Code of ethics

Our code of ethics guides us in how we should act to be a good employer and a long-term attractive and credible business partner.

We have chosen to establish our own code of ethics to meet the requirements of the market, strengthen the internal culture, enable good risk management, strengthen our brand and thereby increase our ability to do business with high standards.

Our mission is to help our customers to be successful. We achieve this by creating long-term relationships based on flexible production, high quality and delivery precision, high security and good availability of products and technical support.

At the same time want to maintain a high level of ethical standards. It is the responsibility of all employees to comply with this code of ethics as well as the applicable legislation. And all employees have a responsibility to ensure that they are familiar with all applicable laws and practice.

OUR CODE OF ETHICS

1. CONDUCT

Stena Aluminium shall support and respect international agreements on human rights.
Stena Aluminium conducts business in compliance with good business practice.
Stena Aluminium acts in such a way as not to damage the reputation of the company.
Stena Aluminium shall keep proper accounts.
Stena Aluminium shall not participate in fiscal or environmental crimes.

2. BRIBES
Stena Aluminium must not - directly or indirectly - offer, promise, request, demand or accept bribes or other undue advantages in order to retain a customer, secure a transaction or to influence an official decision or action. We shall have and apply clear rules regarding gifts, services, entertainment or other benefits of excessive value and that could be considered to be a bribe or return of a favor, or that could cause difficulties for the company or the employee if they become publicly known.

3. ANTITRUST AND COMPETITION LAWS
Stena Aluminium shall comply fully and in a positive spirit with all antitrust and competition laws and regulations in force in those countries where Stena Aluminium operates.

4. TREATMENT OF EMPLOYEES

Stena Aluminium works actively to promote a positive working environment by reducing sick leave, work accidents, RSI and drug abuse, among other things.
Stena Aluminium has connections to occupational health services.
Violence, threats, threatening behavior, harassment, insults and similar are not tolerated in the workplace.
Stena Aluminium shall guarantee fair employment conditions and opportunities (based on local conditions) for all persons, without distinction or discrimination on grounds of gender, transgender identity or expression, sexual orientation, ethnicity, age, disability, religion or other belief.
Stena Aluminium respects the rights of employees to form and join the trade unions they wish and to negotiate collectively.
Stena Aluminium does not accept any form of political, religious or other propaganda-like activities in the workplace.

5. TREATMENT OF CUSTOMERS

Engaging Stena Aluminium is a guarantee of quality for the customer.
Stena Aluminium strives to create value for its customers by offering competitive products and services on the national and international markets.
Stena Aluminium shall provide its customers with information about the code of ethics.

6. TREATMENT OF OTHER STAKEHOLDERS

Stena Aluminium expects to make the same high demands on suppliers, subcontractors and partners on their own activities as on its own operations.
When Stena Aluminium evaluates and selects suppliers, subcontractors and partners, the ability to meet the requirements of the code of ethics shall be a key selection criterion. Procedures for such evaluation are available in the management system.

7. IMPORT FROM/EXPORT TO DEVELOPING COUNTRIES
Stena Aluminium takes responsibility for conducting exports and imports in a responsible manner.
7.1 Forced labor and child labor
Stena Aluminium shall always act to ensure that:

working hours and working conditions of the recipient comply with the statutory requirements
the recipient's employees are treated with respect and are not subjected to corporal punishment or force of any kind
Stena Aluminium does not buy products or services that are directly or indirectly produced by child labor and avoids doing business with companies in breach of ILO guidelines for children and youth work.

8. ENVIRONMENT

In 1997, Stena Aluminium introduced an environmental management system that has been certified in accordance with ISO 14001.
Since 2001, Stena Aluminium has also introduced a work environment management system that has been certified according to AFS.
Stena Aluminium has an environmental policy.
Stena Aluminium has a clear distribution of responsibilities for environment and working environment issues, with representatives included in the senior management.
Stena Aluminium shall observe points A and B when designing the environmental objectives.

A. Stena Aluminium shall produce aluminium alloys by recycling with the least possible impact on the environment and comply with the requirements specified in REACH and other environmental legislation where we have production facilities.

B. In its activities, Stena Aluminium shall encourage its supplier's to inform Stena Aluminium whether the substances below are contained in the material included the products. Stena Aluminium shall also work to ensure that these substances can be identified, separated and disposed of correctly:

substances produced by man and that are organic, persistent and bioaccumulative
substances produced by man and that are carcinogenic, mutagenic and endocrine disruptive, including toxic to reproduction
mercury
cadmium

9. PLAN FOR ENERGY EFFICIENCY
Stena Aluminium has drawn up an action plan to measure the company's energy consumption and to make it more efficient. The aim is to reduce the consumption of non-renewable energy and greenhouse gas emissions per tonne-kilometers.

10. MEASURES IN THE EVENT OF DEVIATIONS FROM THE CODE OF ETHICS

Notification of conduct that deviates from the code of ethics within Stena Aluminium shall be submitted to the immediate manager or the personnel department in Stena Metall.
All notifications shall be taken seriously and examined.
There must be no retaliation of any kind for the notification of deviations from the code of ethics or for participating in the investigation of a complaint.

11. MONITORING AND REPORTING

We will monitor compliance with the Code of ethics once a year.
The monitoring will be done in the form of a written report.
All employees of the Stena Aluminium shall confirm that they have completely understood the contents of the code of ethics and its practical importance, and that they will also cooperate in monitoring compliance with the code or any deviations from it.
An introduction to the code of ethics is a natural part of our induction of new employees.
The guidelines in the code of ethics shall be incorporated into Stena Aluminium no later than two years from the adoption of the code.

Älmhult, October 2013

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