Supplier Code of Conduct

Supplier Code of Conduct

Edition 1 2025

Introduction Be-Ge Supplier Code of Conduct outlines how we do business in Be-Ge and the expectations on our supply network.

Together we can make a difference and build a future for generations to come.

At Be-Ge we believe that we have a collective responsibility to make the world we live in a better place.

By working with three sustainability pillars – climate,

Within the area of people, we invest in health,

resources, and people – and by conducting our business

empowerment, business ethics and compliance, and

with integrity, we are committed to minimising our

respect for human rights, striving for 100% safe products

climate footprint, respecting the boundaries of our

and operations. Social responsibility is fundemental in

planet, and maximising social impact.

our business and covers a broad range of topics across the value chain.

Within the area of climate, our focus on cutting greenhouse gas emissions is critical in meeting the

To achieve full effectiveness of this Supplier Code of

ambitions of the UNFCCC Paris Agreement .

Conduct, Suppliers must ensure that all Requirements

1

are lived by in their own operations, and that their full Within the area of resources, we take on the challenge

value chain complies to the same standards. We also

to fulfil the needs of transportation and infrastructure

expect all our Suppliers to integrate, share and promote

within the limitations of planetary boundaries, in our own

the Expectations of Be-Ge Supplier Code of Conduct

operations and our supply network.

internally and throughout their entire supply network.

1

https://unfccc.int/process-and-meetings/the-paris-agreement/the-paris-agreement

SUPPLIER CODE OF CONDUCT FOR THE BE-GE GROUP The Be-Ge Group is an internationell group of companies.

The business is organised into three divisions and the Be-Ge Företagen AB is the parent company of the Group.

» Be-Ge Seating Division Be-Ge Seating AB Be-Ge Seating A/S Be-Ge Frapett AB Be-Ge Seating UK Ltd

2

Introduction

Be-Ge Seating B.V. Be-Ge Seating GmbH

» Be-Ge Component Division Be-Ge Baltic UAB Be-Ge Plåtindustri AB Be-Ge Stece AB Be-Ge Lackering AB

» Be-Ge Vehicle Division Be-Ge Personbilar AB Be-Ge Lastbilar AB

»»

TABLE OF CONTENT Introduction................................................................ 2 People..................................................................... 10 Resources............................................................... 16 Climate.................................................................... 22 Business ethics and compliance............................. 26

3

Purpose

Scope

The purpose of Be-Ge Supplier Code of Conduct

The Supplier Code of Conduct is an integral part of any

(hereinafter referred to as the “Supplier Code of

existing business relationship and is incorporated by

Conduct”) is to define Be-Ge’s sustainability demands

reference into the agreement(s) between our Suppliers

(hereinafter referred to as “Requirements”) and to give

and Be-Ge. The Supplier Code of Conduct applies to all

guidance on demands to be expected in the future

Suppliers that deliver goods and/or services to Be-Ge.

(hereinafter referred to as “Expectations”) for all

The term “employee” used throughout this Supplier

Be-Ge Suppliers, in the areas of:

Code of Conduct covers everyone working for or on

» People » Resources » Climate » Business Ethics and Compliance Where additional more demanding national laws and regulations occur, they must be taken into account together and applied with Be-Ge Supplier Code of Conduct.

behalf of a Supplier, including but not limited to full and part-time employees, consultants, contractors, trainees, temporary workers, management, and board of directors. The term “employees” also includes specific vulnerable groups, such as young workers and migrant workers.

The term “supply network” used throughout this Supplier Code of Conduct consists of a constellation of suppliers that are involved in supply of said organisation across all stages from extraction of raw materials to final delivery.

It is also guided by networks such as the UN Global Compact 2, as well as frameworks such as the OECD Guidelines for Multinational Enterprises3, the UN Guiding Principles of Business and Human Rights4, the UN International Bill of Human Rights5, the International Labour Organisation’s (ILO) Fundamental Instruments of Principles of Rights at Work6, and the Children’s Rights and Business Principles7.

www.unglobalcompact.org/ www.oecd.org/corporate/mne/ 4 www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf 5 www.un.org/en/about-us/universal-declaration-of-human-rights 6 www.ilo.org/global/standards/introduction-to-international-labourstandards/conventions-and-recommendations/lang--en/index.html 7 https://childrenandbusiness.org/ 2 3

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Introduction

»»

For each area of the Supplier Code of Conduct, Be-Ge has defined two categories for our Suppliers’ sustainability performance and actions – Requirements and Expectations.

