Walki Group’s Code of Conduct

We comply with this Code of Conduct in all our business operations in all the countries in which we operate. The Code of Conduct describes the principles our employees follow and the values our company holds and promotes.

Every employee regardless of their position is committed to complying with the Code of Conduct in for example decision making, business development, investnts and subcontracting. We also expect and encourage all our business partners to uphold the principles outlined in this Code and adhere to equivalent ethical standards in their operations. Our Supplier Code of Conduct specifies the parts of the Code that are particularly important for suppliers.

Employees with leadership or managerial responsibilities are subject to additional obligations and must lead by example. These obligations and guidelines for people in leadership roles are called Walki Leadership Principles. They are a set of basic expectations for Walki leaders, how to lead teams and how leaders are also expected to lead themselves to bring out the best of Walki employees and to help each employee perform with their full potential. Walki Leadership Principles emphasize the importance of our shared company values — integrity, initiative, and commitment — to create a unified leadership culture across the organization, and to highlight the need for leaders to continuously develop themselves, foster trust, encourage diversity, and empower teams to take ownership and innovate, all while ensuring employee well-being and sustainable performance.

Walki Group is a member of the United Nations Global Compact (UNGC) and is committed to aligning our operations with its ten universally accepted principles relating to human rights, labour, environment and anti-corruption. This membership reinforces our dedication to responsible business practices, environmental stewardship, sustainable development and continuous improvement across our operations and value chain.

Compliance

All our employees are expected to consistently comply with all applicable laws and regulations. We follow international standards, such as the Universal Declaration of Human Rights and Core Conventions of the International Labor Organization. All employees are expected to show professionalism, adhere to the good practices of business, and demonstrate environmental and social responsibility. All employees are expected to act in the company’s best interest.

All our business partners are required to comply with the law. We do not condone any breach of law or condone being complicit in any breach of law. We attempt to always interact directly with our suppliers without the involvement of third-party agents or other third parties. We value long-lasting partnerships with our suppliers, business partners and customers.

Violations of the Code or Company policies may result in serious consequences for both the Company and the individuals involved. For these reasons, failure to comply with the Code may lead to disciplinary action, including termination of the employment in accordance with applicable local laws.

Bribery and anti-corruption

We do not accept any form of bribery or corruption. All our employees are expected to comply with all applicable laws and regulations in relation to anti-corruption and bribery. We promise not to pay bribes or make any other form of illegal payments or give benefits to authorities or anyone else directly or indirectly – through a third party acting on Walki’s behalf. We do not advise or incite anyone to offer or accept them either.

We do not tolerate any form of money laundering. All our employees are expected to comply with all laws and regulations in relation to money-laundering, terrorist financing and any other illegal activities as well as applicable sanctions regulations including, but not limited to, those enacted by the European Union, United States, and international organizations as well as local jurisdictions in which Walki conducts business.

Economic sanctions

We are committed to compliance with applicable sanctions regulations in all countries where we do business. All employees are responsible for understanding their obligations under the Walki Sanctions Compliance policies, and all business partners must comply with applicable restrictions.

Human rights

We are committed to respecting internationally recognized human rights. We do not tolerate human rights violations in any form. We require that all of our partners also respect all internationally recognized human rights.

We do not tolerate discrimination or harassment. We treat our employees with dignity and treat everyone equally in recruitment, opportunities, compensation, career progress and termination. We treat all our employees equally regardless of for example, but not limited to race, gender, colour, religion, sexual orientation, ethnicity, national origin, age or physical ability. Bullying, sexual harassment of any kind and any other form of in-appropriate behavior is not tolerated.

We do not tolerate or accept any form of human trafficking or modern slavery. Our employees working with transport are required to ensure that human trafficking does not occur during transportation of products.

Labor rights

We focus on the safety of all our employees. We work to protect and prevent accidents, illnesses and work- related injuries and to ensure the health and safety of all our employees, subcontractors and other visitors at Walki premises. We promote wellbeing and a wellbeing work environment for our employees.

We acknowledge that people are our asset, and we are committed to providing our employees with good working conditions and supporting their well-being at work and work-life balance. We treat our employees equally and comply with applicable labour laws. We comply with the ILO Declaration on Fundamental Principles and Rights and ILO Core Conventions. We always comply with local work legislation and local collective labour agreements.

We respect our employees’ freedom of association, collective bargaining and the right to form trade unions. We always follow in relation to working hours, wages, benefits and overtime compensation national legislation and applicable collective agreements. We are committed to providing our employees fair wages and reasonable working hours. Part-time employees and external workers are treated with same standards and respect as permanent full-time employees.

