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DECEUNINCK CODE OF CONDUCT

As the entrepreneur of the Deceuninck group, we are determined to construct sustainable houses for our people and customers. We deeply believe that it is possible to deliver this sustainability if we adhere to our principles and allow our basic values to direct our actions. Our behavior is the window of the company which we open to the outside world. If forced to make a choice, we will respect the following order: People, Earth, Quality, Service and Profit.

By adhering to this principle, we may encounter a situation which does not clearly define the way forward. In this case, we may make use of the following guidelines:

*OUR BASIC VALUES;
Is this action consistent with our basic values?
*SUSTAINABLE
What do these leading principles mean?
*PRINCIPLES
*PEOPLE
Does this action protect the reputation of Deceuninck?
*PERMANENT RELATIONSHIPS

These four factors of our Code of Conduct form the ethical framework that we base on for our decisions. We expect every person employed within Deceuninck to act in compliance with the principles indicated in this Code of Conduct. If you did not understand these factors or you are not sure to apply them, you should consult your managers to get answers for your questions. No action against this Code of Conduct is tolerable and such actions should be communicated to the respective member of the Management Team Group or the compliance officer with no fear for retaliation. Deceuninck never allows any discrimination or retaliation due to the communication of an illegal or unethical action in good faith. Any breach of the Code of Conduct may result in serious consequences such as disciplinary actions or even cancellation of employment contract.

OUR BASIC VALUES;

OPENNESS
• We simply tell the truth.
• We tell it like it is.
• We respect colleagues while providing valid and efficient feedbacks. We act as a team.
• We honestly accept our mistakes or take corrective and preventive actions while communicating bad news.
• We say what we mean and, we mean what we say; this what we are.

HIGH PERFORMANCE
• Our performance is measured by the society, people, customers and shareholders.
• We constantly make efforts while protecting our basic objectives and values.
• We say what we have done and, we do what we have said; this is how we are reliable and disciplined.

ENTREPRENEURSHİP
• We are open to the world and other opinions. We refuse all the borders and makes efforts for innovation.
• We take risks and initiatives well calculated when we are trusted.
• We think as an owner, we make decisions and assume the consequences.

DECEUNINCK SUSTAINABILITY PRINCIPLES

It is not practical to define detailed main principles for each incidence that may occur within the management of our global business. Alternatively, the basic principles that form the framework in which all possible problems that may occur in any country could be analyzed.
We are honest, loyal, righteous, equalitarian, courteous, reputable, straight, reliable and sensitive in the relationships with our customers, suppliers and employees.

• Any action involving theft, fraud, corruption or abuse and misappropriation are strictly prohibited.
• We make our business decisions honestly and righteously based on unbiased factors: People, earth, quality, service and profit. We can never accept or offer any cash if an expectation is implied in return for a favor, and we shouldn’t accept or offer any gift, favor or entertainment. It is prohibited to give bribes or make improper payments to government officials, civil servants or others.
• We will keep the business records in such a manner that will accurately reflect the nature of our trading operations.
• We will provide innovative and sustainable building products and, ensure that these products are safe. The design, manufacturing and maintenance of the products should be carried out in accordance with the standards of Deceuninck and, pursuant to the obligations arising from the applicable regulations and agreements.
• We should comply with all applicable laws, rules and regulations in all countries and, communicate doubtful breaches. We are committed to not only doing whatever is expected from an entrepreneur but also fulfilling the requirements of the applicable laws. We expect our business partners to act in the same manner.
• We never deliberately help any third party to breach any law of any country by means of forging a document or otherwise.
• We perform our duties by using the authority fairly and equally.

PEOPLE
We should respect the unique character and contribution of each employee. We should be sensitive, respectful and fair to each other, which is the foundation of a good business. We behave appropriately towards each other.

• We respect cultural differences. Diversity of people and opinions is a business advantage of a company.
• Equal opportunity: we never discriminate based on age, race, color, religion, gender, disability, origin, sexual orientation for any employee or others with whom we work. Recruitment, remuneration, working conditions, training, promotion and career development of our employees are based on only their professional skills.
• Mobbing and Violence: mobbing and violence are strictly forbidden and, never tolerated. Unwelcome flirts, improper comments and jokes, suppression, bullying or physical contacts or similar undesirable or annoying situations or behaviors that create a hostile environment are defined as mobbing.
• Safety and Health: we are committed to creating a safe and healthy workplace and, attaching importance to the company and the environment. Each of us should be responsible for observing the applicable safety and health rules relating what we do at the workplace. All of us are required to take measures to protect us and our colleagues from accidents, injuries or dangerous situations. Further, each of us needs to communicate dangerous or unhealthy conditions and take immediate take action to correct them.

PERMANENT RELATIONSHIPS
We avoid any conflict of interest. Business decisions and actions taken on behalf of our company should never be affected by the personal thoughts or relationships. We should never use the assets, information or our position in the company to take personal advantages or provide advantages for our family members. If a family member or a close friend enters into business relations with us or we or a family member has a direct or indirect personal or financial benefit for any business that is currently evaluated, conflict of interest may arise within or outside the company. Further, such outside benefits may arise when our ability to work in such a manner satisfying the company is precluded.

We take responsibility for the environment. It is the right thing to protect the environment and, this is part of our business strategy. We are committed to caring each other and the environment. We strive to reduce the emissions and releases in all businesses we have. We safely use, handle, transfer and dispose all raw materials, products and waste. We help others to understand their responsibilities for the environment when using our products. We strive to constantly increase our environmental performance in collaboration with public officials, contractors and societies. Our environmental commitment is a responsibility shared by everyone. Nobody should think that this is another one’s responsibility.

We respect intellectual capital. We respect and protect confidential information during the term of our employment with Deceuninck. We make use of preventive methods to protect our documents, computers and other data devices containing personal or confidential information. We properly receive, develop and protect any intellectual property. We respect the restrictions on the use and reproduction thereof. Intellectual property includes copyrights, trade secrets and trade brands as well as innovative information and process information. The openness value of Deceuninck doesn’t preclude the responsibility for the proper protection of the information valuable for the business benefits.