SUPPLIER CODE OF CONDUCT

1- PREAMBLE

Point S Group, comprising Affiliates and Operating Companies, commits to developing high standards of Corporate Social Responsibility (CSR) and formalising the ethical behaviours expected from all its stakeholders.

To achieve this, Point S Group involves its suppliers and subcontractors by signing this supplier code of conduct.

This commitment implies close collaboration and the greatest diligence to respond to our questions and, if necessary, to welcome third-party organisations instructed by Point S Group to audit such matters. If, due to particular circumstances, the supplier is not able to comply with certain terms of the code, it has to report any impact, together with the corresponding corrective action and the follow-up procedure over time. It must do likewise if a practice prohibited by the code comes to its attention. These reports should be sent to the following e-mail address: direction@alianco.ch.

2-  SUPPLIERS’ COMMITMENTS TO POINT S GROUP.

2.1   Human rights, labour rights and development of human potential

Human rights, labour rights and development of human potential

Point S Group expects its suppliers to comply with the fundamental Conventions of the International Labour Organisation (ILO) as well as with all regulations applicable to their field of activity. Point S Group expects them to promote and respect human rights in their sphere of influence, in particular on the following topics:

  • Use of child labour: The supplier undertakes not to use child labour under any circumstances. The term “child” here refers to any person below the minimum legal working age in the country where the work is carried out, provided that the legal age is in accordance with the provisions defined by the ILO.
    • Use of forced or compulsory labour: The supplier undertakes not to use forced or compulsory labour as defined by the ILO, i.e. any work or service required of an individual under threat of any penalty and which the individual does not do voluntarily. The supplier respects local legislation against modern slavery.
    • Illegal work: The supplier undertakes not to use concealed work and to fulfil the obligations in terms of declaration and payment to the administrative, social and fiscal authorities as required in the countries concerned.
    • Working hours: Working hours acceptable to Point S Group are determined by the regulations of the countries in which the suppliers operate. In the absence of a national law and also in the case of piecework, ILO standards must be applied.
    • Earnings: The supplier undertakes to comply with local legislation on minimum wages, and to pay employees their wages on a regular basis. The supplier agrees to pay overtime in

accordance with the rates defined by the applicable legislation. In addition, there can be no reduction in standard pay rates for disciplinary reasons.

  • Discrimination: The supplier undertakes not to discriminate between persons on the basis of their age, sex, religious beliefs, political opinions, social or ethnic origin, sexual orientation or identity, disability, family status, nationality, surname or physical appearance. It shall promote equal treatment and equal opportunities in accordance with the ILO principle of non- discrimination.
    • Health and safety: The supplier undertakes to declare all staff to social security bodies and to implement a health and safety policy guaranteeing a safe and healthy working environment for its employees, and to maintain an environment that respects people’s dignity. The risks associated with its activity must be assessed and progress plans implemented to prevent them.
    • Social dialogue: The supplier undertakes to guarantee its employees the right to communicate freely with their management about working conditions without fear of harassment, intimidation, sanctions, pressure or retaliation. It also undertakes to recognize and respect the right of workers to free association, whether or not they join an association of their choice.
    • Harassment and Abusive Conduct: The supplier agrees to treat its employees with respect and dignity and not to condone or engage in any form of physical punishment, physical, sexual, verbal or psychological harassment, or any other form of abusive conduct.

2.2   Business ethics

  • Corruption: The supplier undertakes to conduct its activities in accordance with the principles of honesty and fairness as well as with applicable laws and regulations in relation to the fight against corruption and rejects all forms of corruption in the conduct of its activities. In particular, the negotiation and execution of contracts must not give rise to behaviour or deeds that could be qualified as corruption, influence peddling, or related, similar, or equivalent offences within the meaning of the applicable regulations.
    • Gifts and travel: The supplier undertakes to refrain from directly or indirectly proposing, offering, soliciting or accepting any gift, invitation or any other benefit that could influence or be perceived as influencing a business relationship.

Any gifts and invitations that may be acceptable must be of symbolic value and not of such a nature as to influence the judgment of the recipient or must be in relation with a strategic and business content.

  • Conflict of interest: The supplier undertakes to avoid situations which could lead to a real or perceived risk of interference between the personal interests of an employee or their close relatives, whether legal or natural persons, and the interests of Point S Group. The mere perception of a conflict of interest is harmful.

