1. Commitment by the management

Splitvsion Design AB (hereafter Splitvsion), as an expanding multinational company, acknowledges our growing responsibility for all our actions in Europe and worldwide, wherever we operate. We have the responsibility towards the environment and the people, including thousands of individuals taking part in the production of our products. We must ensure that workers contributing to our success are not deprived of their human rights or subjected to mental or physical harm.

In alignment with international norms and standards, our Responsible Sourcing Policy (“this Policy”) aims to ensure legally compliant and environmentally sound sourcing practices, while upholding our commitment to human rights at every supply chain level.

This policy is endorsed at the executive level of our organization. Updates and further information related to the policy can be found on our website here: www.splitvsion.com. For any questions regarding our Responsible Sourcing Policy please submit your question thorugh the general contact form on our website and it will be directed to our Supply Chain Director.

2. Scope of the policy

The Responsible Sourcing Policy outlines our requirements for supplier and vendor behavior. This policy explicitly applies to our direct, Tier One suppliers. Direct suppliers are defined as providers of:

• Manufacturers who producing our products.
• Technical products and services, including suppliers of materials, services such as logistics, and the wide range of goods and service we purchase.

We will assess Tier One suppliers for compliance with applicable legal requirements and this policy to ensure sustainable sourcing practices throughout our entire value chain. With a mutual commitment and unified approach, we seek our suppliers’ support in enhancing traceability and ensuring ethical practices and long-term value for all stakeholders.

3. Ethical Practice and Legal Requirements

It is a general requirement that all our suppliers, in all their activities, comply with the national laws of the countries in which they operate. However, it is important to understand that Splitvision’s requirements may exceed the requirements of national law. Should any of the requirements stipulated by Splitvision violate national law in any country or territory, the law always prevails. In such circumstances, the supplier must inform Splitvision immediately by all possible means.

As part of our commitment to responsible sourcing, we will uphold the highest standards of ethical conduct, social responsibility, and environmental stewardship across all our operations. This is reflected in our comprehensive approach to sourcing products, commodities, and services, ensuring that our practices are not only in full compliance with legal requirements in the country of origin but also contribute positively to the communities and landscapes within which we operate.

4. Respect for people’s well-being and human rights

4.1 Child Labour

Our policy on child labor is based on the UN Convention on the Rights of the Child, article 32.1. We recognize the rights of every child to be protected from economic exploitation and from performing any work that is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral or social development. Splitvsion does not accept child labor, unless the law has permitted apprenticeship programme and all care conditions are met in the child’s best interest. If a supplier does not accept our policy on child labor, we will not continue our cooperation with this supplier.

We define, the word ”child” as a person younger than 15 years of age or, as an exception, 14 years in countries covered by Article 2.4 in the ILO convention No.138. We acknowledge that, according to the UN Convention on the Rights of the Child, a person is a child until the age of 18. Therefore, we recommend our suppliers to ensure, that employees in the age group 15-18 years, are treated with due care. Limits for working hours and overtime for this age group should be set with special consideration to the workers’ young age.

In countries where the law permits apprenticeship programs for children between 12 and 15 years of age, we will accept that children of this age work a few hours per day. The total numbers of hours spent daily on school and light work should never exceed 7 (seven) hours (ILO convention No. 33). The factory must be able to demonstrate that this work does not interfere with the child’s education, that the work is limited to a few hours per day, that the work is light and clearly aimed at training, and that the child is properly compensated. If we have any reason to doubt that these conditions are met, such apprenticeship programs will not be accepted in factories producing products for Splitvision.

We firmly require that the supplier uses no factory that employs children. We are concerned about the situation of children in many parts of the world. We acknowledge the fact that child labor does exist and cannot be eradicated with rules or inspections, as long as the children’s social situation is not improved. We want to actively work suppliers and with non-government organizations in developing countries and seek opportunities to improve the situation for the children affected by our ban on child labor. If a child is found working in any of the factories producing our products, we will request the supplier to ensure that the measures taken are in the child’s best interest. We will, in cooperation with the supplier, seek to find a satisfactory solution, considering the child’s age, social situation, education, etc. We will not ask a supplier or factory to dismiss a child without discussing about the child’s future. Any measures taken should always aim to improve, not worsen, each individual child’s situation. The factory should cover any costs for education etc. We also recommend suppliers that use factories with predominantly female workers to arrange day care for children below school age.

4.2 Work safety

We require our suppliers to prioritize worker safety at all times. First-aid equipment must be available in each factory, and at least one person in each department must have training in basic first aid. We do not accept factories using hazardous equipment or unsafe buildings without safety measures.