» Requirement

» Expectation

– a Requirement refers to the mandatory

– an Expectation refers to Supplier’s activities

requirements which all Suppliers must comply

where Be-Ge encourages each Supplier to

with. A breach of a Requirement is considered

actively go beyond our mandatory Requirements

as a material breach and would entitle Be-Ge

to further advance Supplier’s sustainable

to terminate the business relationship.

performance and impact in the areas covered by this Supplier Code of Conduct.

5

6

Introduction

Our general requirements » Supplier shall comply with all the Requirements of

» Supplier shall have a code of conduct in place

the Supplier Code of Conduct and make significant

clarifying the Supplier’s rules of behaviour and

efforts to comply with the Expectations.

proper conduct for the Supplier’s employees.

» Supplier shall ensure that all Requirements of this

» Supplier shall be proactive in appropriately

Supplier Code of Conduct are complied with and shared

addressing any risk of violation of the Requirements,

within its own operations to ensure full effectiveness of the

whether in their facilities or in their supply network.

terms of this Supplier Code of Conduct. We also encourage each Supplier to uphold the same standards regarding our

» Supplier shall implement and make available

Expectations throughout their entire supply network.

appropriate grievance channels and remediation

» Supplier shall operate honestly and be transparent

mechanisms for all employees and third parties to raise concerns or complaints, but also recommendations

with facts and data in relation to both Requirements

and improvement ideas concerning the Supplier’s

and Expectations. Be-Ge wants to maintain an open

operations without fear of retaliation.

dialogue concerning achievements, trends, and possibilities for improvements in the areas outlined

» Supplier shall handle environmental violations

by this Supplier Code of Conduct.

and complaints methodically and communicate them

» Supplier shall have a senior executive in place

to affected employees and to external stakeholders, including Be-Ge, when relevant.

who is responsible for compliance with the areas covered by this Supplier Code of Conduct.

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Legal compliance

Management systems

Fundamental to all areas of this Supplier Code of

Suppliers shall establish and maintain adequate

Conduct and the baseline of all business with Be-Ge,

management systems to oversee all elements of this

we require our Suppliers to be knowledgeable about

Supplier Code of Conduct, in proportion to the size,

and to comply with all applicable laws and regulations

complexity and risk environment of the Supplier’s

they are exposed to, as well as the contractual terms

business. It shall contain a policy commitment from

and conditions agreed upon with Be-Ge. All legally

the Supplier’s management, as well as providing for

required permits, approvals, licenses, registrations,

effective due diligence and risk assessment, assigning

inspections, and related reports shall be in place, up to

responsibility to relevant and trained personnel, and

date and available for inspection upon request. In case of

including monitoring and reporting mechanisms related

discrepancy between local laws and regulations and the

to all areas of this Supplier Code of Conduct. Such a

Requirements set forth in this Supplier Code of Conduct,

management system shall be continuously reviewed,

the most stringent terms shall apply. In other words, in

monitored, and improved, preferably under independent

case local laws and regulations are less stringent than

third-party certification. In the case of any improvements,

a Requirement set out in this Supplier Code of Conduct,

Supplier should inform their regular Be-Ge contact.

the latter shall apply and vice-versa. It is an Expectation

We appreciate this information, which gives us the

of the Supplier to inform Be-Ge of any such discrepancy

opportunity to constantly learn and optimise our Supplier

arising from updates to local or regional laws.

Code of Conduct. Any deviation or non-conformity found by the Supplier, or a third party should be brought to Be-Ge’s attention via your regular contact.

8

Introduction

Speak up

Continuous improvement

At Be-Ge, we encourage external third parties – including

Be-Ge believes in continuous improvement and

but not limited to business partners, customers,

recognises that implementing the standards of this

suppliers, dealers, consultants, and former employees –

Supplier Code of Conduct into the Supplier’s operations

to promptly report concerns of misconduct, violations

and supply network is a dynamic rather than a static

of the law, and other unethical behaviours using

process. It is important to us that our Suppliers

Be-Ge Whistleblower policy

show dedication towards embedding not only the

Whistleblowers may identify themselves or decide to

Requirements but also the Expectations into their

report their concerns anonymously. Reported situations

operations and across their supply network and seek

will be investigated diligently and with care.

continuous improvement over time in order to be able to

Be-Ge does not tolerate any kind of retaliation against

show progress in all areas covered by this Supplier Code

anyone reporting, in good faith, or assisting in the

of Conduct.

investigation of a potential violation of the law or of this Supplier Code of Conduct.

