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Compliance

Compliance

OBO-Code of Conduct for Corporate Social Responsibility

Preamble

We, OBO Bettermann, affirm our Corporate Social Responsibility as a part of our global business activities (internationally known as "Corporate Social Responsibility")."OBO's Code of Conduct for Corporate Social Responsibility" (hereinafter called "CoC") acts as a guideline especially regarding working conditions, social and environmental compatibility, transparency, collaboration and dialog that is marked by trust. The content of this CoC is an expression of our collective core values as they are defined in our concept statements and especially as they are affirmed in the social market economy.

The CoC is designed as a self-imposed obligation that assists us in responding to different general conditions in a global market and in facing challenges and social expectations that come from intensified collaboration from within the value chain.

1. Basic Understanding of Social Responsibility in Corporate Management
A mutual, basic understanding of social responsibility in corporate management forms the basis of this CoC. This means for OBO Bettermann to assume responsibility by bearing in mind the consequences of our business decisions and actions on economic, technological, social and environmental levels and to bring about an appropriate balance of interests. We voluntarily contribute to the wellbeing and long - term development of a global society at every point we can at the locations where we are in business. We are geared towards universally held ethical values and principals, especially integrity, honesty and respect of human dignity.

2. Where the CoC applies
2.1 This CoC is in effect for our entirecompany group and business units worldwide.

2.2 We commit to promoting adherence to the content of this CoC at every point we can for our suppliers and in other parts of the value chain.

3. Core Values for Social Responsibility in Corporate Management
We, OBO Bettermann, will proactively work to ensure that the values mentioned below are put into practice and adhered to both now and in the future.

3.1 Adherence to Laws
We will abide by the laws in effect and other legal requirements of the countries where we are in business. For countries that have a weak institutional framework, we will carefully examine what good company practices from our home country should be applied to enable supportive, responsible company management.

3.2 Integrity and Organizational Governance

3.2.1 We, OBO Bettermann, gear our activities towards universally held ethical values and principals, especially integrity, honesty, respect of human dignity, openness and non-discrimination based on religion, ideology, gender and ethnicity.
3.2.2 We reject corruption and bribery as stated in the relevant UN Convention (Convention against corruption in 2003, in force Since 2005) and promote transparency, trading with integrity, responsible leadership and company accountability.
3.2.3 OBO Bettermann pursues clean and recognized business practices and fair competition. In regards to competition, we are focused on professional behavior and high standards of quality for work. We, OBO Bettermann, foster partnership and trusting interaction with the supervisory authorities. Additionally, we will hold to the parameters of the "Guide for our Association Activity - Instructions for Compliance with Competition Law in the Zentralverband Elektrotechnik- und Elektronikindustrie e.V".

3.3 Consumer Interests
To the extent consumer interests are affected, we abide by regulations that protect the consumer, as well as appropriate sales, marketing and information practices. Groups that are in special need of protection (e.g. young people, seriously disabled) will receive special attention.

3.4 Communication
We, OBO Bettermann, will communicate in an open way and is oriented towards dialogue about the requirements of this CoC and about its implementation among employees, clients, suppliers and other stakeholders. Every document and all information will be duly produced. They will not be unfairly changed or destroyed. They will be properly stored. Company secrets and partner's business information will be handled sensitively and will be kept in confidence.

3.5 Human Rights
We are committed to promote human rights and respects human rights stated in the Charter of the United Nations (General explanation of human rights, UN Resolution 217 A (111) from 1948), especially those named in the following.

3.5.1 Privacy
Protection of privacy.
3.5.2 Health and Safety
Ensuring health and work safety, especially the guarantee of a safe and health-promoting work environment, avoiding accidents and injuries.
3.5.3 Harassment
Employee protection against bodiJy punishment and against physical, sexual, psychological or verbal harassment or abuse.
3.5.4 Freedom of Conscience
Protection and guarantee of the right to freedom of conscience and freedom of expression.

3.6 Working Conditions
We, OBO Bettermann, abide by the following core work standards from ILO (International Labour Organization).

3.6.1 Child Labor
The prohibition of child labor, i.e. the employment of persons younger than 15 years old, as long as the legal requirements do not specify a higher age limit and as long as no exceptions are permitted (ILO Convention No. 138 from 1973 and ILO Convention No. 182 from 1999).
3.6.2 Forced Labor
The prohibition of forced labor of any kind (ILO Convention No. 29 from 1930 and ILO Convention No. 105 from 1957).

3.6.3 Wage Compensation Work standards concerning compensation, especially in regards to the level of compensation as stated in the laws and requirements that are in force (ILO Convention No. 100 from 1951).
3.6.4 Employee Rights
Respecting the rights of the employee to freedom of association, freedom of assembly and collective bargaining as long as this is legally permitted and possible in the respective country (ILO Convention No. 87 from J 948 and ILO Convention No. 98 from 1949).
3.6.5 Prohibition of Discrimination
Treatment of all employees in a non-discriminatory fashion (ILO Convention No. 111 from 1958).

3.7 Hours of Work
We abide by work standards concerning the longest permitted time of work.

3.8 Environmental Protection
We fulfil the requirements and the standards for environmental protection that affect our Operations and acts in an environmentally conscious way at all locations where we are in operation. For additional responsibility with natural resources, we hold to the principles from the Rio Declaration (The 27 principles from the "Rio Declaration on Environment and Development" from 1992 as the result from the UN Conference on Environment and Development in Rio de Janeiro).

3.9 Civil Commitment
We, OBO Bettermann, contribute to the social and economic development of the countries and regions where we are in business and promote appropriate, volunteer activities by our employees.

4. Implementation and Application
We will make every appropriate and reasonable effort to implement and to apply the principles and values described in this CoC both now and in the future. Contractual partners will be informed about the basic measures upon request and within the scope of a reciprocal cooperation, so that it becomes observable how keeping these measures is fundamentally guaranteed. No right exists to disseminate operational or business secrets related to competition or any other information that is in need of protection.

Andreas Bettermann, CEO

D-58710 Menden