We recommend that a doctor or nurse should be available on short notice, in case of an accident in the factory. The factory should cover all costs for medical care of worker injuries sustained on the job, if not covered by the social security.

The factory should have clearly marked exits and, preferably emergency exits on all floors. All exit doors must open outwards. Exits must not be blocked by cartons, fabric rolls or debris, and should be well-lit. If emergency exits are locked, the keys must be placed behind breakable glass next to the doors, ensuring they are accessible to all staff at all times.

All workers must be trained and knowledgeable about the factory’s safety procedures, including emergency exits, fire extinguishers, first-aid equipment, etc. An evacuation plan must be displayed throughout the factory. The fire alarm must be tested regularly, and regular evacuation drills are required.

4.3 Worker’s right

We respect the rights of all workers, in alignment with the legal requirements of the International Labour Organization’s (ILO) core conventions. All workers at our suppliers must be entitled to their basic rights.

Under no circumstances does Splitvision accept:

• The use of bonded labor, prison labor, or illegal workers for manufacturing products or providing services for Splitvision.
• Suppliers or their subcontractors using corporal punishment, mental or physical disciplinary actions, or engaging in sexual harassment.
• Any disciplinary actions against workers who peacefully and lawfully organize or join an association.
• Any dismissal of pregnant employees.

All workers must be entitled to an employment contract. If foreign workers are employed on a contract basis, they must never be required to remain employed against their will for any period of time. The employer must cover all commissions and other fees to recruitment agencies related to their employment. No worker must be discriminated against based on race, gender, religion, or ethnic background. All workers with the same experience and qualifications must receive equal pay for equal work. All workers must be free to join associations of their choosing, and they must have the right to bargain collectively.

Wages must be fair and reflect work performance, and they must be paid on time. The legal minimum wage is a minimum, not a recommended level. Weekly working hours must not exceed the legal limit, and overtime must always be voluntary and properly compensated. Workers must be granted their stipulated annual leave and sick leave without any repercussions. Pregnant employees must be granted their stipulated maternity leave. In developing countries, we recommend our suppliers provide workers with at least one free meal per day.

4.4 Working environment

A safe and healthy working environment is essential for worker well-being and product quality. The factory environment must be clean and free from all forms of pollution, with appropriate protective measures in place. We require factories to ensure the following:

• The temperature is tolerable for a working environment, and ventilation is adequate. Heaters or fans must be provided when needed.
• Lighting at each workstation is sufficient for workers to perform tasks with good quality.
• Sanitary facilities are clean, and workers have access without unreasonable restrictions. Sanitary facilities are adequate for the number of workers on each floor, and available and preferably separated for men and women.

If housing facilities are provided by a factory for its staff, the work safety and healthy working environment requirements outlined above must also apply to the housing area. All workers must be provided with their own individual bed, and the living space per worker must meet the minimum legal requirements. Separate dormitories, toilets and showers should be provided for men and women. There should be no restriction on the workers’ right to leave the dormitory during off-hours. We emphasize the critical importance of fire alarms, fire extinguishers, unobstructed emergency exits, and evacuation drills in dormitory areas.

5. Respect for the Environment

The impacts of human activities and economic operations on the environment are of increasing global concern. Splitvision expects its suppliers to act responsibly regarding the environment and the Earth’s natural resources. We require that our suppliers and their subcontractors comply with all applicable environmental laws and regulations in their country of operation. We also require our suppliers to accept our environmental sustainability policy, which covers the following aspects, and encourage them to continuously improve their practices.

5.1 Forests and other ecosystems

We recognise that forests and natural ecosystems are vital for maintaining biodiversity, regulating the climate, and supporting the livelihoods of millions of people. We work to ensure our activities do not contribute to deforestation or forest degradation pursuant to Regulation (EU) 2023/1115. Additionally, we seek opportunities to prevent human rights violations and the conversion of natural ecosystems to other unsustainable land uses.

Splitvsion does not accept products derived from commodities that are associated with the conversation of forest to agriculture use (whether human-induced or not), the conversation of primary forests or naturally regenerating forests into plantation forests or into other wooded land, or the conversion of primary forests into planted forests, after 31 December 2020. Compliance with legal requirements governing forest management, harvesting, and trading activities is non-negotiable. Compliance with all legal requirements concerning biodiversity conservation, the protection of endangered species, and the trade of CITES-listed species is non-negotiable.