Due diligence

Implementation This Supplier Code of Conduct and the associated

Due diligence here refers to Supplier’s ongoing risk

sustainability performance is a key indicator in Be-Ge

management process to identify, prevent, mitigate, and

Supplier qualification and assessment process, and

account for their risks and impacts on climate, resources,

accepting this Supplier Code of Conduct is a prerequisite

people, and business ethics and compliance. Be-Ge

for doing business with us. Upon being onboarded as a

requires every Supplier to perform due diligence in the

Supplier to Be-Ge, Be-Ge verifies compliance with the

areas covered by this Supplier Code of Conduct and/

Requirements and Expectations of this Supplier Code

or applicable laws and regulations, including for the

of Conduct and reserves the right to audit the Supplier

purpose of investigating and evaluating the integrity,

and its supply network, with regards to compliance

quality, suitability, and credibility of all its potential

with the Supplier Code of Conduct, at any point of time

business partners. Supplier’s due diligence efforts shall

during the contract period. Audits may be conducted by

be in accordance with international standards such as

employees of Be-Ge or by an independent third party

the OECD Due Diligence Guidance for Responsible

commissioned by Be-Ge. Lack of cooperation, failure to

Business Conduct8 and the UN Guiding Principles on

address violations of the Requirements of this Supplier

Business and Human Rights. Supplier shall include

Code of Conduct and/or non-timely implementation

impacts of its own operations and its supply network with

of necessary corrective action plans may result in a

a focus on where it has the highest risks of doing harm,

reduction in business and, ultimately, an end to the

and appropriate to company size and circumstances.

business relationship with Be-Ge.

8

www.oecd.org/investment/due-diligence-guidance-for-responsible-business-conduct.htm

9

People We believe in building a better future – but we cannot do that alone.

As a human-centric company, we are invested in the power of people and know their contribution changes everything.

Human rights are fundamental. Our commitment

women, persons with disabilities, migrants, minorities,

to respect human rights covers not only our own

and refugees), and local communities in connection

operations and employees, but also communities

with the Supplier’s activities and operations.

near our operations, Suppliers, and people potentially

Suppliers shall provide employees with a safe, healthy,

impacted by the use of our products and solutions.

respectful, and inclusive working environment that

Embedding responsible business practices across the

minimises the incidence of work-related injuries and

value chain, ensuring transparency and trust, means

enhances the quality of products and services, the

that we act together. Suppliers of Be-Ge shall respect

consistency of production, and worker retention,

all internationally recognized human rights and treat

morale, and well-being. This applies to Supplier’s

all people with dignity. Suppliers should especially be

production facilities, but also to any company-provided

aware of and respect the rights of indigenous people,

accommodation, including but not limited to dormitories

groups in vulnerable and marginalised situations

or any type of transportation provided by a Supplier to

(including but not limited to children and youth,

its employees.

10 People

Modern slavery and forced labour

Child labour

» Requirement

» Requirement

Be-Ge does not tolerate any forms of modern slavery or forced labour, including but not limited to forced, bonded or compulsory labour and human trafficking.

Consequently, Supplier, including their recruitment agencies, shall not engage in or tolerate restrictions of movement, recruitment fees, confiscation of identity documents and/or passports, withholding of wages, abusive working conditions, debt bondage, violence or any other kind of exploitation or abuse. Supplier shall have adequate policies, risk awareness, risk assessment and due-diligence processes in place to prevent modern slavery and forced labour throughout its supply network, including remediation plans addressing situations if modern slavery or forced labour is detected. Supplier shall further abide by the

Be-Ge does not tolerate child labour. Supplier shall prevent all forms of child labour and respect children’s rights to development, play, and education, in line with the UN Convention on the Rights of the Child9.

Supplier shall have adequate policies, risk awareness, risk assessment and due-diligence processes in place to prevent child labour throughout its supply network, including remediation plans addressing situations if child labour is detected at Supplier or any of its subcontractors. The minimum legal working age is the age of completion of compulsory school, but never less than 16 years. Young Workers between the ages of 16–18 years old shall not be exposed to any night or hazardous work that is likely to harm their physical or mental health or safety, or morals, as this may

ILO conventions No. 29 on Forced Labour and No.

constitute child labour.

105 on the Abolition of Forced Labour.

» Expectation

» Expectation Supplier is encouraged to engage constructively with relevant stakeholders such as non-governmental organisations and industry associations to build awareness and proactively work towards preventing modern slavery and forced labour.

