Business Partner Code of Conduct

Applicable as of 12 November 2021.

Navico Group AS and its subsidiaries (“Navico”) have a long history of operating with high ethical standards and integrity. We have done this by balancing our strong desire for profitable growth with our commitments to our various stakeholders, including our employees, consumer and communities in which we operate. The way our employees manage the social, environmental, and economic impacts of our business model is critical to our business success. Our stakeholders expect us to uphold high standards of responsible and ethical behaviour in our operations and to encourage a similar commitment by companies in which we do business.

This Business Partner Code of Conduct (the “Code”) sets forth our standards and expectations with respect to key areas of corporate responsibility. Our goal is to work with our Business Partners to assure compliance with these requirements, and our Business Partners are expected to align with the following standards and are encouraged to exceed the requirements set forth in this Code.

LEGAL COMPLIANCE AND BUSINESS INTEGRITY

Our Business Partners must comply with all applicable laws and regulations in their country of operation and all the laws and regulations in the countries in which they operate on behalf of Navico. The following activities are prohibited: offering or paying bribes, conflict of interest, falsification of documents, collusive bidding, price fixing, price discrimination, cartel participation, or any other unfair or unlawful trade practices in violation of antitrust laws.

The Foreign Corrupt Practices Act and the UK Bribery Act of 2010 make it unlawful for the payment or the promise of payment to a government official, individual or entity to assist or retaining business. Any actions that would be deemed as violations of these laws, or any other anti-bribery laws is strictly prohibited by you and anyone acting on your behalf. We encourage our Business Partners to have written policies prohibiting bribery, kickbacks, corruption and similar prohibited business practices. We expect our Business Partners to train their employees, consultants, subcontractors and vendors on the rules and procedures related to ethical business practices.

We have a strict policy regarding the giving and receiving of gifts by and to our employees. We discourage the giving of gifts to our employees, as even with the best intentions, could be a violation of laws or regulations or create an appearance of impropriety. Any gifts, entertainment or meals given to our employees or given by our employees are to be reasonable and appropriate in value and only in the course of the Business Partner’s business with Navico. Our employees may refuse inappropriate and unreasonable gifts, entertainments or meals from you. Our employees may not accept any gifts, meal or entertainments of a nominal value exceeding US $100.

You will disclose to us any situation that may appear to be a conflict of interest and disclose to us if any employee or family member from Navico may have an interest of any kind in your business or any kind of economic ties with your company.

Business Partners should respect the intellectual property of others. Business Partner will take appropriate steps to protect confidential and proprietary information belonging to us. This duty shall extend to any Information (Confidential Information, Trade Secret, Patent or Trademark) you may be provided with or have access to during your collaboration with Navico. Our Business Partners are routinely asked to sign additional non-disclosure agreements or include non-disclosure language in agreements with us.

You are expected to setup strong process to screen your providers, suppliers, business partners and business partners in general. You and those who act on your behalf, are expected to comply with all laws and regulations involving the importation, exportation and re-exportation of products and technical information, including the non-participation in boycotts and compliance with any sanctions or embargoes set forth by the European Union, the United States and any applicable local regulation.

Navico does not engage in and expect you not to engage in business with sanctioned parties and third-parties based countries under embargoes without relevant authorizations. As Navico Business Partner, you are expected to make sure that you, your business partners, your customers (and their customers) as well as all the third parties involved in your supply chain comply implement processes to comply with the standards set out in this Code.

You must immediately inform Navico in case you become aware or reasonably suspect that you or your business partners fail, have failed or are suspected to fail to comply with the standards set out in this Code.

SOCIAL AND WORKING CONDITIONS

We are committed to the elimination of all form of modern slavery and do not tolerate that our Business Partners (including their business partners) use or caution the use of child labour, forced labour, human trafficking, bonded labour and the use of conflict minerals. We request that our Business Partners (including, notably, our suppliers) maintain a list of the smelters and refiners used in their supply chain and certify the origin of their raw materials in order to ensure strict compliance with international regulations on conflict minerals. We may, at any time, request that you disclose the relevant information related to the smelters and refiners used in your supply chain in order to ensure strict compliance with national and international regulations.

We expect our Business Partners to support and participate in industry efforts aimed at the elimination of such practices wherever they exist in the supply chain.

You must not utilise or benefit in any way from forced or compulsory labour, nor utilise factories or subcontractors that force unpaid labour. The recruitment, transport, transfer, harbouring or receipt of persons, by means of the threat or use of force, coercion or other means for exploiting them, is prohibited.

