Our

Code of Conduct
 Contents
Our business principles______________________________ 3
How to apply the code_______________________________ 4
Integrity concerns___________________________________ 5
The 7 Golden Principles______________________________ 6
Workplace and Environment__________________________ 8
Environment, Health & Safety
Fair employment practices
Development of human capital
Conflict of interest
Fair business______________________________________16
Competition
Suppliers
Product quality and safety
Society and Community_____________________________20
Supporting communities
Open and honest communication
Corporate Governance______________________________22
Information about the Trelleborg Group________________24

2
 Our
business principles
At Trelleborg, we work to create added value for our stakeholders
without compromising the high standards we set in terms of our
environmental and social responsibility.
   We support and operate our business in accordance with the
Ten Principles of the UN Global Compact, the general concepts
expressed in the International Labour Organization (ILO) conven-
tions and the OECD Guidelines for Multinational Enterprises.
   Our Code of Conduct, combined with our rules of corporate
governance and our policies, provide the framework for our
operations. The Code is applicable to all employees, officers and
Board members of the Trelleborg Group, in all markets and at all times.
   Trelleborg encourages suppliers, sales agents, consultants
and other business partners to adopt the Global Compact principles
as well as those in our Code of Conduct. The Code of Conduct was
adopted by the Trelleborg Board of Directors in April 2007.

Sören Mellstig, Chairman of the Board Peter Nilsson, President and CEO

3
 How to
apply the code
Every employee will receive a copy
of the Code of Conduct and needs to
understand and comply with it.
The Code of Conduct organizes and summarizes existing Trelleborg
policies and should be used as a support tool laying down the
principles on which our day-to-day work is based.
   More detailed information can be found in the underlying policies.
The current version of the Code, as well as all our policies, manuals
and recommendations, can always be found on our intranet.
   The officer responsible for the Code of Conduct and follow-up
procedures is the Senior Vice President, Human Resources. At
Group level, Trelleborg conducts training activities and provides
information to support the implementation of the Code of Conduct.
   It is the duty of Trelleborg managers to include the Code of
Conduct in employee training programs.

4
em som är tillgängligt för varje anställd som vill
erträdelser kan ha ägt rum.
ncernövergripande whistleblowerpolicy kan
medarbetare har anledning att misstänka att det

Integrity
verträdelser av lagar och förordningar eller av

concerns
oden. Varje medarbetare i koncernen har rätt att
m helst efterverkningar rapportera misstanke om
iviteter eller andra allvarliga regelbrott till de
ansvariga förWeregelefterlevnad.
have a system
accessible to all employees
s Trelleborg Whistleblower Hotline:
for raising integrity concerns.
portera något kan du:
Employees can apply the Group’s whistleblower policy if they have
reason to suspect that laws, other legal requirements or the Code
efon eller webadressen:
of Conduct are possibly being violated. Every employee in the
org.com/whistleblower Group has the right, without fear of reprisal from anyone, to inform
the designated compliance officers of any suspected criminal or
seriously improper activity.
t eget språk
Using the Trelleborg Whistleblower Hotline:

på att din identitet är skyddad

When you want to leave a message:
• Use the telephone, or the Web at: www.trelleborg.com/whistleblower
• You can use your own language
r och andra instruktioner finns på Koncernens
• Your anonymity is protected
äljer du Group To(Koncernen)
find relevant phoneoch sedan
numbers and other instructions, go to the
Group Intranet. Select The Group/About Our Group/
. Code of Conduct/Whistleblower policy.
5

t 5
 The 7
Golden Principles
Business at Trelleborg shall be conducted
in accordance with the following principles:

1 We respect the rights of the individual, act in accordance with fair

business, marketing and advertising practices and are committed
to continuously developing the safety and quality of our products
and processes.

2 We respect the rule of law, conduct our business with integrity

and honesty and are accountable for our actions.

3 We continuously work to reduce the negative impact of

our operations on the environment and health.

4 We do not engage in illegal operations or operate in the context

of illegal activities.

6
5 We do not tolerate the offering, solicitation or
acceptance of bribes.

6 We are all entitled to alert the designated compliance

officers if we witness any violations of laws or of this
Code of Conduct.

7 Trelleborg listens to its stakeholders and takes their

opinions into account with the objective of ensuring
the sustainable success of our company.

What these principles imply in practice for Trelleborg’s employees

and suppliers is described in this brochure under three headings:
Workplace and Environment, Marketplace and Society and Community.