Supplier is encouraged to engage constructively with relevant stakeholders such as children’s rights experts, non-governmental organisations, and industry associations to build awareness and proactively work towards preventing child labour, respecting children’s rights, and promoting their access to education and healthy development.

www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-child

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Working hours and leave

Wages and benefits

» Requirement

» Requirement

Supplier shall always respect and comply with

Supplier shall always pay and provide its employees’

applicable laws and collective bargaining agreements,

wages and benefits that, as a minimum, comply with

if applicable, on working and resting hours, including

applicable laws and collective bargaining agreements.

overtime working hours, as well as annual, sick,

Supplier shall provide its employees with information

and parental leave, and any other applicable leave

about their employment terms and conditions, including

regulations. All overtime work by Supplier’s employees

benefits, in a format and language they can easily

shall be on a voluntary basis and appropriately

understand, including a written employment contract

compensated in accordance with the local laws.

and a timely wage statement. Deduction from wages

Supplier shall further abide by the ILO convention No.

is permitted only if and to the extent prescribed by

1 and No. 30 on Hours of Work. Supplier is to maintain

applicable law, regulations, or collective bargaining

reasonable working hour schedules for its employees

agreements.

to prevent quality and safety incidents, and to minimise strains on employees’ physical and mental health.

» Expectation

» Expectation

Supplier is encouraged to adopt a pay structure that

Supplier is encouraged to develop a business model

well as the living wage standard of the country. Supplier

which considers work life balance through time

is encouraged to consider ILO convention No. 100 on

management and regularly reviewing the needs of the

Equal Remuneration in its procedures and policies.

employees.

Supplier is encouraged to implement supportive

adequately reflects employee skills and experience as

employee benefits to enable a better work life balance.

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People

Non-discrimination and fair treatment

Freedom of association and collective bargaining

» Requirement

» Requirement

Supplier shall treat everyone with dignity and respect

All employees shall have the right to lawfully form,

and provide equal employment opportunities and

join or not join labour unions, bargain collectively, seek

conditions based on the individual’s ability to do the job,

representation and join worker’s councils in accordance

regardless of employee or job applicant characteristics,

with local law and international conventions. Employees

including but not limited to:

shall be able to openly communicate and share ideas

» Gender, gender identity or expression » Age » Nationality, race, ethnicity, skin colour or cultural

and concerns with management regarding working conditions and management practices without fear of discrimination or retaliation. Where local law restricts the right to freedom of association and collective bargaining,

background

Supplier shall allow alternative forms of worker

pregnancy

» Expectation

» Religion or belief » Disability, genetics, or health information including » Sexual orientation » Union affiliation Supplier shall not tolerate humiliating

representation, association, and bargaining.

Supplier is encouraged to engage in active social dialogue with its employees based on motivation,

or physical punishment or allow any employee to be

recognition, and reward in order to stimulate workplace

subject to verbal, psychological, physical abuse,

engagement. Supplier is encouraged to engage

or sexual harassment.

constructively with relevant stakeholders such as

» Expectation Supplier is encouraged to actively promote diversity and inclusion and provide equitable benefits and working conditions accommodating all categories of human diversity. Supplier is encouraged to engage constructively with relevant stakeholders, such as non-

nongovernmental organisations, industry associations and worker representatives for sustained relations between employers and workers within the industry sectors or areas of operation. Supplier is further encouraged to consider ILO conventions No. 87 on Freedom of Association and No. 98 Right to Organise and Collective Bargaining in its procedures and policies.

governmental organisations and industry associations, to build awareness and proactively work towards identifying root causes of discrimination. Supplier is further encouraged to consider the ILO convention No. 100 on Equal Remuneration and No. 111 on Discrimination in Employment and Occupation in its procedures and policies.

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Health safety and well-being

» Requirement Supplier shall ensure that its employees’ potential exposure to safety hazards, such as machines, equipment, substances, or other chemical, biological or physical agents, are identified, assessed, and controlled through proper design and/or preventative maintenance, and safe work procedures. Hazardous substances

to their own bed with gender separation. Supplier shall ensure that well-being is embedded in the organisation’s day-to-day operations and culture. Supplier shall implement control measures for psychosocial risks related to work organisation, social factors, work environment, equipment, and hazardous tasks.

stored, recycled, and disposed of safely. Where hazards

» Expectation

cannot be adequately controlled by these means,

Supplier is encouraged to work pro-actively with a long-

employees shall be provided with appropriate personal

term health and safety strategy, which includes aspects

protective equipment including access to first-aid

on age, disability, gender, and religion, both from a

supplies. Safety information shall be made available to

physical and mental health risk perspective. Supplier

everyone to educate, train, and protect the employees

is encouraged that strategies for eliminating hazards,

from safety hazards. A Supplier that has employees

reducing psychosocial risks and promoting well-being

performing work on Be-Ge premises shall make sure

should be developed in consultation with employees

that employees are informed about and comply with

and, where they exist, worker representatives. Supplier

local Be-Ge health and safety routines and procedures.

