COMPLETING ARCHITECTURE
CODE OF CONDUCT
FROST A/S Code of Conduct This Code of Conduct outlines the ethical and business standards that FROST expects from its partners. FROST is committed to ensuring that its products are produced under responsible conditions and expects its partners to operate with integrity, fairness, and responsibility. This Code helps FROST select and retain partners who share this commitment, based on internationally agreed conventions and guidelines : The International Bill of Human Rights The International Labour Organization’s (ILO) Declaration of the Fundamental Principles and Rights at Work The UN Guiding Principles on Business and Human Rights The UNICEF Children’s Rights and Business Principles The OECD Guidelines for Multinational Enterprises The OECD Due Diligence Guidance for Responsible Business Conduct The UN Convention Against Corruption The Rio Declaration on Environment and Development and the UN Global Compact’s 10 Principles Partners are expected to implement these standards in their own operations and work with their own partners to do the same.
REQUIREMENTS FOR PARTNERS 1. Human Rights and Labor Conditions •
Non-discrimination and Equal Opportunities: All employees must be treated with dignity and respect, without discrimination based on age, sex, race, religion, origin, sexual orientation, gender identity, or other characteristics. Prohibited practices include abuse, cruel disciplinary measures, and discriminatory medical tests.
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(Reference: ILO Conventions 110, 111, and 159, or the Sixth Principle of the UN Global Compact. Freedom of Association and Collective Bargaining: Partners must respect workers’ rights to join and organize associations and to bargain collectively without interference. If national law restricts these rights, partners must allow workers to elect their own representatives and support alternative forms of worker representation. (Reference: ILO Conventions 87, 98, 135, and 154, or the Third Principle of the UN Global Compact.)
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Forced Labor: The use of forced, bonded, prison, indentured, or compulsory labor, including modern forms of slavery or human trafficking, is strictly prohibited. Workers must not be required to pay fees for employment, nor should personal documents or compensation be withheld. All work must be voluntary, and employees must be able to end their employment at any time. (To support these requirements, disciplinary policies and procedures must be clearly defined and communicated to Workers. This aligns with ILO Conventions 29 and 105, and the Fourth Principle of the UN Global Compact.)
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Child Labor: The use of child labor is prohibited. No person below the applicable minimum legal age (which should be no lower than 15, even if national law permits a lower age) shall be employed. Young workers (15-18) are only permitted to do light work for reduced hours and must be protected from hazardous work, night shifts, or anything that could harm their development.
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Wages and Benefits: Partners must comply with all applicable national and local wage laws, including minimum and overtime wages. Overtime pay must be higher than regular pay. Wages should be sufficient to cover the cost of living and allow for savings. Wage deductions as a disciplinary measure are not allowed, and employees must receive clear, detailed, and regular written information about their pay. (References to ILO Convention 26 and Convention 131)
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Working Hours: Standard working hours must follow local regulations but not exceed 48 hours per week, with a maximum of 12 additional overtime hours. Workers must be free to refuse overtime without fear of punishment. Employees are entitled to a minimum of 1 day off per week, paid annual leave, maternity leave, sick leave, and other types of leave as per local regulations. (Reference: ILO Convention 1 and Convention 14).
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Health and Safety: Partners must ensure a safe and healthy working environment with proper management systems, including a readily available Health and Safety Policy. Key aspects include: •
Safe, healthy, and clean working environments with sufficient lighting.
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Availability of first aid equipment and, where legally required, a doctor or nurse.
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Compliance with fire safety laws, including warning systems, equipment, and marked exits.
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Emergency plans, worker notification, training, and annual drills.
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Safe handling, storage, and disposal of chemicals and hazardous materials.
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Safe electrical installations.
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Provision of free and properly maintained personal protective equipment (PPE), with training on its use.
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Maintenance of hygiene, health, and safety standards in all premises, including dormitories, restrooms, and canteens.
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Access to clean drinking water and sanitary facilities.
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Protection from high temperatures and extreme weather.
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Review of all relevant building safety permits and certificates.
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Measures to protect pregnant and nursing mothers from workplace hazards.
