Suppliers must strive to avoid causing or contributing to adverse human rights impacts through their own activities and seek to prevent or mitigate adverse human rights impacts linked to their operations through business relationships. Uponor expects its suppliers to support and promote diversity, equity and inclusion in all of their operations. Suppliers shall provide equal opportunities to all of their employees and commit to not to discriminate against anyone based on race, age, gender, religion, disability, sexual orientation, marital or parental status, union membership, political beliefs or any other such features. Suppliers are not to allow any form of physical punishment or physical, sexual, psychological or verbal harassment or abuse.

Uponor expects its suppliers not to employ workers or other personnel below 15 years of age or the national legal minimum age, whichever is higher. Suppliers need to ensure that employment of young persons above the minimum age but below 18 years does not interfere with their education, health, safety and morals.

Suppliers shall not use or benefit from forced labour in any form and they shall not retain passports or other documents of employees. Suppliers shall recognise the employees’ right to be organised, form and join a trade union or bargain collectively.
Suppliers shall pay at least the minimum wage required by national laws for regular working hours and overtime. They shall apply normal working hours that comply with applicable laws and collective agreements.

5. Occupational health and safety

Uponor is striving towards zero accidents and expects its suppliers to provide a safe, healthy and secure working environment for all of their employees, sub-contractors and stakeholders under their supervision.

Uponor expects its suppliers to assign responsibility and allocate appropriate resources for health and safety in their respective organisations. A documented system for health and safety management needs to be in place and kept up-to-date. This responsibility includes a documented system that is kept up-to-date and drives continuous improvement in the issues related to health and safety, including having a process to identify and evaluate work-related hazards and risks, as well as appropriate controls, work procedures and plans to prevent workplace hazards and accidents. The suppliers shall monitor and keep a record of health and safety performance as well as report and investigate health and safety incidents. These records shall be shared with Uponor upon request. The suppliers shall provide their employees with appropriate health and safety training and protective equipment as needed. Suppliers are encouraged to implement a health and safety management system in accordance with the ISO 45001 standard.

6. Environmental protection

Uponor expects its suppliers to have all valid environmental permits required by law and to work to prevent any environmental incidents. The suppliers shall use resources efficiently and minimise any adverse impact on the environment. They shall assign responsibility and allocate appropriate resources for environmental management in their respective organisations. This responsibility includes a documented system for environmental management that is kept up-to-date and drives continuous improvement, including a process to identify and evaluate environmental impacts (such as air emissions, energy use, water use, water effluents, land use change, biodiversity and waste) as well as operational controls, procedures and plans to prevent pollution and minimise environmental impacts. The suppliers shall monitor and keep records of environmental performance and strive to continuously reduce environmental impacts. These records shall be shared with Uponor upon request. The suppliers are encouraged to implement an environmental management system in accordance with the ISO 14001 standard.

To support Uponor’s commitment to reduce greenhouse gas emissions aligned with science-based targets in its entire value chain, the suppliers shall monitor, report and aim to reduce greenhouse gas emissions from their own operations and value chains. Uponor encourages its suppliers to set science-based greenhouse gas emission reduction targets and register these through the Science Based Targets Initiative. The suppliers are also encouraged to implement an energy management system in accordance with ISO 50001 standard.

In addition, to support Uponor’s other sustainability targets, the suppliers are encouraged to promote circularity in their operations and product offering, reduce their water consumption, water risks and impact on water quality, as well as to strive to understand their businesses impact on biodiversity and to consequently minimise any adverse impacts and maximise positive impacts.

7. Product quality, safety and transparency

Uponor expects its suppliers to provide quality products that meet all applicable requirements on product safety and environmental performance. The suppliers are encouraged to implement a quality management system in accordance with the ISO 9001 standard.

Uponor is committed to establish and maintain full transparency regarding the environmental performance of its products. In order to support this, Uponor expects its suppliers to be aware of and be able to report on the origin, composition and environmental performance characteristics of materials used in products supplied to Uponor. Uponor recommends its suppliers to develop and provide Life Cycle Impact Assessment datasets in accordance with the ISO 14040 series of standards, or Environmental Product Declarations in accordance with EN 15804. If such productspecific datasets are not available, Uponor expects its suppliers to actively support Uponor’s product transparency efforts by collecting and providing environmental performance data related to their operations.

The suppliers shall ensure product safety by complying with all relevant regulatory requirements and restrictions applicable in the region to which the products are being supplied, such as but not limited to

• the European Union’s RoHS directive (Restriction of the uses of certain Hazardous Substances), REACH regulation (Registration, Evaluation, Authorization and Restriction of Chemicals)
• Waste Framework Directive including the information requirements defined for the SCIP database (Substances of Concern in Articles as such or Complex Objects)
• the California Safe Drinking Water and Toxic Enforcement Act of 1986, commonly known as Proposition 65, codified at Cal. Health & Saf. Code §§ 25249.5–.13

Suppliers shall ensure that all necessary declarations and other documentation required by all applicable regulations are available to Uponor. Suppliers shall inform in writing of any and all products which are not in conformity with such relevant regulations or restrictions, and comply with any relevant requirements for marking or labelling products which are not in conformity with such requirements.

The suppliers shall commit to not to purchase any materials from illegal sources. They shall work proactively to prevent the use of Conflict Minerals in their products. This applies in particular to tin, tantalum, tungsten and gold sourced from countries which are either suffering from armed-conflict, such as civil war, a state of fragile post-conflict, or witnessing weak or non-existing governance and systematic violations of international law, including human rights abuses.

8. Monitoring and enforcement

By committing to this Supplier Code of Conduct, the supplier permits Uponor to verify compliance with the requirements of this Supplier Code of Conduct through information requests and questionnaires. Suppliers are expected to address such requests without delay. Suppliers also allow Uponor or an authorised third-party to conduct audits of the Suppliers’ operations, facilities and data with regards to the topics set forth in this Supplier Code of Conduct.

The supplier permits Uponor to require corrective actions in cases of non-compliance with the requirements of the Supplier Code of Conduct.

Uponor reserves the right to terminate its agreement with the supplier at its sole discretion and without a penalty if all corrective actions are not taken by the request of Uponor, or, in case of further non-compliances.

Violations or concerns regarding a supplier’s behaviour or operations must be reported to Uponor contact person. In sensitive cases, Uponor has an external whistleblowing reporting channel, which anyone can use in their own name, or, anonymously and confidentially. The whistleblowing service is provided by an external partner to secure anonymity. The communication channel is encrypted and password-protected. All messages will be processed in confidence. The service can be accessed via https://report.whistleb.com/en/uponor or Uponor Group’s website.