is encouraged to involve concerned employees when

Supplier shall have adequate emergency preparedness

designing or redesigning workplaces as well as to

procedures in place to identify and assess potential

include workplace ergonomics in health and safety

emergency situations. Emergency plans, fire safety and

committees with employee representation. Employees

response procedures shall be implemented, including

performing work on Be-Ge premises are encouraged

employee notification and evacuation procedures,

to identify and report actual and potential unhealthy

employee training and evacuation drills. Fire safety

and unsafe working conditions and to bring them to

procedures shall, where available, be periodically

Be-Ge’ attention.

reviewed and approved by local authorities. Supplier

Supplier is encouraged to consider ILO conventions

shall identify, evaluate, control, and reduce employee

No. 155 on Occupational Safety and Health and No.

exposure to ergonomic risks, including but not limited

187 on Promotional Framework for Occupational Safety

to prolonged standing, sitting, improper working and/

and Health in its procedures and policies. Supplier is

or lifting positions, repetitive movements, or physical

encouraged to utilise the Occupational health and safety

load. Employees shall have ready access to free and

management – Psychological health and safety at work

clean drinking water, hygienic toilet facilities, hygienic

– Guidelines for managing psychosocial risks10.

food preparation, storage and eating facilities, adequate

Supplier is encouraged to provide ready access for

ventilation, light, and temperature levels, and acceptable

truck drivers delivering goods to and picking up goods

levels of noise and dust pollution. If accommodation is

at Supplier’s premises to free and clean drinking water,

provided, Supplier must provide each employee the right

hygienic toilet, and waiting facilities.

in chemical products shall be handled, transported,

10

ISO 45003:2021, IDT https://www.sis.se/api/document/get/80029829

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People

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Resources The planet’s resources are finite, and therefore every business must rethink existing production and consumption patterns.

Taking care of our planet’s resources means implementing a circular business approach and improving environmental resource management as well as material efficiency throughout the entire life cycle.

The life cycle stages include extraction of raw materials,

Suppliers of Be-Ge shall conduct responsible supply

design, production, transportation/delivery, use, end-

chain management of any materials critical to the

of-life treatment, and final disposal. It means to source

industries in which Be-Ge operates, and in particular

materials responsibly without risk of contribution to

of those from conflict-affected and high-risk areas,

adverse impacts such as human rights violations,

including water management and substances of

conflict, or climate change. With water being a scarce

concern. Suppliers shall utilise circular business

natural resource that is expected to become even

models designing out waste and pollution and keeping

more scarce in the future, it’s about addressing water

materials in use phase. The use of virgin materials shall

management plans to maximise efficiency and to ensure

be minimised using circular strategies. Suppliers shall

safe usage. In addition, biodiversity protection, through

implement strategies which ensure minimal loss of

regulations and management plans, is essential to

biodiversity as well as contributing to a replacement of

ensure that the land, the forest, the waterways and more

biodiversity.

continue to renew and replenish for a living world.

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Resources

Responsible sourcing of minerals and materials

» Requirement Be-Ge requires all Suppliers to exercise adequate due diligence following the OECD Due Diligence Guidelines for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas11. Be-Ge requires specific focus on the sourcing, extraction and handling of tantalum, tin, tungsten, gold, hereinafter referred to as “Conflict Minerals”.

Supplier shall upon request from Be-Ge submit a valid CMRT (Conflict Mineral Reporting Template). Supplier shall have a policy and due diligence process in place to ensure that any of these minerals contained in the products manufactured by the Supplier do not directly or indirectly finance or benefit armed groups that are perpetrators of human rights abuses, or in any other way directly or indirectly contribute to human rights violations. We require Supplier to ensure that all smelters and refiners in its Conflict Minerals network take part and actively engage in third party audit programs and to provide any information on such smelters and refiners upon request to Be-Ge. Supplier shall also perform adequate due diligence for other materials that are identified by Be-Ge as directly or indirectly contributing to violations of human rights and/or climate change, including making a reliable determination of the origin and source of such materials.

Supplier shall not directly or indirectly procure minerals or materials that contribute to illegal deforestation, and all wooden products shall be either FSC12 or PEFC13 certified. Supplier shall furthermore not procure minerals or materials that are mined from the deep seabed or are sourced without respecting indigenous people (including their right to prior and informed consent), including to financing any of the activities mentioned above directly or indirectly.

» Expectation Supplier is encouraged to take a holistic and circular approach for their raw material supply chain by looking for innovative solutions and circular flow of material throughout the design and manufacturing process.