7
 Workplace
and Environment
Environment,
Health & Safety
Our fundamental principles shall
contribute to ecologically sustainable
development and to safeguarding the
health and safety of all our employees.
ENVIRONMENTAL MANAGEMENT
• All production and development units shall implement
and maintain a certified environmental management system
in accordance with ISO 14001.

• We shall train and inform our employees about environmental,

health and safety issues and involve them in a continuous
improvement process.

8
ENERGY & MATERIALS
• We will work to increase our resource efficiency by reducing
the consumption of energy and raw materials in our production
and by finding ways to improve the recovery of materials and
energy from production waste that we cannot reduce or avoid.

HEALTH & SAFETY

• We shall manage Health & Safety in accordance with
the Group’s common standards, as described in our
Safety@Work Manual.

• We shall maintain good health and safety standards

wherever we operate and work to minimize the risks and
effects of accidents.

• We do not permit employees to be intoxicated at

the workplace or to work under the influence of drugs.

DEVELOPMENT
• Environmental, health and safety aspects shall be taken into
account in the development of products and processes.

• We shall take into account the effects on the environment,

health and safety of the chemical substances used in our
products and processes.

9
 Fair
employment practice
Our fundamental principle is
that we respect our employees
and their human rights.

• We will not apply special treatment to employees in regard

to employment or work assignments on the basis of gender,
race, religion, age, disability, sexual orientation, nationality,
political opinions, or social or ethnic origin.

• Trelleborg employees shall not harass or discriminate against

any colleague or business partner for any reason.

10
• We will respect our employees’ right to be represented by
unions and other employee representatives, as well as their
right to take part in collective employment agreements.

• Wages and salaries will be paid as agreed and on time.

We will recognize good performance and extra efforts.

• We work for the abolition of child labor within our sphere of

influence. The minimum age for working in our operations is
15 years, and not younger than the compulsory school age
in individual countries.

• We do not allow illegal or forced labor in our own operations

or in the operations of our suppliers or any other parties with
whom we cooperate.

11
 Development
of human capital
Our fundamental principle is that
we will provide appropriate training
to improve skill levels.

12
• All employees are responsible for their personal
development of skills and capabilities.

• In accordance with business needs, we will provide

the opportunity to improve our employees’ capabilities
in order to develop their professional skills and enhance
their social and economic opportunities.

• Competence development activities shall aim at

creating the right conditions to fulfill present and future
requirements.

• We will provide tools and training to support the

implementation of the Code of Conduct, its components
and underlying policies.

13
 Conflict of interest
Our fundamental principle is that
Trelleborg employees shall not
participate in any activities that
are in conflict with the interests
of the company.

14
• A conflict arises when an employee’s personal, social,
financial or political activities have the potential to interfere
with his or her loyalty or objectivity vis-à-vis the company.

• Employees shall avoid all situations in which there is

a potential conflict of interest.

• Employees shall avoid personal or family financial interests

in, or indebtedness to, enterprises that have significant
business relations with Trelleborg.

• At the managerial level, Trelleborg does not accept outside

employment without specific approval from the head of the
business unit concerned, in accordance with the “Grandfather
Principle” (approval also from the level above).

• All potential conflicts of interest shall immediately be

reported to management.

15
 Fair business
Our fundamental principle is that in all our
business activities and relations with cus-
tomers, business partners and authorities,
sound business ethics must always prevail.
• We do not accept the offering, solicitation or acceptance of
any form of bribes, whatever the form, method or purpose.

• The remuneration of agents shall be appropriate and for

legitimate services only.

• We shall report our activities to combat bribery, money-

laundering and extortion in a transparent manner.

• No employee shall seek or accept any gift, entertainment or

personal favor that might reasonably be believed to have an
influence on business transactions or which is contrary to
applicable laws or customary business practice.

16
 • Gifts, entertainment, compensation or personal favors
may be offered to a third party only if they are modest in
value and consistent with applicable laws and customary
business practice.

Competition
Our fundamental principle is that all entities
and employees of the Trelleborg Group must
at all times observe and be in compliance
with applicable laws on competition.
• If there is any doubt regarding applicable competition law,
legal advice must be obtained.

• Certain types of agreements that are particularly sensitive with

regard to competition law must not be negotiated or entered
into without the involvement of the legal department.

17
 Suppliers
Trelleborg is committed to working
with suppliers who adhere to our quality
requirements and business principles.
We will strive to support positive changes
as regards quality, the environment and
the work environment.
• Our ambition is to include the requirement of compliance
with the Trelleborg Code of Conduct in supplier contracts.