5.2 Chemicals and materials

The use of chemicals in products and operations is associated with human health and impacts on the environment. Compliance with all applicable regulations on chemicals is non-negotiable. Suppliers must accept our policy on chemicals and support us to minimize negative impacts on people and the environment. Splitvsion does not accept:

• The use of solvents or other hazardous chemicals restricted or banned by law in our products or in product production.
• changes or replacements of chemicals or materials without Splitvsion’s formal assessment and approval.

Upon Splitvision’s request, all our suppliers must provide information and/or certification documents on chemicals and materials, report the chemicals used, and provide a signed confirmation that no prohibited or banned chemicals are used in our products or their production by them or their subcontractors.

5.3 Waste and pollution

We strive to apply circular economy principles to all materials used for our products and packaging and work actively to minimize waste generation and pollution to the greatest extent possible.

We require our suppliers to ensure meeting all applicable legal requirements for waste management and environmental protection regarding air, soil, surface, and groundwater.

We encourage our suppliers adopting best practices in managing and minimizing the volume and negative impact of waste and pollution from their activities, including production, processing, or any other activities under their control. We promote recycling and reuse, and we actively test recycled materials in our products, especially for packaging materials using plastics.

5.4 GHG and climate change

We recognize that climate change is a pressing global challenge and it must be addressed through a comprehensive strategy. Our strategy and practices encompass increasing the use of renewable energy, reducing greenhouse gas emissions, implementing adaptation efforts proportionate to the risks of climate change, and pursuing GHG removal and ecosystem restoration initiatives throughout our operations and value chain.

We require our suppliers to actively adopt practices aligned with our approach and tailored to the scale and nature of their operations. We expect our suppliers’ support us in collecting data for life cycle assessment and/or carbon emission calculations for our products. We encourage them to continueously improve data quality and methodologies for emission calculations and to contribute to GHG removal and ecosystem restoration projects through internationally recognized certification or verification.

6. Implementation of This Policy

In order to ensure the success of our Responsible Sourcing Policy, we will carry out the following actions.

6.1 Due Diligence Processes

Splitvsion has established and implemented a documented due diligence system, to manage potential risks in conforming with the legal requirements and the requirements described above. These include ongoing assessments and a strategy for engaging with and monitoring our suppliers:

• We will ensure that information about suppliers and sources of material is collected and evaluated to enable traceability and effective risk assessment.
• We will conduct risk assessments on all suppliers and the supplies of relevant commodities and products to evaluate whether they meet the requirements of our policy.
• In case risks are identified and cannot be classified as negligible we will carry out appropriate actions to mitigate the potential risks.

6.2 Supplier Engagement and Capacity Building

We will engage with suppliers to communicate key aspects of this policy and clarify conditions and expectations. We will support the alignment of our suppliers’ operations with our policy by providing resources, training and support, especially to those who need more assistance.

6.3 Communication

We strive for open, transparent, and meaningful dialogue with all our stakeholders, including customers, suppliers, community members, and industry partners. Regular updates, reports, and discussions ensure that our stakeholders are well-informed about our practices, progress, and challenges in our supply chain. We believe that this inclusive approach to communication not only enhances our policy’s effectiveness but also contributes to the overall sustainability and integrity of our operations.

6.4 Complaints Mechanism

We recognise the importance of an accessible and responsive complaints mechanism as a key aspect of responsible business practice. We ensure that every complaint is addressed promptly and effectively while upholding the principles of fairness and respect for all parties involved. This approach underscores our dedication to continuous improvement and accountability in our operations.

If you wish to voice your concern about or report a potential or actual violation of our Responsible Sourcing Policy please contact through the channel stated in section 1.

7. Review and Adaptation of This Policy

We monitor our internal systems and procedures which underpin the implementation of this Responsible Sourcing Policy. As necessary and applicable, access will also be made for external evaluations of the performance of the relevant systems in place, to ensure that they are implemented and functioning as intended.

Adaptions will be made to both the Responsible Sourcing Policy and the relevant systems and procedures, in response to new insights, changes in international norms or regulatory requirements, and stakeholder feedback. This dynamic approach allows us to be agile and responsive to emerging challenges and opportunities, ensuring our policies not only meet current sustainability standards but also anticipate future needs and trends. Through this continuous improvement process, we reaffirm our commitment to sustainability, ethical practices, and social responsibility.

Over time, we expect to continuously raise the sustainability standards of our sourcing activities by improving their credibility and robustness of our sourcing activities, certification and verification standards and sourcing requirements.