Code of Conduct

INTRODUCTION

The code of conduct (the “Code”) of Combined Effect AB (559320-9728), (“Combined Effect”), is based on our core values. The Code applies to the entire value chain and illustrates what we expect of our suppliers and business partners. It offers guidance about how we should conduct ourselves in relation to our stakeholders and describes the directives and principles we follow as part of our operations. The Code assumes compliance with legislation and regulations and is based on international standards such as the UN’s Declaration of Human Rights, the principles of the UN Global Compact and the guidelines of the ILO (International Labour Organization), OECD as well as national legislation. Combined Effect is proactive in its efforts to reduce its negative impact on the environment and risks to people’s health and safety. We adhere to the precautionary principle in our work, which means that precautions are taken as soon as there are grounds for suspecting that an activity could harm the environment or people’s health. The Code applies to Combined Effect, its subsidiaries, board members, employees, suppliers, business partners and subcontractors and the Code of Conduct is divided up into the following parts: Human Rights, Health and Safety, Workers’ rights, Environment, Business Ethics, responsibility and implementation.

1. LEGAL REQUIREMENTS

Our general rule is that all our suppliers, developers and other business partners must, in all their activities, follow the national laws in the countries in which they operate. The Code of Conduct is considered the minimum requirement and if local or international law, regulation or rule implies more demanding requirements, such shall apply. In case of conflict between the Code of Conduct and mandatory local laws or regulation, the latter shall prevail.
However, Combined Effect’s requirements may go beyond the requirements set out in national law.

2. HUMAN RIGHTS AND LABOR STANDARD

2.1 No tolerance for child Labour or forced labor

Combined Effect does not accept child labour or any form of modern slavery in our operations or through our value chain. Modern slavery includes forced, bonded or compulsory labor, physical or psychological punishment or human trafficking.
We do not employ anyone younger than 15 years or, if higher, the legally prescribed minimum work age.

2.2 Young Workers

All legal limitations on the employment of persons below the age of 18 years must be followed. We acknowledge that according to the UN Convention on the Rights of the Child, a person is a child until the age of 18. We recognize the rights of every child to be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral or social development.

3. HEALTH AND SAFETY

We require our suppliers and other business partners to support and respect the protection of internationally recognized human rights and adhere to at least the same standards as set out herein, to make employees’ safety a priority at all times.

3.1 Fire Safety

Emergency exits on all floors must be clearly marked, well-lit and unblocked all the way out of the building. Evacuation through emergency exits must always be possible during working hours. Everyone working on the premises must be regularly trained in how to act in case of fire or other emergency. Regular evacuation drills for all employees are required; evacuation plans and firefighting equipment must be in place.

3.2 Accidents and First Aid

Employers must work proactively to avoid accidents causing harm to any employee in the workplace. Relevant first aid equipment must be available and where legally required a doctor or nurse should be available during working hours.

3.3 Working Environment

The premises must be regularly maintained and cleaned and must provide a healthy working environment.
For more information, see our Work Environment policy.

4. WORKERS’ RIGHTS

4.1 Basic Rights

4.1.1 Combined Effect does not accept any forms of forced or bonded labor and we do not accept the use of prison labor or illegal labor in the production of goods or services for Combined Effect.

4.1.3 Every employee shall be treated with respect and dignity. Migrant workers shall have exactly the same entitlements as local employees. Under no circumstances do we accept the use by our suppliers, their subcontractors or other business partners of humiliating or corporal punishment, and no employee shall be subject to physical, sexual, psychological or verbal harassment or abuse.

4.1.3 All employees have the right to form or join associations of their own choosing, and to bargain collectively. Combined Effect does not accept disciplinary or discriminatory actions from the employer against employees who choose to peacefully and lawfully organise or join an association.

4.1.4 No employee shall be discriminated against in employment or occupation on the grounds of sex, race, colour, age, pregnancy, sexual orientation, religion, political opinion, nationality, ethnic origin, disease or disability.

4.1.5 All employees are entitled to a written employment contract, stipulating the employment terms and conditions. The employer has a responsibility to ensure that all employees are aware of their legal rights and obligations.

4.2 Wages, Benefits, Working Hours and Leave

As stated in the Universal Declaration of Human Rights Article 23:3: “Everyone who works has the right to just and favourable remuneration ensuring for himself and his family an existence worthy of human dignity…”:

4.2.1 Wages must be paid regularly, on time, and must reflect the experience, qualifications and performance of the employee. Combined Effect’s minimum requirement is that employers shall pay at least the statutory minimum wage or the prevailing industry wage, whichever is higher. All other types of legally mandated benefits and compensations shall be paid. No unfair deductions are allowed, and the employee has the right to a written specification of how the wage has been calculated.

4.2.2 Ordinary working hours must not exceed the legal limit and shall never exceed 48 hours per week. Overtime hours must not exceed the numbers allowed by the law of the country. If such limits do not exist, overtime work should not exceed 12 hours per week. Overtime work must always be compensated in accordance with the law. Employees are entitled to at least one day off in every seven-day period.

