Code of Conduct

 FOREWORD

Ponsse group (hereafter “Ponsse”) is committed to carrying out its business in a sustainable and responsible way. This Code of Conduct (“Code”) is strongly supported by our corporate values: Honesty, Innovation, Ponsse spirit, and Closeness to the customer. This Code gives guidance in our responsibilities towards our business environment, employees, business partners and society in general and is supplemented by specific Ponsse-wide principles and guidelines.

Our business operations are based on high ethical standards. We believe that our excellent reputation contributes to our business success.

We expect our employees, business partners, suppliers and customers to act in accordance with the principles stated in this Code of Conduct.

COMPLIANCE WITH LAWS

We always act according to the laws and regulations of the country in which we operate. It is the responsibility of all employees to be aware of relevant laws affecting their job duties or, in case of doubt, to seek advice to ensure compliance.

Ponsse Plc., the parent company of Ponsse group, is listed on NASDAQ OMX Helsinki Ltd. and follows the applicable corporate governance related laws and regulations effective from time to time in Finland. We ensure that the information provided to the market is accurate and reported in accordance with relevant laws, stock exchange rules and corporate governance codes.

SOCIAL RESPONSIBILITY

We respect and comply with the principles set out in the United Nation’s Universal Declaration of Human Rights.

We do not accept child labor nor other forms of compulsory or forced labor.

We support the freedom of association and all employees have the right to be a member of a trade union and to bargain collectively.

We treat our employees and job applicants in a non-discriminatory manner with regard to gender, nationality, religion, race, age, disability, sexual orientation, political opinion, union membership, or social or ethnic origin.

We strive to create and maintain a sought after workplace for all our employees, who are to be treated with equal respect and dignity. Furthermore, we promote a culture of equal opportunities and diversity. We do not tolerate any kind of harassment or bullying at work.

HEALTH AND SAFETY

We provide a safe and healthy working environment in compliance with applicable laws and regulations and are committed to continual improvement. It is our aim to prevent accidents and to mitigate health and safety risks in the workplace.

We expect our personnel to take responsibility for their own safety and the safety of others in the work place.

We develop innovative products and services and aim to minimize health and safety risks relating to their use in our product development and quality assurance methods as well as through development of our other internal processes and guidelines.

ENVIRONMENT

It is our policy to follow the environmental laws and adopt practices that protect and sustain the environment, and to take environmental aspects into account in our product development as well. We aim at increasing the energy efficiency of our operations, reduce waste, and protect the environment.

Where possible and practical, we give preference to ecologically sound supplier products and services.

BUSINESS INTEGRITY

We strive to be a trustworthy partner to our business partners, suppliers and customers.

Our employees and directors are expected to promote the best interest of Ponsse and act responsibly in doing so. Situations where personal interests may conflict with those of Ponsse must be avoided. The establishment of any business relationships must be based on objective criteria.

We are committed to working against corruption in all its forms, including extortion and bribery. We do not pay or authorize payment of or receive bribes or other illegal payments to obtain or retain business.

We do not offer nor accept any courtesy or a gift or benefit which could be reasonably assumed to influence decision making in our business or which exceed the limits of normal hospitality.

MONEY LAUNDERING

We do not accept, facilitate or support money laundering. We will conduct business only with reputable parties involved in legitimate business activities, with funds derived from legitimate sources.

FAIR COMPETITION

We promote fair and honest competition. We comply with the applicable competition laws regardless of the market area and refrain from entering into or carrying out any illegal practices.

COMPANY ASSETS

All employees are responsible for taking good care of Ponsse’s assets including physical property, financial assets, intellectual property, and any confidential information. Employees have a duty to use the assets only for legitimate business purposes and to protect them from loss or unauthorized use. Our assets may not be used for unlawful or improper purposes.

We shall protect any confidential material and information entrusted to us by subcontractors, suppliers or customers.

IMPLEMENTATION AND COMPLIANCE

All employees, including management at all levels, must comply with this Code. Supervisors shall be in charge of introducing the Code to existing and new employees.

Failure to act in compliance of this Code may result in appropriate disciplinary actions.

We encourage our employees to report any possible concerns or violations of this Code in confidence to their own supervisor, the management or human resources representative. There will be no adverse work-related consequences for any persons reporting such violations in good faith.

UPDATING

This Code of Conduct has been approved by the Board of Directors of Ponsse plc. on 12th of December, 2016.

The Board of Directors may review and update this Code when necessary. Additional instructions of the application of this Code can be given in separate guidelines. In case questions arise regarding the interpretation of the Code or compliance with it, please contact Petri Härkönen.