1.  The Company

Danish Tool Productions ApS is a Danish manufacture of tools, founded back in 1989. We have since developed and produced niche products mainly for the construction and restoration industry but also for other industries. We are a small company with a strong corporate culture.

Our staff consists of different people, with great respect for each other and their work assignments. Quality is a priority on at all products made by Danish Tool Productions. This implies a focus on engineering, design and choice of materials in the production.

The most important resource at Danish Tool Productions is our employees, their knowledge and commitment. Therefore, we also focus on our employee satisfaction, as a way to ensure the best quality of products.

2.  The Purpose of COC

The aim of Danish Tool Productions’ “Code of Conduct” is to create and encourage responsible production principles throughout the world. We want this “Code of Conduct” to ensure that our partners produce and deliver services to Danish Tool Productions in a manner that respects the environment and the employees’ rights.

Acceptance of and compliance with this “Code of Conduct” is an integrated part of any commercial agreement with Danish Tool Productions and contents must be considered as an absolute minimum even if national or international standards may set a lower standard than is the case in this paper. If there are national or international requirements that raise the right standard, these are always respected.

Danish Tool Productions follows the principles of this “Code of Conduct” and demands that our partners do the same and ensure that their suppliers in the same way comply with these principles.

3.  Legal Requirements

Danish Tool Productions will at all times comply with both national and international legislation relevant to the operation of the business this includes personnel, social, safety and environmental legislation. In a similar way, we expect all our partners to complying with all relevant laws in the operation of their business.

4.  Work Conditions

In Danish Tool Productions, we pride ourselves on our employees and their wellbeing, so it is important to us that our partners do the same.

4.1.         Child Labour

Child labour shall not be used or benefited from. With child labour is meant someone working fulltime who are younger than the local minimum age for full employment.

We guarantee and expect that:

• All employees are minimum 13 years of age.
• Employees between 13 – 15 years of age work a maximum of two hours daily.
• Employees between 13 – 15 years of age are instructed in their work and the conditions under which the work is performed.
• Employees under 18 years of age do not perform dangerous work or work at night.
• All apprentices in the company are more than 14 years old and works as part of their training.

We are in Danish Tool Productions aware of and respect the prohibition of child labour, as expressed in the Ordinance of the Working Environment Act, Act No. 2062 of 16^th November 2021.

Danish legislation complies with EU Directive 94/33/EC of 22^nd June 1994 on the protection of young people at work.

4.2.         Forced Labour

Forced labour shall not be used or benefited from. With forced labour is meant a person performing their jobs under the threat of punishment, confiscation of personal property, be it ID cards, passports, etc., deprivation of housing and financial debt.

Moreover, it is not allowed to use labour that is detained unless they have been convicted in a public judicial system and that the work performed both are monitored by public authorities and all other matters described in this document are respected.

We are in Danish Tool Productions aware of and respect the prohibition of forced labour, as expressed on ILO Forced Labour Convention, 1930, act. no. 29.

4.3.         Discrimination

Prohibition of discrimination dictates that a company cannot discriminate against its employees based on race, religion, sex, political beliefs, social origin, age, disability or other personal characteristics. The prohibition against sex discrimination includes discrimination against women or men because of marriage or parenthood.

We guarantee and expect that:

• There in the company is no discrimination based on sex, race, religion, political opinion, sexual orientation, national origin, social origin, ethnic origin, age or disability.
• There in the company is no discrimination in connection with hiring, firing, transfer, promotion, assignment of work or competency development. All decisions regarding employment, promotion, dismissal, pay and other terms is based on relevant and objective criteria.

The company is aware of and respects the ban on discrimination as expressed in the act on Prohibition and Discrimination in Labour, act no. 1001 of 24^th August 2017 and the act on Equal Treatment for Men and Women in Employment and Maternity Leave etc. act no. 899 of 5^th September 2008.

The Danish legislation is in conformity with EU Directive 2000/43/EF of 29^th June 2000 on Ethnic Equal Treatment. EU Directive 2000/78/EF of 27^th November 2000 establishing a general framework for equal treatment employment and occupation.

