1 Compliance and responsibility

1.1 We observe our Code of Conduct

The Code of Conduct of Kojamo Group (hereinafter referred to as “Kojamo”) is a set of guidelines, created for the benefit of our personnel, describing the practices applied by Kojamo in all interaction and communication with our stakeholders, society and the environment. The Code of Conduct applies to all units and functions.

All of Kojamo’s current and new employees are required to observe this Code of Conduct and act responsibly and transparently. Employees are required to participate in training on the Code of Conduct and everyone is required to report any misconduct witnessed by them.

Our cooperation partners are also required to commit to a corresponding set of guidelines on responsible business known as the Code of Conduct for Suppliers.

Our operations are firmly founded on our core values: happy to serve, strive for success and courage to change.

Happy to serve

• Our service is high-quality, professional, friendly and respectful of the customer.
• We want to listen to and understand the customer and solve the customer’s needs.
• We treat and serve each person as an individual.
• We earn our customers’ trust each day.

Strive for success

• We want to always do things better, achieve results and accomplish our goals.
• We bear responsibility for our work and we take pride in our results.
• We value each other’s expertise and we work together.
• We encourage each other. We recognise each other’s strong performance.
• We do what we promise.

Courage to change

• We have an open-minded attitude towards change. We dare to look for new ideas and best practices by challenging conventional ways of working.
• Development may include experimentation and we are not afraid to try new things. We learn from our mistakes.
• We are also a pioneer in the use of new technologies.
• Renewal requires that we continuously learn new things.

1.2 Compliance with laws and regulations

Kojamo operates in full compliance with laws and regulations. Kojamo operates in an honest and fair manner and refrains from any activities that might compromise this commitment.

All Kojamo employees are required to be familiar with the laws and regulations applicable to their work.

2 Responsibility for the personnel

Competent and healthy employees play a central role in enabling Kojamo to achieve its goals. We respect the human rights defined in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. We comply with the current employment legislation and collective bargaining agreement as well as the Group’s personnel policy. We offer our personnel a safe and healthy working environment and we invest in the occupational well-being and safety of our employees in various ways.

Kojamo applies equal and fair operating models in all functions and job roles to ensure the equal treatment of employees throughout the employment relationship, starting from recruitment. Everyone is treated equally at work regardless of their ethnicity, gender, age, mother tongue, origin, political and religious beliefs, sexual orientation, marital status, disability and any other factors.

Kojamo does not condone any discrimination or harassment against employees, cooperation partners or stakeholders.

Kojamo supports the freedom of association and the right to unionise.

3 Responsibility in operations

3.1 Bribery and hospitality

Neither Kojamo’s personnel nor anyone representing the Group are allowed to offer, give or accept bribes. All forms of bribery and corruption are prohibited. No inappropriate financial benefit shall be offered to business partners or public officials with the purpose of promoting the business operations of the Group or gaining any other advantage for the Group, where such benefits can be considered to be aimed at influencing decisions or gaining preferential treatment or where such benefits may otherwise seem inappropriate.

In accordance with Kojamo’s hospitality guidelines, accepting and offering gifts and benefits is allowed if they are occasional, minor and reasonable in terms of amount and value. Accepting or offering gifts of money – including cash and securities – is prohibited under all circumstances. Accepting or offering gifts or benefits of any kind is also prohibited in connection with contract negotiations.

3.2 Environmental responsibility

We observe the principles of sustainable development in everything we do. We take environmental impacts into consideration and prevent and reduce them in all of our operations, in line with our objectives, throughout the life cycle of our housing stock. We promote the circular economy as well as energy and material efficiency. We develop new and modern construction solutions, housing services and ecological innovations related to energy-efficient housing solutions. We operate in full compliance with existing environmental legislation, regulations and permits.

3.3 Purchases

Kojamo’s purchasing function is based on safe, sustainable, reliable and cost-efficient purchasing that takes into account the full life cycle and processes of the products and services involved. We observe sustainable principles in all our purchasing and seek to conserve raw materials, energy and natural resources wherever possible.

Kojamo’s purchasing is carried out on market terms in accordance with good business practice and, as a rule, most purchasing activity is subjected to competitive tendering. Whether a competitive tendering process is required, and the exact extent of such a process, is determined by the value of the prospective purchase. All purchases are made on the basis of formal quotations submitted following a tender request.

Any parties that are in a regular business relationship with Kojamo and part of the supply chain must observe the provisions of the Contractor’s Obligations Act, other applicable legislation and Kojamo’s Supplier Code of Conduct.

Kojamo treats partners equally, openly and fairly. The business activities of a supplier and Kojamo must not be significantly dependent on each other based on an overall assessment.

As a rule, purchases from companies with which a Kojamo employee who participates in negotiations or decision-making processes pertaining to the purchase or competitive tendering is closely associated through a close business, family or friendship relationship is prohibited. If an employee who is in a relationship of the aforementioned nature does not participate in negotiations or decision-making processes pertaining to the purchase or competitive tendering, purchasing from such companies is possible. However, employees are required to report any potential conflicts of interest to their supervisor before a purchasing or competitive tendering process is carried out.