We respect human and labour rights and do not accept any form of child labour, bonded labour or forced labour.

Fair competition

We do not take part in activities that negatively affect or in any way restrict fair competition. We comply with all applicable competition laws. We do not accept any illegal or restricting business methods.

Our employees are required to inform without delay of any condition which could be or could be perceived as a conflict of interest. Conflict of interests can also include, but not limited to, personal benefits and benefits to the person’s family. Employees shall not seek personal gain, nor assist others to profit, from opportunities that are discovered through the use of corporate property, information and position.

Commitments on behalf of Walki where an employee has an actual or potential conflict of interest, for example due to close personal relationships, must be referred to an employee’s superior for approval.

Gifts and hospitality

Any personal gifts or hospitality must be considered of little value and common. Accepting or giving a gift or hospitality cannot lead to any kind of relationship with dependency between the parties. We comply with all laws and standards issued on giving and accepting gifts and applicable standards are assessed in accordance with the legal requirements of each jurisdiction.

All donations to charities and other non-governmental organizations are decided by the Walki Group Executive Team. We do not make any donations in cash. We do not support any political parties.

We respect our company’s assets and use these assets with care and only for legitimate business and authorized purposes.

Confidentiality

We comply with the strictest rules, applicable regulation and best practices of confidentiality and privacy. All our employees handle all confidential information with the highest level of confidentiality. We ensure that confidential information is not passed on to third parties.

Personal data

Personal data and personal information are strictly confidential information. We comply with the General Data Protection Regulation (GDPR) and all other applicable national/sectorial laws in relation to processing of personal data.

We only collect, process and store personal data for lawful and approved business purposes. The amount of collected personal data must be limited only to the amount necessary with regard to the purpose of the processing. Processed and collected personal data must be kept updated. Personal data must be processed in Walki’s official IT systems and registries with appropriate safeguards. Due to its confidentiality personal data may not be disclosed without lawful justification.

Use of artificial intelligence

We comply with EU AI Act regarding the use of Artificial Intelligence. AI must be used responsibly with safe, secure, humane and environmentally friendly approach. Walki retains of using AI systems with Prohibited/Unacceptable risk according to EU AI Act. It is allowed to use AI systems with High risk, Limited risk or Minimal/No Risk if the appropriate safeguards set in place.

Quality

We are committed to providing safe, functional, and high-quality material solutions that meet and exceed the requirements of our customers. We strive to manufacture products in full compliance with applicable standards and requirements, supported by comprehensive internal and external testing. Our development activities are based on customized innovations. We work closely with our customers and suppliers to ensure the safety, functionality, quality and continuous improvement of our products. Walki Group plants producing food-related products maintain robust systems to ensure compliance with all applicable food safety standards.

Environment

We comply with applicable environmental and product regulations and remain mindful of the impacts of our operations and products on the environment, climate, natural resources, biodiversity, ecosystems and communities. We are committed to advancing a circular, resource-efficient, and low-carbon future by transforming materials and creating solutions that extend the life of resources, minimize waste, and help reduce carbon footprints.

In product development and innovation, we apply life cycle thinking to minimize negative environmental impacts and maximize positive outcomes—such as reducing waste through functional packaging and improving building energy efficiency—considering the impacts from raw material sourcing to end-of-life.

We operate with a strong focus on resource efficiency—optimizing the use of raw materials, energy, and water—while continuously reducing emissions, waste, and our overall carbon footprint.

We are committed to responsible use of water. We actively monitor water consumption, implement efficiency measures, and strive to minimize water-related impacts on local communities and ecosystems—prioritizing actions in areas facing water stress.

We source fibre-based raw materials originating from responsibly managed forests, prioritizing recycled and FSC®/PEFC-certified materials. We work to ensure that our activities do not contribute to deforestation.
All our employees share responsibility for considering key environmental impacts in their daily tasks and decision.

Implementation

All employees are responsible for acting in compliance with this Code of Conduct. All Walki employees are responsible for reporting immediately any suspected or detected grievances and violations of this Code of Conduct. Reporting can be made confidentially and anonymously through the Walki whistleblowing service at the address: https://walki.integrityline.com.

Suspected violations of the Code are investigated and resolved by Walki Corporate Responsibility Committee.

If you have questions about any aspects of the Code, you should seek help or advice from your supervisor, any member of the management team, your HR representative or compliance organization (compliance@walki.com).

This Code of Conduct is reviewed annually by Walki Sustainability Steering Committee, with updates made as needed and subject to approval by the Board of Walki Group.