Code of Conduct

At Klappir, we believe that sustainability, transparency, and integrity are essential to creating a positive and lasting impact for our company, our communities, and the planet.

This Code of Conduct defines the values, ethical standards, and professional behaviors expected from everyone representing Klappir, including employees, management, contractors, and board members. Our commitment to doing business the right way extends to our customers, partners, suppliers, communities, and the environment. This Code serves as a guiding framework to help us make decisions, act with integrity, and build lasting trust.

See Klappir Annual Report

2.1 Customers

• We deliver services and products that are reliable, innovative, and sustainable.
• We treat customers professionally, fairly, and with respect.
• We protect customer information and confidentiality at all times.
• We communicate transparently and set realistic expectations.

2.2 Partners and Suppliers

• We build partnerships based on trust, fairness, and shared commitment to ethical and sustainable practices.
• We expect our partners and suppliers to uphold high standards of business ethics, human rights, and environmental responsibility.
• We collaborate openly, respecting intellectual property, brand reputation, and contractual obligations.

2.3 Workforce (Employees and Contractors)

• We foster an inclusive, diverse, and respectful workplace where everyone has the opportunity to grow and succeed.
• We maintain a workplace free from discrimination, harassment, bullying, and retaliation.
• We respect human rights, promote well-being, and support professional development.
• We encourage open communication and collective problem-solving.

2.4 Communities and the Environment

• We aim to create positive social and environmental impacts in the communities where we operate.
• We minimize our own environmental footprint and support the transition to a low-carbon, circular economy.
• We engage responsibly with local stakeholders and public authorities.

• Honesty and Integrity:

Klappir upholds a zero-tolerance approach to bribery, fraud, and unethical conduct. Our Anti-Corruption and Ethical Business Conduct Policy applies to all employees, contractors, and partners, and aligns with Icelandic and international laws. We prohibit offering, soliciting, or accepting bribes, kickbacks, or undue advantages in any form. Modest gifts or hospitality may be permitted only when transparent and lawful. Employees are required to avoid conflicts of interest and report them promptly.

All third-party relationships must reflect our ethical standards, and we may conduct due diligence or audits. Accurate record-keeping is essential, and violations may result in disciplinary or legal action. Whistleblowers are protected under EU directives. Regular training ensures all staff understand and uphold our integrity-focused culture. Ethical conduct is foundational to Klappir’s ESG leadership and reputation.

• Confidentiality and Data Protection:

We safeguard all confidential and personal information in compliance with GDPR and other applicable data protection laws.

• Fair Competition:

We compete honestly and fairly and respect antitrust and competition laws.

• Anti-Discrimination:

We promote equal opportunity and prohibit discrimination based on race, age, sex, disability, religion, nationality and sexual orientation.

• Respect for Intellectual Property:

We respect and protect the intellectual property of Klappir, our partners, and our customers.

• Environmental Responsibility:

We work to prevent pollution, reduce waste, and act in ways that protect and sustain the environment.

Klappir encourages all individuals to speak up if they witness or suspect unethical behavior, misconduct, or violations of this Code. Whereas Klappir´s employees are less than 50, the company is not required to have “Rules on protection of whistleblowers”. However, Klappir has written the rules. No one will face retaliation for raising concerns in good faith.

Reports can be made to:

• Direct managers
• Klappir’s Sustainability Leader
• Designated Ethics Contact Point (when established)

All reports will be handled confidentially and investigated appropriately.

Adhering to this Code is the condition of working with or for Klappir. The Code of Conduct is introduced to new employees in the Onboarding process and is accessible on the homepage and in the Workforce handbook.

Violations may result in disciplinary action, including termination of employment or contract, and/or legal action if necessary. All employees, contractors, and representatives must read, understand, and comply with the Klappir Code of Conduct. We are all responsible for protecting Klappir’s reputation, values, and future.

Stakeholder: Board of Directors

Responsibility: Overall responsibility for the Code of Conduct, ensuring alignment with Klappir’s strategic goals.

Stakeholder: Sustainability Leader

Responsibility: Day-to-day implementation, monitoring the integration of the policy into all operations. Responsible for ensuring that the audit is carried out.

Stakeholder: All Employees and Contractors

Responsibility: All employees and managers must familiarize themselves with the Code of Conduct policy and follow its rules and procedures and are encouraged to submit suggestions for improvement.

The Code of Conduct is reviewed annually, or more frequently, if necessary, to ensure it remains aligned with Klappir’s goals and operational needs.

The Code of Conduct is published on Klappir’s website and included in the Workforce Handbook for accessibility and awareness.

This policy is approved by the board of directors.

Code of Conduct

Version: 01 New. Pol.

Changed by: Hildur Jónsdóttir (HJ)

Date: 15.05.2025

Changes made in this version: First version of Policy