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Systems for preventing, managing, tracking, and reporting occupational injuries and illnesses, including providing medical treatment, investigating cases, and facilitating return to work.
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Identification, evaluation, and control of exposure to physically demanding tasks.
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Evaluation of machinery for safety hazards and provision of physical guards.
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Provision of health and safety information and training in a language workers understand.
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Clear posting of health and safety information and encouragement for workers to raise concerns without retaliation.
2. Anti-corruption and Business Ethics •
Anti-corruption: Partners must not engage in unethical conduct, bribery, kickbacks, or provide improper gifts to gain competitive advantage. A zero-tolerance policy against bribery, corruption, extortion, and embezzlement is required. Partners and their subcontractors must work towards eliminating corruption.
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Compliance with Sanctions, Export Controls, and Other Applicable Laws: Partners must comply with all national and local laws, regulations, and industry standards, including those related to customs, export control, antiboycott, and economic/financial sanctions. Partners must not operate from sanctioned countries or territories, nor transfer products in violation of sanctions. In case of conflict between laws, the higher standard prevails.
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Fair Competition: Partners must observe fair business practices, advertising, and competition, complying with antitrust laws that prohibit agreements influencing prices or limiting customer freedom.
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Privacy/Data Security: Partners must protect private information of FROST, subcontractors, customers, consumers, and workers by complying with data protection and information security laws and regulations.
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Intellectual Property: Partners must respect intellectual property rights and ensure that technology and expertise transfers protect intellectual property and FROST information. Partners should stay informed about changes in intellectual property regulations.
3. Environment (See Appendix A Environmental Policy for further detail) FROST is committed to sound environmental programs and practices and encourages waste reduction and recycling. Partners should have an environmental management system or precautionary action plan to minimize their environmental impact, including an Environmental Commitment stating their CO2-e emissions, measures taken, and reduction targets. Partners must comply with all applicable environmental laws and safely dispose of hazardous materials.
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Hazardous Substances: Partners must adhere to all applicable laws and regulations concerning restricted substances, including labeling, recycling, and disposal. They must also comply with agreedupon, customer-specific, restricted, and hazardous material lists and, if applicable, have their own Manufacturing Restricted Substances List (MRSL). Chemicals posing environmental hazards must be safely handled, stored, recycled, and disposed of. Delivered goods must comply with international standards for chemical content, including EU REACH regulations (Annex XVII and Candidate List), California Proposition 65, and country-specific export market regulations. Local laws must be followed for the storage, handling, use, and disposal of all chemicals, in compliance with Material Safety Data Sheets (MSDS).
4. Animal Welfare If products contain materials derived from animals, partners must ensure animals have been treated according to all applicable regulations, conventions, and standards, with dignity and respect. Animals must not be deliberately harmed or subjected to pain. The taking of animal lives must be quick, least painful, non-traumatic, approved by veterinarians, and conducted by trained personnel. FROST expects partners to follow The Five Animal Freedoms: 1.
Freedom from Hunger and Thirst
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Freedom from Discomfort
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Freedom from Pain, Injury or Disease
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Freedom to express Normal Behaviour
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Freedom from Fear and Distress
5. Grievances Partners are responsible for establishing effective grievance mechanisms for individuals and communities affected by negative impacts. Employees who report violations of this Code or applicable laws must not face disciplinary measures or negative consequences.
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MONITORING AND COLLABORATION FROST has the right to assess its supply chain and may require partners to complete self-assessment questionnaires. FROST may also conduct periodic on-site visits, including unannounced audits, to check working and living conditions, records, and compliance. Partners can object to audit measures that violate mandatory data protection regulations. Partners are expected to have proper due diligence procedures to identify and mitigate risks within their supply chains, in accordance with OECD Due Diligence Guidance (the OECD Due Diligence Guidance for Responsible Business Conduct). In case of a suspected violation or heightened risks, partners must inform FROST promptly about identified violations, risks, and corrective measures.
If a violation is identified, FROST will notify the partner in writing within one month and provide a suitable period to achieve compliance. If the partner violates the Code or related policies, FROST will work to remedy the situation, potentially issuing a warning, requiring corrective action, or terminating the relationship. FROST reserves the right to extraordinary termination and damages if the violation is culpable and continuation of the contract is unacceptable.