Be-Ge welcomes initiatives and ideas enabling us to evaluate any holistic sustainable impact improvements for our common products and services. At all times, we encourage our Suppliers to adhere to the precautionary principle by, when suitable alternatives are available, substituting materials and methods posing potential environmental or health related risks. Be-Ge further encourages Supplier to consider biodiversity, including ecosystems and habitats, and to avoid harmful soil modifications within their material supply chain.

Be-Ge welcomes Supplier to constructively engage with relevant stakeholders, such as subject matter experts,

https://www.oecd.org/corporate/mne/mining.htm https://fsc.org/en/forest-managers 13 https://www.pefc.org/ 11

12

scientists, and non-governmental organisations, to understand and improve its impact on biodiversity, ecosystems, and habitats both on land and deep sea.

17

Circular economy and waste management

» Requirement

» Expectation

To enable the transformation of our industry from a

In Supplier’s transformation journey towards circularity

linear to a circular economy, Supplier shall continuously

and efforts to continuously optimise their business,

demonstrate accountability and make efforts to optimise

Supplier is encouraged to specifically emphasise

and explore circular business models for the products

proactive design for circularity with focus on materials

delivered to Be-Ge, including its packaging, all in

and minerals based on the circular 9R-framework.

accordance with internationally recognised circular

The 9R-framework14 defines levels of circular activities

principles. Supplier shall monitor, track, and treat

from Recover and Recycle over Remanufacture and

liquid and solid waste generated by its operations,

Reuse towards Reduce and Refuse. Be-Ge furthermore

industrial processes and sanitation facilities, and

stimulates innovative circular business models where

foster opportunities for improvement and minimised

Supplier is extending and optimising the product use

waste. Supplier shall – in agreement with Be-Ge – use

phase and maximises the product reusability.

market available recycled material for the production

Supplier is encouraged to implement a waste

of their products delivered to Be-Ge, with the ambition

management strategy that targets, in order of priority:

to transition to a circular material flow. Supplier shall

(1) prevention, (2) reduction, (3) reuse, (4) recycling,

apply circular strategies to their processes and waste

(5) energy recovery, (6) incineration without energy

management to avoid any kind of waste ending in landfill

recovery, and (7) landfill/disposal of waste in a safe and

or polluting rivers, oceans, and waters, to the best of

environmentally responsible manner.

their technical ability. Supplier shall monitor, track, design and optimise the composition of their packaging material which becomes waste at Be-Ge in line with Be-Ge packaging standards, e.g., utilising non-complex materials and/or materials for which there are locally established recycling markets available.

14

https://www.researchgate.net/figure/The-9R-Framework-Source-Adapted-from-Potting-et-al-2017-p5_fig1_320074659

18

Resources

19

Water management

» Requirement Supplier shall monitor, track, and document its consumption of water to be able to identify aspects that Supplier can control and influence, fostering opportunities for improvement, minimised consumption and reuse to close the loop. Supplier shall use and process water responsibly, being of most importance to Suppliers located in areas affected by water scarcity and/or Suppliers with high water consumption. The Supplier shall ensure that the collection, use and reuse of water and rainwater is considered in their production processes and water management. Supplier shall furthermore treat and clean all wastewater from its operations to a minimum level in accordance with applicable local legal requirements.

» Expectation Supplier is encouraged to implement a long-term water management strategy with clear targets on how to protect water as a resource, improve water use efficiency, reduce consumption, and maintain good water quality through responsible treatment of wastewater discharges. Supplier is further encouraged to engage constructively with relevant stakeholders such as water management experts and nongovernmental organisations to understand and improve its impact on safe and resilient water supplies, including interlinked impact on biodiversity and ecosystems.

20

Resources

Substances of concern

Biodiversity protection

» Requirement

» Requirement

Supplier shall identify and declare potentially harmful

Supplier shall implement an appropriate assessment

substances as well as other critical materials in products

of the impact and necessary mitigation measures for

delivered to Be-Ge, and upon request by Be-Ge work

sites potentially impacting a protected area in terms

actively to eliminate and phase out any such identified

of biodiversity. Suppliers shall avoid contributing to

substances of concern. Substances and critical

and benefiting from the unlawful conversion of natural

materials included in products or services delivered

ecosystems. Suppliers shall avoid using products made

to Be-Ge must comply with any applicable laws and

from or originating from endangered species. Supplier

regulations such as REACH, RoHS and SCIP prohibiting

may only use materials originating from species that

or restricting the use or handling of specific substances.

are classified as “least concern (LC)” by the IUCN Red

Supplier shall track and follow up on substances of

List15. Supplier shall also implement adequate policies,

concern and critical materials.

due diligence, risk awareness, risk assessment and

Material Data Sheet (MDS) registration is mandatory

risk mitigation processes in regard to commodities with

in due time for all parts and materials delivered to

high risk of causing deforestation throughout its supply

Be-Ge, regardless of design date, application of the

network.

part or material, and including spare parts and parts for customer adaptation. Supplier is responsible to ensure that the MDSs are updated and reflect the true content of the part delivered to Be-Ge.