• We will insist that suppliers follow legal requirements

and work actively to reduce negative environmental and
health impacts from processes, services and products.
We will encourage suppliers to implement certifiable
quality and environmental management systems.

• We will support and continuously monitor the performance

of our suppliers.

• If a supplier is found not to be adhering to an agreed

specification, we will consider appropriate actions, including
demands for corrective measures, or termination of the
relationship.

18
Product quality
and safety
Our fundamental principle is to
take all reasonable steps to ensure
the safety and quality of the goods
we supply.
• Our products shall meet agreed and legal standards
for customer health and safety, including health warnings,
product safety and information labels.

• We will offer sufficient, accurate and clear information

regarding our products’ content, safe use, maintenance,
storage and disposal to enable our customers to make
informed decisions.

• We will provide transparent and effective procedures to

address customer complaints and contribute to a fair and
timely resolution of customer disputes, without undue cost
or burden.

• Our ambition is to assess, and address in our decision-

making, the foreseeable environmental, health, and safety-
related effects associated with our main products over
their full life-cycle.

19
 Society
and Community
Supporting
communities
Our fundamental principle is to contribute
to a better society by supporting local
communities where we operate.
• We will strive to hire and develop local employees
and managers.

• We will promote local contributions to activities in

the local communities.

• We will prioritize sponsorship agreements that benefit

the societies and environments where we conduct our
operations, and which support our values and strengthen
our relations with customers and partners.

• We shall not make contributions to political parties or

committees or to individual politicians.
20
 Open and
honest communication
Our fundamental principle is that all
communication shall adhere to relevant
legislation, regulations and standards.
Our communication shall be transparent
and honest.
• We are committed to being open and accurate within the
limits of commercial confidentiality.

• Our communication shall be characterized by close relations

with the Group’s stakeholders and based on frequent contacts,
clarity and strong ethics.

• As employees, we are all required to observe the applicable

rules on preservation of confidentiality regarding the company’s
and the business partners’ proprietary information, as well as
any information that could potentially affect the company’s
share price.

• The CEO, CFO and heads of Corporate Communications and

Investor Relations are company spokespersons and may make
statements on behalf of the Group. Other managers are
spokespersons within their own areas of responsibility.

21
älld som vill

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Infor

The guiding principles for good corporate governance are aimed

at establishing favorable conditions for active and responsible
ownership, a well-considered division of responsibilities between
owners, the Board and company management, and transparency
toward all stakeholders.
   The Annual General Meeting is the Trelleborg Group’s highest
decision-making body. The meeting appoints the Board of
Directors, which is responsible for sharing the management and
control of the Trelleborg Group among the Board of Directors,
its elected committees and the President in accordance with
the Swedish Companies Act and other legislation, rules and
regulations governing listed companies, including the Swedish
Code of Corporate Governance, Trelleborg’s Articles of Association
and the Board’s and its Committees’ own internal control
ncernens instruments.
n    Read more at www.trelleborg.com/corporategovernance.

22
5
 Elections
Shareholders Nomination
form the Annual General Meeting Proposals Committee
Elections
Information
Elections

Information
Board of Directors
Audit Committee, Finance
Auditors Committee, Remuneration Committee
CR
Objectives,
Strategies, Reports Risk
Steering Management
Control
instruments Internal
Control
Staff
President and CEO functions
Objectives, Reports,
activities, forecasts,
values, Trelleborg Trelleborg Trelleborg Trelleborg Trelleborg business
remuneration Coated Industrial Offshore & Sealing Wheel
overview
structures Systems Solutions Construction Solutions Systems

External steering instruments Internal steering instruments

23
 Information about
the Trelleborg Group
På www.trelleborg.com hittar du information
om Trelleborgkoncernen, till exempel:

• Annual reports
• Interim reports
• Corporate Responsibility Report (www.trelleborg.com/cr)
• Press releases and other news
• The Trelleborg magazine T-TIME
Trelleborg AB
Corporate Communications
Box 153, SE-231 22 Trelleborg, Sweden
Tel: +46 410-670 09
Fax: +46 410-427 63

24
My notes:

25
My notes:

26
My notes:

In the event of uncertainty regarding the Code’s wording or its

implications, the English version applies.

27
 Belongs to:

www.trelleborg.com

March 2014 Trelleborg Corporate Communications