You shall not employ individuals below the age of 16, except if allowed by local law and such exception is consistent with the International guidelines set forth in the Labour Organisation’s Declaration on Fundamental Principles and Rights at Work. Business Partner shall maintain documentation of each individual’s date of birth or has legitimate means of confirming each individual’s age.

Our Business Partners should provide wages at least equal to the applicable minimum wage and any associated statutory benefits. If there is no legal minimum wage, Business Partners ensure that wages are at least comparable to those at similar companies in the local area or to prevailing industry norms. Working hours should reflect applicable legal norms and overtime hours should be paid at the legally mandated premium or at least at the same rate as regular hours worked if there is no mandated premium.

Business Partners shall not engage in physical, mental, verbal, sexual or any other abuse, inhumane or degrading treatment, corporate punishment or any form of harassment or abuse of authority.

Business Partners respect the right of employees to form and join trade unions and bargain collectively in a lawful and peaceful manner, subject to and in accordance with applicable law.

We expect our Business Partners to provide their employees with a safe and healthy working environment for all employees that include appropriate controls, safety procedures, preventative maintenance, and protective equipment. Practices must comply with all relevant local and national laws, codes, and regulations.

You must immediately inform Navico in case you become aware or reasonably suspect that you or your business partners fail, have failed or are suspected to fail to comply with the standards set out in this Code.

ENVIRONMENT AND SUSTAINABILITY

We encourage our Business Partners to reduce waste and usage of all types by implementing appropriate conservation measures and create improvement plans for waste reductions. Business Partners must obtain, maintain and keep current all required environmental permits and registration and any operational and reporting requirements shall be followed.

DATA PROTECTION

As Navico Business Partner, you are likely to receive personal data belonging to Navico employees and other business partners. Navico complies with Data Protection regulations applicable in the countries where it processes personal data. When processing personal data received from Navico, you are expected to respect the relevant Data Protection Regulations, including notably, but not exclusively, the General Data Protection Regulation of the European Commission, the California Consumer Privacy Act or the New-Zealand Privacy Act. Personal data are any information which are related to an identified or identifiable natural person and therefore include individuals name, emails, titles or professional phone numbers which you may receive on a regular basis.

You should only process data of data subject based in the European Union lawfully, fairly and in a transparent manner. In addition, you should ensure that you have established relevant safeguards and security measures in place to protect against any loss of availability, confidentiality or integrity of such personal data. Finally, you must ensure that you will provide data subjects with effective channels to allow them to exercise their rights to access, be notified, rectify, erase, restrict or object to the processing of their personal data, as well as their rights to object to automated individual decision-making and portability. You will immediately, (in any case within no more than forty-eight hours of discovery) report any breach, loss or suspected loss of integrity, availability or confidentiality of such personal data to Navico’s Global Data Protection Officer at: DPO@Navico.com.

CONTACT US AND REPORT CONCERNS

You are responsible for prompt reporting of actual or suspected violations of laws, our Business Partner Code of Conduct, and/or any contractual relationship with us. This includes violations by any employee, agent or business partner acting on behalf of either the Business Partner or our own employees. We also encourage all Business Partners to implement confidential and anonymous means for employees to raise grievances. To report any violations of this Code of Conduct, you may contact using the following contact information:

– Navico Global Legal Department at Legal@navico.com
– Navico Whistle-Blower Helpline (to report anonymously) at: www.navico.ethicspoint.com

VERIFICATION AND COMPLIANCE

Business Partners should have adequate monitoring and record keeping systems to ensure compliance with this Code of Conduct. Our relationship with you is based on mutual trust and respect. You may also demonstrate your commitment to these principles through compliance with your own code of conduct or company policies that embrace these standards. However, we reserve the right to monitor, review and verify compliance with the Code by requesting you to periodically complete certification forms, questionnaires or by granting us permission to verify compliance with the Code by an on-site visit upon reasonable prior notice.

In case of non-compliance, corrective actions will be set forth, in order to comply with laws and regulations.

Business Partners are responsible for informing and training their workers about the expectations contained in this Code. This might include prominently posting the Code in the workplace in the area accessible to workers, conducting group or individual meetings to review and explain the Code, or other such communications.

We reserve the right to terminate its business relationship with a Business Partner who is unwilling to comply with the Code or requests to verify your compliance with the Code. Notwithstanding any provision of your contract with us, we always reserve our right to terminate our relationship with you and our other Business Partners in case of material breach of the provision of this Code.

We reserve the right to request periodic written certification of the Business Partner’s compliance with the Code of Conduct and to revise this Code without notice.

Questions or comments about this Policy should be directed to: Legal@navico.com