» Expectation Supplier is encouraged to assess their impact on biodiversity across the entire value chain and take

» Expectation

a zero-harm approach, by avoiding activities that

Be-Ge has the ambition to phase out Substances of

set clear, measurable goals for how they will reduce

Very High Concern (SVHC) and any other substances

their negative impact on biodiversity and how they

fulfilling the criteria of being a SVHC under EU REACH

will contribute to restoring ecosystems. Supplier is

legislation. Supplier is encouraged and expected to pro-

encouraged to minimise their impact and actively

actively work together with Be-Ge in this ambition, e.g.,

work to restore natural environments that have been

evaluating and proposing sustainable alternatives to

harmed by investing in naturebased solutions and

minimise the dependency of such substances.

“giving back more than you take”.

15

endanger ecosystems. Supplier is encouraged to

https://www.iucnredlist.org/

21

Climate This is the deciding decade, with climate change being one of the biggest challenges of our time. Be-Ge recognises the importance of remaining within the boundaries of the planet, to avoid passing irreversible tipping points, where a transition to a low carbon economy is critical. To tackle the climate challenge, Be-Ge expects its Suppliers to join our journey towards the goal of the UNFCCC Paris Agreement.

Suppliers shall reduce their negative impacts by protecting the environment and minimising greenhouse gases (GHG) from their industrial activities including their supply network.

22 Climate

23

Net-zero supply network

» Requirement

» Expectation

Supplier shall strive to reach net-zero greenhouse gas

Suppliers are encouraged to have GHG emissions

(GHG) emissions in its operations and supply network.

reduction targets verified by the Science Based Targets

To reach this target, all Suppliers shall set targets

initiative17. The mitigation hierarchy for Supplier’s

covering scope 1 and 2 emissions, as defined by the

netzero supply network roadmap should preferably

Greenhouse Gas Protocol Corporate Standard16. The

start with (1) elimination of GHG emissions through

targets shall be relevant for Suppliers’ core business

energy efficiency and introduction of new concepts

and contribute to relevant industry initiatives. Supplier

and technologies as top priority, (2) replacing fossil

shall monitor and track the fulfillment of the targets and

GHG emissions with biogenic GHG emissions and (3)

or upon request by Be-Ge be open and transparent

neutralisation activities as a last resort when all other

about its GHG emissions.

options are exhausted. Supplier is advised to engage with their supply network partners to encourage and support their efforts in setting and achieving science based GHG emissions reduction targets.

Be-Ge further encourages Supplier to take a holistic and circular approach to reduce climate impact by looking for innovative solutions and circular flow of material throughout the design and manufacturing process.

Be-Ge welcomes initiatives and ideas enabling us to evaluate any holistic climate impact improvements for

16 17

https://ghgprotocol.org/corporate-standard https://sciencebasedtargets.org/

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Climate

our products and services.

Net-zero logistics

» Requirement Supplier shall work to support the net-zero greenhouse gas supply chain by having strategies in place for decarbonised logistics. Supplier shall work to optimise freight transport mode and increase asset utilisation to reduce GHG emissions.

» Expectation Supplier is encouraged to improve fleet energy efficiency and to reduce the carbon content of energy used.

Energy consumption and usage of renewable energy

» Requirement Energy consumption is a heavy contributor to climate change. To fulfil the challenges of a net-zero GHG emissions supply chain, Be-Ge requires all Suppliers to work for are ducation of their energy consumption and to advance the use of renewable and alternative energy sources for their operations and logistics system.

Purchasing or establishment of renewable energy sources under the responsibility of Supplier, for example windmills or solar panels, must always consider and respect the rights of local communities and indigenous people, including their right to prior and informed consent.

» Expectation Parallel to Supplier’s efforts to minimise energy consumption, Be-Ge encourages Supplier to choose the lowest carbon footprint alternative. For electricity, heating, and cooling this means excluding fossil sources such as coal, natural gas, or oil and switching to renewable sources either at site or by contracting renewable energy traceable via Energy Attribute Certificates (EACs) or similar.

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Business ethics and compliance Be-Ge believes that earning and retaining business fairly and in compliance with applicable legal requirements is essential to build trust with customers, business partners, and society at large.