5.  Terms of Employment

The international minimum standards on wages, goods and Employment conditions dictate that company employees receive an employment contract, a fair salary, and salary during overtime, are given the right to vacation and development of skills. Furthermore, employees are entitled to be absent with pay in connection with pregnancy, childbirth and adoption. Moreover, all employees are trained within their specific field of work.

We guarantee and expect that:

• All employees receive a minimum wage, which is consistent with international standards.
• All employees at commencement of employment will have written information about wages, work, job content, rights regarding vacation, dismissal, pay and working hours.
• All employees who work for shorter periods are entitled to vacation, and that vacation time is adjusted to the length of the appointment.
• All employees receive a training period where they learn about their specific field of work.

The company is aware of and respects the Danish requirements on pay, benefits and employment conditions, as expressed in the act of Employer’s Obligation to Inform Employees About the Conditions of Employment, act no. 240 of 17^th March 2010, Holidays Act, act no. 230 of 12^th February 2021, Order of Law on Equal Treatment for Men and Women in Employment and Maternity Leave etc. act no. 899 of 5^th September 2008 and the Law on Entitlement to Leave and Benefits in the Event of Childbirth, act no. 1084 of 13^th November 2009.

The Danish legislation is in conformity with EU Directive 2019/1152 of 20^th June 2019 on transparent and predictable working conditions in the European Union.

5.1.         Working Hours and Rest

International rules on working hours and rest dictates that a company’s employees may work a maximum of 48 hours per week and is entitled to at least one day off every week. In addition, overtime will be limited to 10 hours per week per employee.

We guarantee and expect that:

• The maximum weekly working time is on average 48 hours including overtime.
• The employee receives at least 11 hours rest per day.
• There is at least one rest day per week.
• The employee is entitled to a break where the job can be vacated if the workday is longer than 6 hours.
• Night workers do not work more than an average of 8 hours per day.
• The employee has the right to at least 25 days of paid vacation per year.

The company is aware of and respects employees’ rights with regard to working hours, rest and vacation, as expressed in the publication of the Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish legislation is in conformity with the EU Directive 2003/88/EC of 4^th November 2003.

5.2.         Dining Facilities and Drinking Water

With dining facilities and drinking water means that the company should offer employees suitable dining facilities and allow them to store and consume food.

We guarantee and expect that:

• Access to a dining area with adequate hygienic conditions.
• Ability to store your own food and drink.
• Access to healthy safe drinking water during the hours of work.

The company is aware of and respects the rules on access to dining facilities, as expressed in the Danish legislation in the Ordinance of the Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish legislation is in conformity with EU Directive 89/654/EEC of 30^th November 1989 on workplace requirements.

5.3.         Medical Care and First Aid

With medical care and first aid means, that there must be equipment in the company, which enables the employee to receive and give first aid in acute emergencies. Additionally, all employees have access to medical care in acute medical emergencies and long-term illness.

All company employees have access to free medical care. In Denmark it is not necessary to be insured for medical help. The company has also taken the necessary measures for first aid.

We guarantee and expect that:

• The workplace is equipped with appropriate rescue equipment and necessary facilities for first aid in emergencies.
• A sufficient number of people is trained in first aid.

The company is aware of and respects the rules on access to first aid, as expressed in the Danish legislation in Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish legislation is in conformity with EU Directive 89/654/EEC of 30^th November 1989 on workplace requirements.

5.4.         Personal Safety

It is important to Danish Tool Productions employees to have instruction and the necessary safety equipment to carry out their work.

We guarantee and expect that:

• Employees received the necessary instruction or training to perform their work safely.
  • Employees have the required safety equipment to perform their work safely.
  • All machines in the workplace are equipped with safety devices such as emergency stop devices and warning equipment.
  • All employees who use the machines have a thorough training in using the machines.
  • All equipment is maintained so that safety is not compromised.
  • All machines are marked with requirements for security.

6.  Work Environment

With work environment means that the company’s setup and operations must be organized so that work does not lead to a weakening of employees’ physical or mental condition. The requirements for healthy and safe working conditions are closely linked to the company’s work to avoid accidents.

