Sectra Code of Conduct

Sectra conducts global businesses, with its principal exposure to countries in Europe and North America. Our work on increasing our market shares and winning the loyalty of new customers cannot jeopardize our ethical behavior and responsibility. The company’s model for working with customers, distributors, sub-suppliers and strategic partners is based on responsibility, transparency and knowledge sharing. We endeavor to build long-lasting relationships since these give us the time to develop both an understanding of each other’s values as well as mutual respect. These close, long-term partnerships play a very important role in Sectra’s success.

Sectra’s Board has established a Code of Conduct, see below, that describes the values and fundamental principles that apply to Board members, managers and employees as well as external parties such as sub-suppliers, consultants, distributors and partners. When it comes to external parties, this is regulated through the terms of agreement or (in the case of large companies over which we have only a minor influence) in the choice of partner. The Code of Conduct is included in all distribution agreements, for example, and Sectra is entitled to terminate its business relationships at short notice if the Code is not followed. Should this happen however, ongoing service agreements could be transferred to a new partner or the agreement itself could be taken over by Sectra, making it clear to the counterparty in question that Sectra treats such breaches with the utmost seriousness. There is a follow-up every year, which can lead to a more detailed review as needed. Reviewing external partners is part of the annual management review, and is regulated in Sectra’s management system. In addition, regulatory audits are conducted regularly via a selection in accordance with procedures in the management system.

The Code of Conduct

Sectra AB is committed to conducting its affairs ethically and lawfully. This Code of Conduct of Sectra establishes policies that are intended to guide employees, managers and directors in the performance of their duties and responsibilities and ensure compliance with the Company’s commitment to ethical and lawful conduct. The Code of Conduct apply to all employees and managers (referred to collectively hereafter as “employees”) and directors of Sectra AB and its domestic and foreign subsidiaries.

Policies

1. Compliance with Laws

The Company will conduct its business and affairs in compliance with all laws, rules, and regulations and in accordance with the Company’s high ethical standards.

2. Work Environment

The Company will maintain a safe and drug-free work place that is free from discrimination and harassment based on race, color, creed, religion, sex, age, disability, national origin, ancestry, citizenship, armed forces service, marital or veteran status, sexual orientation, or any other impermissible factor.

3. Manufacturing Products

The Company is committed to producing products that are safe and effective. In developing and manufacturing medical devices and other products, the Company has established and will comply with standards that meet regulations set by the laws and regulations of the country of development and manufacture. In manufacturing its products, the Company will comply with all applicable laws and regulations, including those relating to the environment and occupational health and safety. When purchasing from or using sub-contractors Sectra AB and its subsidiaries must take reasonable precautions to secure that its sub-contractors adhere to good working conditions according to local standards in the country in question.

4. Competitive Practices

The Company will compete for all business opportunities vigorously, fairly, ethically, and legally. The Company will comply with all antitrust and other laws regulating competition and trade in each country where it conducts business and will not discuss pricing, cost, production plans, business strategies, or any other proprietary or confidential information with its competitors.

5. Marketing and Sales

The Company will represent its products and services accurately and will comply with applicable regulatory and legal requirements governing the marketing and sale of its products and services.

6. Recording and Reporting Information

In recognition of the fact that accurate information is essential to the Company’s ability to satisfy legal and regulatory obligations, all employees and directors will record and report all information accurately and honestly. No employee or director will sign or submit, or permit others to sign or submit on behalf of the Company, any document or statement that he or she knows or has reason to believe is false.

7. Payments

The Company and its employees and directors will not make any improper payments to government or non-government officials, employees, customers, persons, or entities, nor will the Company or its employees and directors request or accept any improper payment from suppliers, customers, or anyone seeking to do business with the Company.

8. Confidential Information

No employee or director will use, for his or her own personal gain, or disclose to any third party, any confidential or proprietary information that he or she obtained as a result of his or her employment with or relationship to the Company. Confidential or proprietary information includes all non-public information that might be of use to competitors or harmful to the Company and its customers if disclosed. No employee or director will buy, sell, or deal in the Company’s stock based on non-public information.

9. Corporate Opportunities

Employees and directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises. Employees and directors are prohibited from (a) taking for themselves personally opportunities that are discovered through the use of corporate property, information, or position, (b) using corporate property, information, or position for personal gain, or (c) competing with the Company.

10. Conflicts of Interest

No employee or director will engage in any activity or have any outside interest that might deprive the Company of his or her loyalty, interfere with the satisfactory performance of his or her duties, and make it difficult to perform his or her duties for the Company objectively and effectively, or be harmful or detrimental to the Company.

11. Protection and Proper Use of Company Assets

Theft, carelessness, and waste have a direct impact on the Company’s profitability. All employees and directors will take appropriate actions to protect the Company’s assets and ensure their efficient use for legitimate business purposes.

12. Usage of social media

Each employee is responsible for his or her use of social media, for any content that he or she posts and for the consequences thereof. The employee must only provide content that he or she is comfortable sharing with others under these terms. Statements in the name of the Company must not be made as a private person unless the employee has a special assignment from the Company. The employee as a person will always easily be more or less associated with the employer, the employee must be aware of how he or she expresses him/herself when posting information in any contexts, even outside of working hours. Please always be clear that you don’t speak on behalf of your employer.

Compliance

The President or executive in charge of each division, subsidiary, or operating unit is responsible for ensuring that his or her employees understand and comply with this Code of Conduct and for creating a work environment in which compliance is expected and rewarded.

Any violation of these policies and procedures should be reported immediately to the President or executive in charge of the applicable unit. The Company will promptly investigate any alleged violation of these policies; breaches will result in disciplinary action.