4.2.3 The employees shall be granted and correctly compensated for any types of paid leave to which they are legally entitled. Examples of such leave include annual leave, parental leave and sick leave.

5.ENVIRONMENT

The environment is of increasing concern globally and Combined Effect expects its suppliers and other business partners to act responsibly in this respect. Our suppliers must comply with all applicable environmental laws and regulations in the country of operation.
Combined Effect is committed to combat global warming in our operations. Combined Effect is committed to the Science Based Target 1.5°C ambition and has implemented short and net zero climate targets in line with the SBT Criteria.

5.1 Environmental Permits
Combined Effect must have the relevant environmental permits and licences for its operations.

5.2 Waste Management
Any waste and in particular hazardous waste must be taken care of in a responsible manner and in accordance with local law.

6.BUSINESS ETHICS

6.1 No tolerance for corruption and bribery

Corruption – the abuse of power for personal gain – comes in various forms such as bribery, excessive business entertainment, extortion and conflicts of interest. Combined Effect has zero tolerance for corruption. We never pay bribes or facilitation payments. We do not offer or accept gifts, hospitality or expenses that are improper in value or that could inappropriately affect business decisions.

6.2 No conflicts of interest

A conflict of interest is when a personal, professional or financial interest of an individual employee interferes, or appears to interfere, with the best interests of Combined Effect. Employees of Combined Effect must avoid all conflicts of interest that may impact – or appear to impact – Combined Effect. Business decisions must remain independent from any consideration that does not involve the business at hand and cannot be influenced by private interests.

For more information, see our Conflicts of Interest policy.

6.3 Anti-money laundering and transparency with financial activities

Combined Effect screens and audits business partners in order to reduce the risk of becoming involved in unethical, illegal or criminal activities. Combined Effect is committed to fully comply with applicable anti-money laundering and terrorist financing laws. Combined Effect does not engage in transactions with parties that participate in money laundering or criminal tax evasion. All financial activities should be conducted transparently and recorded accurately.

6.4 Compliance with trade restrictions and sanctions

Combined Effect complies with relevant export controls and sanctions laws and regulations, including United Nations sanctions and applicable sanctions under the laws of the European Union. Combined Effect does not engage with business partners that are the target of any economic sanctions or export control laws.

6.5 Information security and protection of privacy

Combined Effect is committed to high security awareness. Information is considered a critical asset and resource and its incorrectness or unavailability could affect business competitiveness. Information security is therefore vital.

Combined Effect ensures that its IT security arrangements are appropriate to the requirements of the information assets concerned and that it implements appropriate governance and management arrangements to manage risk, monitor compliance and report and respond effectively to any incidents.

Combined Effect values the privacy of employees and other individuals and complies with applicable data protection legislations when processing personal data. In particular, Combined Effect protects personal data from any improper disclosure, theft or misuse at all times.

For more information, see our Data Protection Policy.

6.6 Sustainable tax

Combined Effect has a ‘zero incident’ policy for tax compliance. Combined Effect complies with tax laws and practices where we operate. Combined Effect pays the right amount of tax, in the right place, at the right time.

7. RESPONSIBILITY AND IMPLEMENTATION

Each employee, manager, executive officer and member of the board of directors of Combined Effect must understand and comply with the Code. Managers should ensure that their teams fully understand and are expected to comply with the standards and requirements stipulated in the Code.

Implementation of the Code is ensured through the following activities:

– making the Code of Conduct known in all relevant parts of the organization. The Code should be available on the Company’s website and shall be part of all employees’ onboarding phase;
– organizing general and role-based trainings to management and employees, at a minimum on a yearly basis;
– making a centrally placed employee responsible for the implementation of the Code in the supplier’s business or other business partners;
– having a third-party whistleblower function.

8. REPORTING CONCERNS AND CONSEQUENCES OF VIOLATION

If you become aware of or suspect a possible violation of law, rule, regulation or of a possible violation of this Code of Conduct, or any other of Combined Effect’s policies, you are required to promptly contact the Legal department at: legal@rawfury.com.

You can also raise concerns anonymously through Combined Effect’s or its subsidiaries whistleblowing system. For example, the whistleblowing system of Raw Fury AB is available at: Raw Fury Whistleblower policy_2023.docx. Combined Effect will not tolerate any attempt to take adverse action against an employee for reporting a genuine concern regarding suspected wrongdoings. Retaliation against anyone who speaks up is a violation of the Code and will not be tolerated.

Combined Effect does not tolerate any illegal or unethical behaviour. Violations of the Code is likely to damage Combined Effect’s brand and reputation. Failure to follow the Code is taken seriously and may result in disciplinary action appropriate to the violation, including, but not limited to, termination of the employment.

9. REVIEW AND FOLLOW-UP

Compliance with this Code of Conduct will be monitored through internal and external audits, and routine follow-ups of all reported matters. This Code of Conduct has been approved by the Board of Directors on June 3rd, 2026 and will be reviewed on a yearly basis to ensure compliance with the latest regulations.