HR Policy

HR POLICY ADOPTED 2023-06-30 Revised 2025-07-04

The Board of Directors of Earl Holding III AB (reg. no. 559032-9339) (the “Company” ) has on 2025-07-04 adopted this HR Policy to govern the Company’s strategic Human Resources governance.

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1. Background and purpose Eton strives to be at the forefront of employee development and to be an environment where each employees’ potential is maximized. Eton operates globally, under different local conditions, and this Policy is a tool, designed to harmonize the strategic Human Resources efforts of the Group, ensuring that Eton’s values remain at the core of the Human Resources Governance.

The purpose of this Policy is to lay down the overall framework for the Group’s Human Resources Governance and to provide guidance to leaders and managers in relation to recruitment and onboarding, organizational and individual development, compensation and benefits and equal treatment.

2. Policy statement 2.1 Recruitment and onboarding One Eton, Empowering, Work Smart, Quality-Driven, Customer-Committed and Progressive are Eton’s core values, they stand at the center of Eton’s strategic HR work.

Eton is always looking to recruit personnel that are in line with Eton values. Employees that put excellent quality in everything they do, that are committed to Eton’s customers and their colleagues and that are progressive and strive for continuous improvements.

Eton promotes internal career advancement as a first way of recruiting and a way of keeping and acknowledging talent within the company. Eton encourage employees to attend training programs and provides opportunities for internal recruitment, internal transfers and job rotation within the Group.

Onboarding employees is a vital step to ensure that employees feel welcome, understand Eton’s values and are able to start performing their duties in an efficient manner. The onboarding tool used at Eton is digital and contains articles, assessments, quiz and policies. The process of onboarding starts before the employee’s first day of work and continues for approximately two months.

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Includes all subsidiaries of the company group in which Earl Holding III AB is the parent company.

2.2 Organizational and individual development Eton’s management team regularly attends trainings and development programs in order to enhance their management skills and culture.

Eton also trains and help mid-level management develop their leadership skills by internal trainings through it’s digital onboarding and training tool.

Eton applies a set structure for formal employee dialogue. The structure contains one meeting before end of Q2 and is supported by standardized documentation. All Eton employees are entitled, and expect, to have a Performance & Development Plan with individual result and competence goals and activities together with short- and long-term development activities. To help set these goals and activities the competence model along with the role description should be applied.

Eton believes that the most important competence development happens “on-the- job”, and continuous follow up and feedback to supplement the formal performance and competence development process. All Eton managers are accountable to provide ongoing feedback to their employees, as well as required on the job training and coaching to ensure ongoing improvement and development. Individual employees are responsible to broaden and deepen their skills within their respective are of profession, to secure their own career development and ensure Eton’s leadership in the market. Eton also provides individual training when identifying that employees need inspiration, development or when there is a gap towards the individual’s role and function at Eton.

2.3 Compensation and benefits Eton is committed to provide a fair and transparent compensation and benefit scheme to all employees, regardless of full time or part time work.

Individual employees go through a yearly compensation and benefits revision. In some jurisdictions this is either regulated by law or by collective bargaining agreements. The evaluation is based partly on last year’s performance of the individual and partly on adherence to company values.

If the need arises to adjust an employee’s remuneration outside of the yearly revision that is done by an adjustment of the employee’s individual compensation and benefit scheme. Such an adjustment requires the approval of the CEO.

2.4 Equal treatment Being a company operating in a global market, Eton sees diversity and mutual trust and respect in the working environment not only as an imperative, but as a source of competitive advantage. Eton therefore operate its business with consideration to respect, human rights, safety and health, and to the environment.

At Eton, equal opportunities apply irrespective of gender, gender identity and expression, sexual orientation, ethnical background, religious beliefs, disability or age. Everyone who works at Eton shall feel welcome and safe. Employment and development opportunities must always be based on competence, experience and ability to perform according to Eton’s core values and high quality customer service.

Discrimination or harassment based on gender, ethnicity, religion or other belief, sexual orientation, gender identity or expression, disability or age is not accepted at Eton. All forms of discrimination and harassment is investigated, appropriately handled and followed-up upon.