The supplier undertakes to inform Point S Group of any situation where there could be an actual or potential conflict of interest with the employees or Operating Companies of Point S Group or their relatives so that the circumstances can be analysed on a case-by-case basis.

Such cases must be reported via the email address direction@alianco.ch, which ensures confidentiality for all whistle-blowers.

  • Fraud and swindling: The supplier and its staff undertake not to use any documents or confidential information obtained during their business relationship with Point S Group as a basis for transactions or to enable third parties to negotiate contracts.
    • Insider trading: The supplier and its employees undertake not to disclose, either directly or indirectly, any confidential or privileged information.

The supplier and its employees must comply with applicable laws on insider trading. They shall refrain from disclosing or using documentation and confidential information obtained during their business relationship with Point S Group as a basis for trading or for enabling third parties to trade in Thermador shares or related financial instruments.

2.3  Confidentiality and Intellectual Property

  • Personal and/or Sensitive Information: The supplier agrees to comply with the General Data Protection Regulation (GDPR) and other applicable personal data laws, guidelines and regulations. In addition, the supplier undertakes to handle sensitive, confidential and/or proprietary information appropriately. Such information shall not be used for any purpose other than the business purpose for which it was intended.
    • Intellectual Property: The supplier undertakes to comply with applicable legislation regarding the assertion of intellectual property rights, including protection against disclosure, patents, copyrights and trademarks.
    • Data security: The security of data and computer systems is an essential requirement for Point S Group which may entrust data and/or give access to its computer system. The supplier commits to comply with the security requirements which could be transmitted by Point S Group. Should a cyber-attack occur, the supplier shall inform Point S Group as soon as possible.

2.4  Environment, health and safety

Point S Group expects its suppliers to:

  • Comply with prevailing environmental laws and regulations in their own country.
    • Monitor the impact of their activities on the environment in terms of water consumption, energy, greenhouse gas emissions and waste production. Wherever possible, Point S Group asks the supplier to periodically assess its greenhouse gas emissions and to communicate this to its usual contact person within Point S Group. On the basis of this information, Point S Group expects the supplier to take a progressive approach and to try to reduce the environmental impact of its products or services throughout their life cycle.

Point S Group expects its suppliers to include environmental, health and safety criteria in the purchase of products and services, and the design, manufacture and implementation of their own products and services, in order to reduce their impact in those areas throughout their life cycle, while maintaining and/or improving their quality.

The supplier undertakes not to supply Point S Group affiliates and operating companies with any products that may contain substances prohibited under the laws of the destination country or countries.

In particular, the supplier undertakes to comply with European Regulation No 2023/1115  i.e. the “EUDR” Regulation on Deforestation, European Regulation No. 1907/2006/EC, the “REACH” Regulation, amended in 2018 by Regulation No. 2018/675/EU on chemical products, and with Directive 2017/2102/EU amending Directive 2011/65/EU, the “RoHS” Directive (Directive restricting the use of 10 substances in electrical and electronic equipment in all concerned markets and apply locally all other rules in place or that may appear.

2.5  Supply Chain

Point S Group expects its suppliers to commit to an approach which is at least as demanding towards their own suppliers in turn, by adopting the code of conduct of Point S Group or their own code. In the latter case, they will be required to provide an English translation. Either way, they will be asked to provide proof of roll-out of the adopted code.

Point S Group expects its suppliers to:

  • Promote and enforce the principles of its code of conduct with its subcontractors.
    • Implement a monitoring process to prevent and manage any risks that may have a significant environmental and social impact.
    • Cooperate with Point S Group in order to apply the present code of conduct as fully as possible. They agree to have the code’s principles assessed or audited by Point S Group or by duly appointed third-party organisations. If, due to particular circumstances, the supplier is not able to respect certain terms of the code, it must immediately inform Point S Group in question in order to agree together on corrective measures to be implemented by emailing: purchase@alianco.ch.
    • Point S Group suppliers are encouraged to set up their own code of conduct and to pass on their principles to their own suppliers and subcontractors.
    • Within the framework of this code, Point S Group reserves the right to request information relating to the non-financial performance of the supplier annually.
    • An email address direction@alianco.ch is open to suppliers to report situations that are not in line with ethical practices, if these situations involve its employees or those of Point S Group.

This code is valid until a new version is issued, overriding this code. It does not replace any other assessments made by Ecovadis, Sedex or other providers.