Securing What Matters

CODE OF CONDUCT

Securing What Matters

WHY THIS CODE OF CONDUCT?

At Betafence we believe our success depends on relations based on trust and professionalism. This Code of Conduct guides us in building and maintaining these relationships with integrity, whether it is with fellow team members, our customers and commercial partners or our shareholders, government authorities and community members. All persons acting on behalf of Betafence are expected to perform their activities in an ethical way, in accordance with laws and regulations and within the standards Betafence sets through our policies, guidelines and procedures.

This Code lays down a strong ethical foundation for Betafence, and enforces the implementation of legal and ethical policies and procedures for various forms of decision making.

BETAFENCE BUSINESS PRINCIPLES

Fairness, Honesty and Respect

We maintain strong relationships based on mutual respect and trust with our customers, suppliers and other business partners by treating everyone we deal with in the same way we expect to be treated:with fairness, honesty and respect.

Corporate Social Responsibility

We continually build on our reputation as a responsible corporate citizen.

Our Way of Doing Business

We comply with generally accepted business standards in dealing with our business partners.

Respect for the Environment

We demonstrate respect for the environment wherever we operate in the world. All team members are expected to consider the impact their business decisions and conduct has on the environment and the community.

Compliance with Legislation

We adhere to internal policies and follow applicable laws and regulations in countries where we operate. Where this Code or company guidelines differ from applicable local laws, the higher standard is followed.

Respect for Human Rights

We support the elimination of discriminatory practices with regard to employment and occupation and aim to promote and embrace diversity in all aspects of our operations. We strongly condemn all forms of exploitation of children; we prohibit the use of child labour in all our facilities and fully support the abolition of exploitative child labour. We support the elimination of all forms of forced or compulsory labour and the freedom of association and the right to collective bargaining.

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We aim to achieve success through ways that reflectour business values and high standards of

ethics. We will always demonstrate respect for peopleand the planet.

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BETAFENCE AS A PLACE TO WORK

Health and Safety

Betafence complies with health and safety laws, standards and regulations applicable to our business. We are committed to providing a safe and healthy working environment for all our employees and expect our business partners to uphold the same high standards in their operations.

Communication

We foster open and honest communication within our organisation. We encourage collaboration and the sharing of information, dialogue and consultation. We expect our employees to raise work-related concerns with their direct manager or, when appropriate, the next manager in line.

Equal Employment Opportunities andNon-discrimination

Betafence is committed to an inclusive work culture and recognizes and appreciates that all people are unique. We appreciate and respect team members for their individual abilities and the value they bring to the organization.

Betafence has zero tolerance for any form of harassment or discrimination on the basis of gender, religion, race, national or ethnic origin, cultural background, social group, disability, sexual orientation, marital status or age.

We encourage and value diversity in our workforce, and respect diversity with our customers, suppliers and other stakeholders. We strive to be representative of the communities within which we operate.

Equal employment opportunities for all applicants and employees are supported throughout the Betafence group. The recruitment, hiring, training, promotion, compensation, benefits, transfer and career development of our employees are based on professional qualifications and past work performance only.

WHAT WE EXPECT FROM OUR EMPLOYEES

Personal Conduct

As a Betafence employee or representative, you are expected to conduct business and behave impeccably towards customers, business partners, colleagues and other stakeholders. This includes respecting and being sensitive to foreign cultures and customs. Betafence does not accept any form of discrimination or behavior that colleagues or business partners may regard as improper.

Betafence places confidence in the loyalty, motivation, competence and sense of responsibility of its employees. We expect them to always behave in a professional manner and adhere to the highest standards of integrity.

Information Technology and Communication Resources

Professional Conduct

Each employee is expected to behave in an attentive and respectful manner in his or her relationships with other team members. Discrimination, victimization, any form of harassment, intimidation, violence and ostracizing is not tolerated.

Each employee is expected to perform his or her work in a competent and responsible manner, free of the influence of alcohol or drugs. Identifying, communicating and controlling risk exposures to prevent accidents and minimize losses is each person’s responsibility.

Betafence’s IT and communication resources are intended for professional use only. They are to be used in a responsible and professional way at all times.

Compliance with the Letter and the Spirit of Laws and Regulations

Each employee is responsible for familiarizing him or herself with and adhering to applicable laws and regulations, and to act in a manner that upholds the spirit and the intent of the law. The principle of caution is maintained where the legal framework is open to interpretation.

Relationships with our Customers, Suppliers and other Business Partners

Employees’ dealings with customers, suppliers and other business partners should be fair and honest, in strict compliance with contractual undertakings and applicable laws and regulations.