Eton actively works towards equal treatment of all employees, regardless of full time or part time work as well as regardless of temporary or permanent employment.

Everyone working for Eton, in particularly those in a management position, has a responsibility in the daily work to ensure compliance to these commitments.

Eton actively tries to maintain gender diversity in the workplace. Pay gaps between the genders are investigated yearly and any discrepancies addressed.

2.5 Work Environment, Health and Safety Eton is committed to ensure occupational safety and health (OSH) of all Eton employees in every aspect related to the work. Eton applies ongoing risk assessment of all aspects of work including: • • •

what could cause injury or harm, whether the hazards could be eliminated and, if not, what preventive or protective measures are, or should be, in place to control the risks.

Health and safety issues are treated with openness and care. Risks are identified and analyzed, and when necessary, measures shall be taken immediately to correct any OSH risks.

Managers have responsibility for ensuring the well-being of the employees, including a reasonable workload in compliance with labor laws. Employees are expected to take responsibility for health and safety in their daily work and work to continuously improve the working environment. This entails to follow instructions and procedures, and to be aware of and report potential risks and threats to maintain a healthy work environment.

An employee survey is conducted once a year in order to examine overall employee engagement and satisfaction, including a number of key OSH dimensions. The results visualize the development areas for each unit and the company in general. Each manager is then responsible for following-up the performance of their department and together with the employees to establish an action plan for the coming year. The result of company-wide issues is addressed by the management team.

Eton has adopted a Work Environment Handbook where this procedure is more closely regulated.

2.6 Personnel Data Protection Eton is accountable to ensure compliance with laws with regard to the processing of employee data. This includes • • • •

Ensuring that all processing of personal data is minimized to what is business critical Consent must be obtained from the employee, where applicable.

Before processing of employee data, the employee must be informed about what information is processed, what it is used for, and how to modify or correct the information.

Transfers to third parties, including publication on the Internet, is allowed only according to the above and when adequate protection is in place

For more in detail, Eton has adopted a Procedure regulating Privacy and Data Protection.

2.7 Employee separation and discharge Eton works in close cooperation with unions and workers councils to manage separation and termination in accordance with local employment protection laws in all operating countries.

The responsible manager is accountable to ensure that: •

Eton’s HR process for end employment is used and followed in accordance with local and regional law.

• • • • •

All physical property belonging to the company is returned.

Access to company premises, network and systems are removed.

All critical data and files relating to the employee’s work is retained and that such material or other intellectual property do not leave the company when the employee is terminated Work assignments and knowledge is being transferred Exit interview is conducted in the case of employee separation

2.8 Community Engagement Eton actively encourage employees to volunteer twice per year with the purpose to: • •

Provide employees time off to support volunteer activities that enhance and serve the communities in which employees live and work Provide employees time off to support volunteer activities that impact quality of life, including any sustainability or diversity & inclusion initiative.

The goal of Eton’s Volunteer Program is to create community engagement opportunities for Eton employees that are meaningful, purposeful and helps those in need. At the same time, Eton recognizes that participating in these activities will also enrich and inspire the lives of our employees. ‘Community’ is not defined as just local community, but can include a global perspective, e.g. diversity, inclusion, environmental or other sustainability perspective. Any and all volunteer activites should always be in line with the values listed above.

3. Relevant Entity/BU This Policy applies Group wide to all BU/Entities.

4. Roles and responsibilities The Board of Directors is the approver of this Policy.

The Group CEO is the owner of this Policy.

The Group CEO shall be responsible for strategic Human Resources Governance and together with the HR team be responsible for implementation of the guidelines set out in this Policy.

5. Exceptions There are no exceptions to this Policy. Any need for exceptions to this policy must be clearly defined and documented. All exceptions shall be approved by the Board of Directors.

6. Monitoring of compliance Compliance of this Policy is monitored by the HR Team and by undertaking work place surveys aimed at employee dialogue.

This Policy is reviewed at need, for example due to feedback from employee dialogue.

7. References Eton’s Work Environment Handbook Eton’s Privacy Procedure