Our purchasing activities are governed in more detail by our Supplier Code of Conduct and the Group and Unit -level purchasing principles.

3.4 Competition

Kojamo’s operations are based on open and fair competition. Kojamo is committed to complying with competition legislation in all of the Group’s operations. If Kojamo has a dominant market position, Kojamo shall not abuse it.

4 Conflicts of interest

All actions and decisions by Kojamo’s management and employees must be solely in Kojamo’s interest in a manner that does not involve conflicts of interest of any kind. They must support the implementation of Kojamo’s strategy and the related objectives. The management and personnel shall not undertake any activities that could lead to a conflict between their personal interests and the interests of the company, the company’s business partners, customers or other stakeholders.

As a listed company, Kojamo plc observes the Finnish Securities Market Act, the EU Market Abuse Regulation and other applicable rules and regulations (including Kojamo’s insider guidelines), which prohibit employees, managers and Board members from directly or indirectly participating in insider trading or disclosing inside information without authorisation.

It is also against our Code of Conduct to take advantage of, disclose or use confidential information that has come to an employee’s knowledge on the basis of their position or duties.

Kojamo does not offer direct or indirect financial support to political parties, organisations or individual politicians.

5 Protection of property and information

Kojamo’s property – including intangible assets, resources, premises, buildings and equipment – is intended to be used only for Kojamo’s business purposes. All Kojamo employees are required to protect Kojamo’s property, and Kojamo’s property and resources shall not be used for illegal or unethical purposes. The same applies to all property of business partners that is in Kojamo’s possession.

When handling confidential information and personal data, it is necessary to always observe an especially high standard of responsibility and confidentiality as well as the applicable laws and regulations, data security practices, data protection practices and Kojamo’s internal policies, procedures and guidelines. Kojamo respects its customers’, employees’ and other related individuals’ right to privacy protection with regard to personal data.

We are open and transparent in our communications. Kojamo’s communications with the capital markets must ensure that all market participants have simultaneous access to equal, fair, sufficient and accurate information about the company, its business operations, objectives, strategy and financial position to determine the value of Kojamo’s securities. Public statements about Kojamo can only be issued by designated individuals.

Activities on social media are governed by the same principles as other communications and interaction.

6 Sponsorship

Sponsorship is part of Kojamo’s marketing communications and its purpose is to promote the Group’s positive public image. Sponsorship activities are carried out in a planned and transparent manner. The recipient of sponsorship must be in line with Kojamo’s values and Code of Conduct. Decisions on Kojamo’s sponsorship activities are made by the Management Team and a separate advisory panel.

7 Violations of the Code of Conduct

All Kojamo employees shall strive to prevent violations of this Code of Conduct and report any violations without delay.

Possible observations of any unethical activities or other malpractice must be reported whenever there are grounds to do so. Any non-compliance must be primarily reported to the line manager. If this is not possible, the employee may contact the line manager’s manager, the HR unit or the internal audit function.

Kojamo uses a whistleblowing system to facilitate the anonymous reporting of violations of the Code of Conduct. An employee who sincerely reports any potential violations shall not suffer any negative impact on their current or future career. Reported cases are processed as quickly as possible, in strict confidence and impartially.

Violations of the Code of Conduct lead to appropriate sanctions and disciplinary action. The consequences range from admonitions to the termination of employment. Violations may also lead to consequences under civil or criminal law.

If you have any questions regarding appropriate conduct, contact your supervisor, other members of the management or the legal affairs unit.

This Code of Conduct was approved by Kojamo’s Board of Directors on 12 February 2025.

1 Responsible operations and legal compliance

Kojamo Group (hereinafter referred to as “Kojamo”) is committed to operating responsibly and transparently and in full compliance with laws and regulations. We demand that our cooperation partners throughout the supply chain observe the same standards of responsibility as well as the laws, regulations and national and international agreements that govern their operations.

This Supplier Code of Conduct is a set of guidelines drafted for Kojamo’s cooperation partners, and all of the participants of our supply chain are required to observe the principles described herein. The Supplier Code of Conduct applies to all of Kojamo’s purchasing activities. Our partners are responsible for their subcontractors’ ethical operating practices, the control thereto, and the responsibility and legality of their operations in accordance with this Supplier Code of Conduct.

2 Conflicts of interest

Kojamo and its cooperation partners shall steer away from any activities where the interests of the parties conflict. The business activities of a cooperation partner and Kojamo must not be significantly dependent on each other based on an overall assessment.

The cooperation partner, its person in charge or its beneficial owner should not be closely associated to a person working in Kojamo through a close business, family or friendship relationship. If an employee, who is in a relationship of the aforementioned nature, does not participate in negotiations or decision-making processes pertaining to the purchase or competitive tendering, purchasing from such companies may be
possible in case it is the most economically advantageous to Kojamo’s.

