Introduction

Bravedo’s Ethical Business Principles support our values and strategic objectives. Responsible business practices, sustainable development and good governance form the foundation of our success. These principles establish shared standards that guide our operations both within the Group and in collaboration with partners and suppliers.

Bravedo complies with all applicable international and national laws and regulations in the countries where it operates, including securities market, competition, consumer, marketing, product liability, labour, environmental, privacy, and equality legislation.

The Group’s activities are guided by international agreements and recommendations, such as:

• The UN Universal Declaration of Human Rights and the Convention on the Rights of the Child

• The UN Convention against Corruption

• ILO Declaration on Fundamental Principles and Rights at Work

• OECD Guidelines for Multinational Enterprises

• EU and UN sanctions as well as other international sanction frameworks

Commitment to Ethical Principles

These principles apply to the entire Bravedo Group, including subsidiaries and business areas. All Bravedo subsidiaries and employees are committed to adhering to these principles. The same requirements apply to partners and subcontractors. Suppliers commit to a separate Bravedo Supplier Code of Conduct, the acceptance of which is a prerequisite for cooperation.

We encourage subsidiaries to create more detailed principles suited to their specific operations, provided they support local business needs and complement the Group guidelines. They must not conflict with Bravedo’s overarching principles.

Accessibility of the Principles

Bravedo’s Ethical Business Principles are available in Finnish and English on the Group’s website. The policy is reviewed annually and updated when necessary to reflect current practices and legal requirements.

Stakeholder Consultation and Involvement

The principles have been prepared in consultation with Bravedo’s Sustainability Committee, which includes representatives from subsidiaries and personnel. Bravedo has also conducted a double materiality assessment, involving key stakeholders — employees, customers and suppliers. The assessment results have informed the content of these principles.

Implementation and Oversight

The Bravedo Oy Steering Group has approved these principles and oversees their implementation at Group level. Each subsidiary is responsible for appointing a person accountable for ensuring implementation and reporting to its board when necessary.

Roles and Responsibilities under the Policy

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ETHICAL BUSINESS PRINCIPLES

Compliance with Laws and Regulations

Bravedo is committed to acting responsibly and transparently at all levels of its operations. We train our employees and monitor regulatory developments to anticipate and manage risks. When areas for improvement are identified, we act promptly and responsibly.

We report on our impacts and progress toward our responsibility goals as part of the Group’s sustainability reporting in accordance with CSRD requirements.

Anti-Corruption and Anti-Bribery Principles

We promote fair and transparent business practices through internal guidelines, training and ongoing monitoring. Our aim is to strengthen trust, ethical culture and openness across all stakeholder groups.

Bravedo does not tolerate bribery, corruption or unethical behaviour in any form. This includes offering, promising, giving or receiving improper payments or advantages to gain business benefits. We work proactively to prevent such risks by training personnel and monitoring our operating environment.

Responsibility for People

Bravedo provides a safe, fair and supportive working environment. Key priorities include improving working conditions, ensuring non-discrimination and equality, and fostering employee development. We work to prevent discrimination, harassment and inhumane working conditions by continuously improving our practices and listening to employees regularly.

Bravedo respects human rights and expects the same from all partners and suppliers. We follow international human rights principles and ILO conventions. More detailed actions and assessment practices are described in our separate Human Rights Policy [link].

Further personnel-related guidelines and practices are detailed in our HR Policy [link], supporting a fair and inclusive work environment and employee development.

Environmental Responsibility

Bravedo is committed to environmental responsibility by reducing emissions and resource consumption and by continuously improving sustainable operating practices. We regularly assess environmental impacts and set clear reduction targets. In exceptional situations, we respond promptly and mitigate impacts when necessary.

We develop innovative solutions that support environmental well-being and resource efficiency. We require subsidiaries to perform emissions accounting and report results, which inform Group-level target setting and continuous improvement. More detailed practices are outlined in our Environmental Policy [link].

Data Protection and Information Security

Bravedo processes personal data and confidential information carefully and in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR). We train employees on data protection practices and require partners to follow equivalent principles.

Information security is a core part of our operations, and we continuously improve our processes to safeguard data. Further information is available in the Group’s Data Protection Policy [link].

Ethical Conduct in the Supply Chain

Bravedo expects suppliers and their subcontractors to follow responsible and ethical practices throughout the supply chain. In procurement managed by the Group’s procurement team, suppliers must accept Bravedo’s Supplier Code of Conduct already at the tender stage; acceptance is a prerequisite for cooperation. Our aim is to gradually extend this practice across all Group procurement.

We assess and, when needed, audit suppliers’ responsibility practices during procurement and throughout the collaboration. If unethical conduct is identified, we take corrective action together with the supplier or terminate the partnership.

We seek to strengthen positive environmental, social and societal impacts within the supply chain and encourage suppliers to continually improve their sustainability performance. Suppliers must be able to demonstrate compliance with applicable laws and Bravedo’s Supplier Code of Conduct requirements, including environmental responsibility, human rights, working conditions, health and safety, data protection and anti-corruption.

Reporting Concerns and Contact Information

Internal reporting:
All employees are required to report potential misconduct either to their manager, another appropriate internal party, or through Bravedo’s Whistleblowing Channel. The channel ensures independent and confidential handling of reports in accordance with Directive (EU) 2019/1937.

External reporting:
External stakeholders may submit reports through the electronic reporting channel of the Office of the Chancellor of Justice.

More information on the handling of reports is available in Bravedo’s Whistleblowing Privacy Notice.

For questions or development suggestions regarding these principles, please contact:

Anna-Maria La Fiura
Director, Communications & Sustainability, Bravedo
anna-maria.lafiura@bravedo.fi

Bravedo Oy’s Steering Group approved this policy in October 2025.