We guarantee and expect that:

• All stages of the production is planned and organized so that it takes place in a safe and sound manner.
• Work in the company is done, following these principles of prevention:
  • Risks tackled at source.
  • Work is adapted, as well as possible, to the individual employee with regard to particular arranged of work space and choice of equipment, labour and production methods.
  • Monotonous work is limited so that the health impact of such work is reduced.
  • No structures and work practices which may pose a significant hazard to employees is used.

The company is aware of and respects the rules on access to first aid, as expressed in the Danish legislation in Working Environment Act, act no. 2062 of 16^th November 2021, Order on the Performance of Work no. 559 of 17^th June 2004 and the Order of youth work no. 1049 of 30^th May 2021.

The Danish legislation is in conformity with EU Directive 89/391/EEC of 12^th June 1989 on the implementation of measures to improve worker safety and health at work, EU Directive 89/654/EEC of 30^th November 1989 on minimum safety and health in the workplace, the EU Directive 94/33/EC of 22^nd June 1994 on the protection of young people at work.

6.1.         Health Promotion

With health promotion means that the company must assist in improving the employee’s health and medical conditions, for example by combining efforts for a better working environment with initiatives that are aimed at a healthier lifestyle and improved wellbeing.

Danish Tool Productions helps promote employee’s health by providing gym facilities. Furthermore, all smoking is prohibited inside the premises of the company.

6.2.         Psychological Work Environment

With psychological work environment means that employees must not be subjected to physical or psychological abuse such as violence, threats of violence, any threatening behaviour, verbal abuse and harassment.

We guarantee and expect that:

• There is minimal risk of physical or mental health deterioration in the work.
• There is no monotonous repetitive work, which jeopardizes the physical or mental health in the short or long term.
• There is no secluded work that may endanger the physical or mental deterioration of health where it can be avoided or reduced.
• The work does not involve risk of physical or mental deterioration of health caused by bullying, including sexual harassment.

The company is aware of and respects the rules on access to first aid, as expressed in the Danish legislation in Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish legislation is in conformity with EU Directive 89/391/EEC of 12^th June 1989 on the implementation of measures to improve worker safety and health at work.

6.3.         Fire Safety

With fire safety means that the company should have emergency exits and that safety equipment is available and that the firm has prepared evacuation plans and conducted evacuation drills.

We guarantee and expect that:

• There are a sufficient number of escape routes and emergency exits.
  • Emergency exit doors and gates can be opened easily and safely and that they are freely passable.
  • Escape routes are freely passable.
  • There are signs that provide information or warnings about conditions of safety and health.
  • The workplace in case of risk to specific hazards is provided with the necessary alarm and necessary equipment for first aid in emergencies.
  • There is established a sufficient number of operational fire extinguishers.
  • Flammable waste stored in fireproof containers that are emptied regularly.

The company is aware of and respects the regulations on fire safety, as expressed in the Danish legislation in the Notice of Construction Act (BR18), act no. 1399 of 12^th December 2019, with the following changes act no. 182 of 5^th March 2022, act no. 794 of 2^nd June 2020, act no. 1872 of 7^th December 2020, act no. 1282 of 11^th June 2021, act no. 2312 of 7^th December 2021, act no. 1030 of 27^th June 2022, act no. 1286 of 15^th September 2022, act no. 1464 of 28^th November 2022, act no. 1498 of 6^th December 2022 and act no 1583 of 21^st December 2022 and the Order of the Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish working environment legislation complies with EU Directive 89/391/EEC of 12^th June 1989 on the implementation of measures to improve worker safety and health at work, EU Directive 89/654/EEC of 30^th November 1989 on health and safety in the workplace and the EU Directive 92/58/EEC of June 1992 concerning minimum requirements for signalling in health and safety at work.

6.4.         Ventilation and Exhaustion

With ventilation and exhaustion means that the company’s workplaces must be designed, constructed and in use, so employees can work without the ventilation and/or exhaustion causes them discomfort.