Be-Ge requires its Suppliers to honour the values of uncompromising integrity, fairness, and transparency and to always operate honestly and equitably throughout their operations and business relationships, as a condition to doing business with Be-Ge.

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Business ethics and compliance

Business ethics

» Requirement Supplier shall always uphold the highest level of business ethics and compliance in all business interactions and disclose details of its corporate structure when requested by Be-Ge. Conflicts of Interest Supplier shall do business in an open and transparent way avoiding conflicts of interest that could interfere with objective and professional decision making.

For that purpose, Supplier must disclose any situation where a Be-Ge employee or professional under contract with Be-Ge may have a personal interest of any kind in the Supplier’s business or any kind of economic ties with the Supplier.

Anti-Corruption and Anti-Money Laundering Supplier shall not engage in, endorse, nor tolerate any form of bribery or corruption, directly or indirectly.

Supplier shall not offer nor accept any form of improper benefit to or from a third party – private or public – with the purpose of obtaining or retaining business or any form of preferential treatment. Supplier shall also refrain from proposing to Be-Ge any form of improper benefit. Such benefits may comprise not only cash but also job opportunities, favours, travel, facilitation payments, promises to pay debts, or unlawful gifts and entertainment. Supplier shall have adequate policies, risk awareness, risk assessment, and due diligence processes in place, to prevent bribery and corruption or money laundering in its dealings or in its supply chain.

Supplier agrees to abide by and comply with all relevant anti-money laundering laws and regulations as well as any laws designed to ensure financial transparency.

Supplier shall also implement effective internal controls.

Export Controls and Economic Sanctions Supplier shall conduct its business with Be-Ge in compliance with all applicable export control regulations, economic sanctions, embargoes, and other trade restrictions. Supplier shall not perform any act which would cause Be-Ge to be in violation of or exposed to adverse consequences under these regulations. Supplier represents that neither Supplier, nor any of its affiliates, directors, officers, or agents, are designated for sanctions or export control restrictions (denied or restricted party). Supplier shall not supply to Be-Ge any goods, software, technology, technical data, or services that are sourced from a restricted party or that have trans-shipped or transited through a country that is subject to sanctions. Supplier shall implement a whistleblower process where its employees and external third parties can (anonymously or not) raise any concerns of misconduct without fear of retaliation.

Confidentiality and Intellectual Property Rights

» Expectation

Supplier shall respect Be-Ge confidential information

Supplier is encouraged to implement an information

and intellectual property rights by safeguarding against

management strategy, including proper levels and

misuse, mishandling, counterfeit, theft, fraud, or

thresholds as well as records and indicators for proper

improper disclosure in accordance with applicable law

business ethics and compliance across its supply

and Be-Ge Seating contractual terms.

network.

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Fair competition

Information security

» Requirement

» Requirement

Supplier shall respect and comply with all applicable fair

Supplier shall safeguard Be-Ge information and take

trade, competition and anti-trust laws and regulations

appropriate steps to protect its confidentiality, integrity,

and shall not have any anti-competitive discussions or

and availability. In case information security has been

enter into any anti-competitive agreements, including

violated, e.g., through cyber-attacks, the Supplier has

illegal price-fixing, market sharing, customer allocation,

the obligation to inform Be-Ge immediately.

or other illegal restrictive practices, at any level of the

This includes events which put the Supplier’s ability

production or distribution chain.

to serve Be-Ge’s delivery requirements at risk,

» Expectation

as well as the risk of data leakage.

Supplier is encouraged to implement a corporate or

» Expectation

group-wide compliance program on fair competition

Supplier is encouraged to implement an information

applicable to all of Supplier’s affiliate organisations.

security management system and cybersecurity guidelines, which includes self-assessment and testing of resistance to internal and external threats; execution

Data privacy

of training internally on cybersecurity; and a mitigation

» Requirement

Supplier is further encouraged to demonstrate

Whenever a Supplier is entrusted with any personal

certification, such as ISO/IEC 27001 or equivalent

data, Supplier shall safeguard it and take appropriate

certification or report.

steps to protect it from misuse. All applicable data privacy laws as well as the contractual terms with Be-Ge shall be observed and complied with when collecting, storing, using, processing, or sharing personal data.

» Expectation Supplier is encouraged to implement a risk-based process to identify threats to privacy, and to act upon any threats or risks identified.

28 Business ethics and compliance

plan in case of cyber-attack or cyber-incident. accreditation with a recognised information security

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Responsible and sustainable development with respect for nature and enviroment

be-ge.se

Be-Ge – Edition EN 1/2025