3 Anti-grey economy efforts

Kojamo’s anti-grey economy models exceed the legislative requirements in many respects. Partners who are in a business relationship with Kojamo and participate in the supply chain shall observe the provisions of the Act on the Contractor’s Obligations and Liability when Work is Contracted Out (Contractor’s Liability Act) and other applicable legislation. Kojamo’s cooperation partners shall comply with all laws and regulations pertaining to taxation and money laundering as well as all applicable economic and trade sanctions.

Our partners are required to join the Reliable Partner service maintained by Vastuu Group Oy and the related reporting shall be kept up-to-date throughout the duration of the agreement. We monitor the information required by the Contractor’s Liability Act for all of the companies in our purchasing network.

4 Responsibility for the personnel

Our cooperation partners shall comply with the current employment legislation and collective bargaining agreements in all of their operations as well as regulations governing occupational health and safety, and commit to promoting these. Our cooperation partners shall also respect the human rights defined in the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work.

Our cooperation partners shall respect employee rights. Our cooperation partners shall commit to the equal treatment of employees regardless of their gender, age, origin, language, political and religious beliefs and any other factors. We do not condone any form of discrimination, harassment, bullying or threats in our cooperation partners’ operations. We do not condone the use of illegal labour, forced labour or child labour in our supply chain. If the countries of operation in our cooperation partner’s own supply chain does not have national legislation that prohibits the use of child labour, our partner shall implement regular procedures to ensure that no-one under the age of 15 is employed in the supply chain.

Our cooperation partners shall ensure safe and healthy working conditions for their employees in accordance with all applicable laws and regulations.

Our partners shall ensure that their employees act irreproachably and provide their employees with the freedom to unionise.

5 Bribery and corruption

Our cooperation partners shall not offer, give or accept bribes. All forms of bribery and corruption are prohibited in Kojamo Group’s supply chain.

Our cooperation partners shall not offer any inappropriate financial benefits to representatives of Kojamo or public officials with the purpose of promoting business operations or gaining any other advantage, where such benefits can be considered to be aimed at influencing decisions or gaining preferential treatment or where such benefits may otherwise seem inappropriate. Our current or potential cooperation partners shall not offer any bribes or benefits to Kojamo’s representatives in connection with contract negotiations.

6 Environmental responsibility

Our cooperation partners shall observe the principles of sustainable development in everything they do.

Our cooperation partners shall have a sufficient environmental management system, environmental programme or similar system that defines the general operating principles for promoting environmental responsibility and reducing environmental impacts. Our cooperation partners shall comply with the provisions of environmental legislation, decrees and permits. Our partners shall strive to reduce their environmental emissions, use eco-friendly products and improve their energy and resource efficiency. Our cooperation partners shall only hand over waste to parties that have the required permit to receive waste.

7 Protection of property and information

When handling confidential information and personal data, our cooperation partners shall always observe an especially high standard of responsibility and reliability as well as the applicable laws and regulations, data security practices, data protection practices and any detailed policies and guidelines potentially issued by Kojamo.

Kojamo’s property – including intangible assets, resources, premises, buildings and equipment – is intended to be used only for Kojamo’s business purposes. Kojamo’s property and resources shall not be used for illegal or unethical purposes. The same applies to all property of our cooperation partners that is in Kojamo’s possession.

All communication pertaining to Kojamo or related to cooperation with Kojamo shall only be undertaken with Kojamo’s consent and in cooperation with Kojamo.

8 Monitoring and reporting

We monitor the quality and performance of our partners in an appropriate manner. Our cooperation partners shall have appropriate and reliable operating methods and they shall be capable of offering a high level of delivery reliability. We ensure that our suppliers deliver high quality reliably by undertaking regular monitoring and collaboration and by using performance indicators set for our partners.

Where necessary, our partners must report to Kojamo on their operations in accordance with this Code of Conduct and their key sustainability indicators. The said information may be relevant to Kojamo for example regarding sustainability reporting.

Compliance with the Supplier Code of Conduct and other topical matters related to sustainability will be discussed in regular intervals as part of the annual cooperation meetings between Kojamo and the partner.

Kojamo also reserves the right to conduct also sustainability audits as part of its annual audit plan. The cooperation partner must participate free of charge at least to the first audit of a calendar year.

9 Violations of the Supplier Code of Conduct

All of our cooperation partners shall comply with this Supplier Code of Conduct.

In the event that a partner is found to be operating in violation of this Supplier Code of Conduct, we shall terminate our cooperation with the partner with immediate effect. Violations may also lead to consequences under civil or criminal law.

Any observations of conduct in violation of the Supplier Code of Conduct must always be reported to Kojamo’s contact person without delay. Kojamo uses a whistleblowing system to facilitate the anonymous reporting of violations of the Supplier Code of Conduct. Any party who sincerely reports any potential violations shall not suffer any negative consequences. Reported incidents are processed as quickly as possible, in strict confidence and impartially.

This Supplier Code of Conduct was approved by Kojamo’s Board of Directors on 12 February 2025 and it replace the Supplier Code of Conduct approved on 15 February 2024.