We guarantee and expect that:

• The company’s jobs are designed, arranged and used so that work can be performed without ventilation and exhaustion causing employees discomfort.
  • There is established mechanical ventilation at workplaces where the development of harmful gases, dust or irritating fumes cannot be prevented.
  • In workplaces where hazardous fumes and dust cannot be effectively removed by ventilation, the work must be restricted to a special room or cabin.

The company is aware of and respects the rules on access to first aid, as expressed in the Danish legislation in Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish legislation is in conformity with EU Directive 89/654/EEC of 30^th November 1989 on minimum safety and health in the workplace.

6.5.         Temperature

With temperature means that the company’s workplaces must be designed, constructed and used so that work can be performed without temperature conditions gives employees discomfort.

We guarantee and expect that:

• The company’s work zones are designed, arranged and used so that work can be performed without temperature gives employees discomfort.
  • The temperature in work spaces is tailored to the employee’s working methods and their physical demands.
  • Temperature conditions in the workspace are free of annoying temperature differences.

The company is aware of and respects the rules on access to first aid, as expressed in the Danish legislation in Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish legislation is in conformity with EU Directive 89/654/EEC of 30^th November 1989 on minimum safety and health in the workplace.

6.6.         Safe Building

With safe building means that all buildings, structures, areas, etc. is designed, constructed and operated, so it does not cause risks for worker safety and health.

We guarantee and expect that:

• All buildings, structures, lands, etc., that the company’s employees’ access in connection with their work, are designed, arranged and operated in a manner that does not involve risks to the employee’s safety and health.
  • The workplace is designed in a safety and healthy manner based on an assessment of any health risks that may affect the physical or mental health.
  • The workplace is arranged so that there is a possibility of escape and rescue persons in the event of fire or other accidents.

The company is aware of and respects the rules of safe buildings, as expressed in the Danish legislation in the Notice of Construction Act (BR18), act no. 1399 of 12^th December 2019, with the following changes act no. 182 of 5^th March 2022, act no. 794 of 2^nd June 2020, act no. 1872 of 7^th December 2020, act no. 1282 of 11^th June 2021, act no. 2312 of 7^th December 2021, act no. 1030 of 27^th June 2022, act no. 1286 of 15^th September 2022, act no. 1464 of 28^th November 2022, act no. 1498 of 6^th December 2022 and act no 1583 of 21^st December 2022 and the Order of the Working Environment Act, act no. 2062 of 16^th November 2021.

The Danish working environment legislation complies with EU Directive 89/391/EEC of 12^th June 1989 on the implementation of measures to improve worker safety and health at work and EU Directive 89/654/EEC of 30^th November 1989 on health and safety in the workplace.

7.  Corruption

With corruption means a broad list of situations where personal interests are mixed together with public interests, such as bribery, breach of trust, bribery and favouritism.

We guarantee and expect that:

• No employees exchange unjustified benefits with Danish or foreign public officials or with representatives from other private companies.

The company is aware of and respects the rules of corruption, as expressed in the Ordinance of the Penal Code, act no. 1851 of 20^th September 2021, § § 122, 144, 290, 299.b and 306.

The Danish legislation is in conformity with Council of Europe convention against corruption on basis of Article K.3 (2) (c) of the Treaty on European Union on the fight against corruption involving officials of the European Communities or officials of Member States of the European Union.

The Danish authorities punish violations of the Danish rules on corruption with imprisonment in up to 6 years or in extenuating circumstances with a fine. This also applies if the offenses are committed abroad.

8.  Environment

With environment means that the company complies with the rules and laws that is set to protect the environment.

We guarantee and expect that:

• The reduction of waste and emissions to air, soil and water.
• Handling of chemicals is done in an environmentally safe way.
• Handling, storing and disposal of hazardous waste are done in the most environmentally safe manner.
• Contributes to the reuse of materials and products.

The company is aware of and respects as expressed in the Danish legislation on environmental protection, Order no. 100 of 19^th January 2022.

8.1.         Setup and Operation

With setup and operation means the starting and running of a factory must be done with an effort to reduce emissions of substances that can harm the environment. In addition, the company must also comply with requirements for operating and location, which include protection of air, water, soil and accident prevention and reduction of noise pollution.