Employees may not accept bribes or kickbacks, and must not facilitate or participate in corrupt activities of any kind. No excessive benefits, such as gifts, entertainment, travel or accommodation, or any other gratuities will be offered to or received from

existing or future customers, suppliers or other business partners. Each employee should carefully read the anti-bribery compliance manual available on the intranet or upon request from local HR and strictly adhere to it.

Commercial agreements should always be in line with our ethical principles.

No employee shall support customers, suppliers or other business partners in evading tax, or let their owners or employees benefit from price settlements that are not in line with ethical business practices and with tax and other legal requirements. Each employee shall also comply with applicable antitrust laws and regulations (in general terms, the way companies need to deal with their competitors, customers and suppliers) that encourage competition by prohibiting unreasonable restraints of trade. Each employee should carefully read the antitrust compliance manual available on the intranet or upon request from local HR and strictly adhere to it.

Political Contributions and Mandates

Any direct or indirect contribution by or in the name of Betafence to any political party, committee or candidate for public office is forbidden, even if permitted by local regulations, unless the formal approval of Betafence’s CEO has been obtained in advance.

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Members of Betafence’s management teams in all units or regions who wish to be a candidate for local, national, federal or regional elections are requested to notify Betafence’s executive committee of their intentions.

Protecting Physical Assets

Betafence’s physical assets include facilities, equipment and computer and communication systems. Appropriate security measures should be taken and usage guidelines to protect Betafence’s physical assets from theft, loss, damage, or misuse should be followed. Each employee must report the theft, loss, damage, or misuse of Betafence’s physical assets immediately.

All employees should respect Betafence’s property and facilities and treat them with care. This includes keeping factories, offices and work areas clean and tidy.

Misuse of equipment provided by Betafence, including phones, vehicles and computers is not tolerated. Computers provided by Betafence to employees and the data stored on them remain the property of Betafence. No software may be installed on company computers without the permission and participation of the IT department.

Inappropriate use of computers is not permitted. As far as the use of the Internet is concerned, an occasional consultation of websites is accepted for personal reasons and within reasonable limits, provided the content is not contrary to public order or morality, and that the consultation of such sites is not detrimental to the interests and the reputation of Betafence. A reasonable use of personal email in the framework of the requirements of daily and family life is also accepted, on condition that the use of the email facility is not excessive and does not affect professional communication or impede work performance.

Conflicts of Interest

If employees encounter situations in which their personal interests may conflict with the Betafence Group’s interests, they shall bear in mind the Group’s interests and the expected loyalty to the Betafence Group. Betafence’s property or information will not be used for personal gain or gain of third parties. Our employees will not engage in any other remunerated activity (whether for their own account or for the account of a third party) that could interfere with the proper execution of the employment agreement with Betafence, and/or could damage Betafence’s interests or image.

Betafence employees or representatives will refrain from obtaining advantages for themselves (or related persons) that are improper or in any way may harm Betafence’s interests. Such interests include financial performance, environmental, health and safety considerations, security and commercial and public reputation.

To avoid conflicts of interest, employees will not: (i) acquire any interests in a competitor, supplier or customer without the prior written approval from management;(ii) exercise any outside professional activity (competing with the business of Betafence)

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For the purpose of applying this Code of Conduct, an activity competing with the business of Betafence means:

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Integrity of Financial Records

All financial transactions must be accurately and properly registered in the company’s books and records. No false or artificial entries shall be made for any reason.

Confidentiality

Employees take the necessary steps to protect the confidentiality of any information acquired in the course of their employment. Confidential information includes but is not limited to documents, data or knowledge about business figures, business plans, new products, R&D ideas or projects, styles, designs and design concepts, commercial or marketing strategies, pricing information, customer lists, vendor lists, investments, manufacturing and project management and integration processes and know-how, internal policies and procedures. Confidential information will not be disclosed, whether verbally, in writing or electronically. This duty remains in effect, even after an employee leaves Betafence Group.

We always follow the law,act with integrity and honesty inall matters, and are accountablefor our actions. This is how wecontribute to making Betafence

a great place to work!

Securing What Matters

CODE OF CONDUCT

The financial interest, directly or indirectly, in a company that is active in the fencing business for perimeter protection and/or in high security total solution projects, including the financial interest as a creditor;

The participation or activity as a manager, associate, director or shareholder in a company that is active in the fencing business for perimeter protection and/or in high security total solution projects;

Engaging in any relationship with a company that is active in the fencing business for perimeter protection and/or in high security total solution projects, in the capacity of officer, agent, employee, independent consultant or representative;

Supplying services, irrespective of their nature, to a company that is active in the fencing business for perimeter protection and/or in high security total solution projects.

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