COMMUNICATION AND COMPLIANCE Partners must establish and maintain procedures to evaluate and select partners and subcontractors based on their social and environmental accountability. All partners are expected to establish management systems to ensure compliance with applicable laws, regulations, and this Code. Should partners encounter difficulties adhering to FROST’s principles or identify breaches, they must immediately contact their main FROST contact person or report anonymously via email: lk@frost.dk. Partners’ employees can report work-related concerns anonymously and without fear of retaliation via email lk@frost.dk Partners agree to continuously seek ways to advance sustainability and ensure favourable living and working conditions for their employees. By accepting business from FROST, partners acknowledge their agreement and intention to comply with this Code.
By signing this Code, partners commit to responsible conduct, adhering to the principles and requirements, and communicating the content of this Code to workers, contractors, and subcontractors. Signatures are collected during onboarding. This Code may be amended by FROST, with the current version published on the FROST websites. Partners should regularly review for updates. FROST will notify partners of material changes via email with a 30-day review period. Continued engagement after this period signifies acceptance. Non-material changes may be made without notice.
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FROST ENVIRONMENTAL POLICY This COC is supported by the Environmental Policy: FROST is dedicated to minimizing environmental impact throughout our product lifecycle, from raw materials to recycling. We employ a precautionary approach and expect our partners to do the same, focusing on circularity, responsible resource use, and pollution prevention. Key Principles: •
Precautionary Approach & Environmental Management: •
We and our partners must minimize environmental risks, secure necessary permits, and avoid environmental prosecution.
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Partners are encouraged to measure emissions and set reduction targets using recognized tools.
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Partners must provide valid environmental permits and documentation upon request, maintaining current registrations and following operational/reporting requirements.
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Sites must not be under threat of environmental prosecution or fines.
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Critical abatement equipment (e.g., air emission scrubbers) must be operated correctly.
Resource Use & Product Development: •
FROST is committed to mindful design and material choices, using recycled/recyclable materials where feasible and designing for material separation.
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We expect partners to minimize natural resource use (e.g., water, raw materials) and consider environmental impact in product development and sourcing, addressing issues like microplastic release.
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Partners should improve production efficiency, reducing environmental impact and auxiliary volumes.
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Partners must avoid or phase out substances of very high concern to health and safety, providing transition plans if required.
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Partners must lower toxicity in atmospheric and aquatic environments, working with readily degradable materials (e.g., non-hazardous chemicals, enzymes).
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Partners must have measures in place to prevent pollution from their site activities.
Energy, Emissions, Water & Waste: •
Partners must prioritize renewable energy, gradually transitioning from high CO2 fuels, and measure/control energy use.
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Partners must minimize and measure emissions to air, water, and ground (including CO2 from transport and production), providing data upon request.
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Air emissions must be characterized, monitored, controlled, and treated according to national law.
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Partners should reduce transportation impact by prioritizing road, sea, or rail transport and using fuel-efficient vehicles.
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Water use must be minimized through recycling, heat recovery, water-saving equipment, combined processing steps, and low-temperature processes.
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All wastewater must be purified, and sludge treated, before discharge, adhering to national requirements. Wastewater test results must be provided upon request.
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A proper waste management system is required. Waste must be handled by authorized contractors, kept to a minimum, and reused/recycled where possible.
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Waste of all types (including water and energy) must be reduced at the source through practices like modifying processes, material substitution, and conservation.
COMPLIANCE & PARTNERSHIP: FROST conducts due diligence through self-assessments and site visits. If negative impacts are identified, a mitigation plan will be developed, and partners are expected to adopt it. Failure to comply may result in partnership termination.
Hans Jørgen Frost August 2025
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FROST A/S Headquarter & Showroom Bavne Allé 32, DK-8370 Hadsten +45 8761 0032 • info@frost.dk Flagship Showroom Christian IX’s Gade 5, DK-1111 Copenhagen +45 5172 6432 • showroom-cph@frost.dk
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