We guarantee and expect that:

• The company follows environmental authority’s guidelines and instructions on protecting water, air, soil, the prevention of accidents and noise levels.
• The company continuously seeks to assess whether any discharges into the environment can be reduced at source.
• The company is aware of and comply with requirements from the authorities controlling the company’s environmental performance.

The company is aware of and respects as expressed in the Danish legislation on environmental protection, Order no. 100 of 19^th January 2022.

8.2.         Hazardous Substances

With hazardous substances means that work occurs in a sanitary and safe manner. Workplace instructions, with description of each substance or material used in the company must be available and understandable for all people. The instructions must ensure that employees are not exposed unnecessarily to hazardous substances and materials which can be harmful to their health and safety.

We guarantee and expect that:

• The operating instructions are updated and issued to the employees and that employees have received instruction in them.
• All relevant staff has been trained in the use of the substance or material.
• That necessary first aid equipment is available and ready for use.
• No children under 18 years work with hazardous substances.

The company is aware of and respects the rules of the handling of dangerous substances, as expressed in the Danish legislation in Working Environment Act, act no. 2062 of 16th November 2021.

The Danish law contains provisions in conformity with EU Directive 2004/37/EC of 29^th April 2004 on the protection of workers from risks related to exposure to carcinogens, the EU Directive 98/24/EC on the protection of occupational safety and health of workers from risks related to chemical agents and the EU Directive 94/33/EC of 22^nd June 1994 on the protection of young people at work.

8.3.         Chemicals

With chemicals means the requirements for both the content of chemicals in the products and the way it is classified, packaged and labelled.

We guarantee and expect that:

• The company classify, pack, label and stores all chemical substances and products correctly according to current Danish rules.
• The company does not use chemicals that are prohibited in international conventions on hazardous substances.
• The company does not use ozone-depleting substances for uses that are prohibited within in the EU or Denmark.
• The company regularly assesses whether the use of environmental and hazardous chemicals can be replaced with less environmental and health hazardous substances.

The company is aware of and respects the environmental administration rules on chemicals, as expressed in the Danish legislation in the Executive Order on the import and sale of highly toxic and toxic substances and mixtures, etc., on the storage and reporting of theft of certain substances and mixtures and on the prohibition of misleading statements when marketing substances and mixtures, act no. 1565 of 19^th December 2022.

The Danish legislation is in conformity with EU Regulation No. 1272/2008 of 16^th December 2008 on classification, labelling and packaging of substances and mixtures.

We guarantee and expect that:

• Company’s products, which contain substances that come under the REACH Regulation list (See Annex XIV of REACH) or the Candidate List are classified, packaged and labelled in accordance with regulations.
• The company continually works to reduce the content of environmental and health hazardous substances in its products and always perform an environmental and health assessment of new substances and materials in its products.

9.  Raw Materials

Danish Tool Productions ApS, hereby declare that the products manufactured and supplied from our company are free from conflict minerals, including Tantalum, Tin, Tungsten, Gold, Cobolt, Mica and DAP.

Conflict Minerals:

• Tantalum (Ta): Not used in our production
• Tin (Sn): Not used in our production
• Tungsten (W): Present (sourced from non-conflict area)
• Gold (Au): Not used in our production
• Cobalt (Co): Present (sourced from non-conflict area)
• Mica: Not used in our production
• DAP: Not used in our production

Due Diligence:

Danish Tool Productions ApS has conducted due diligence to confirm that the supplied products do not contain conflict minerals sourced from conflict-affected or high-risk areas.

Compliance with Applicable Regulations:

Danish Tool Productions ApS certifies that the products manufactured and supplied from our company comply with all applicable regulations regarding conflict minerals.

Responsible Sourcing Practices:

Danish Tool Productions ApS is committed to responsible mineral sourcing practices and ensures that its supply chain is free from materials associated with human rights abuses, environmental degradation, and unethical mining practices.

We understand the importance of responsible mineral sourcing, and we affirm our commitment to transparency and compliance with all relevant regulations.