1. Purpose and Scope

For the PMC Hydraulics Group to grow responsibly, create lasting value, and contribute positively to society, it is essential that all companies within the Group are guided by shared values and a common approach to how we conduct our business. This means acting consistently across the Group, taking responsibility for our sustainability impact, and showing respect for people, relationships, and the environment in which we operate.

We believe that responsible business is rooted in integrity, sound judgement, and accountability. These principles define the culture we seek to build and shape how the PMC Hydraulics Group is experienced by employees, partners, and the wider community. Each of us plays an important role in upholding these values through our decisions and actions.

This Code of Conduct (the “Code”) is a cornerstone of our governance framework. It sets out the ethical principles and standards that guide our behaviour as an employer and our interactions with colleagues, customers, suppliers, shareholders, business partners, and the communities in which we operate.

Together with the other governing documents of the group, this Code applies to everyone working for or representing the PMC Hydraulics Group, regardless of role, position, or form of employment. All individuals covered by the Code are expected to understand its content and comply with its requirements.

The Code complements applicable laws, internal policies, and local procedures. Where differences arise between local law and the Code, the stricter requirement applies.

The PMC Hydraulics Group operates with decentralised leadership and local responsibility. This model depends on professionalism, sound judgement, and personal integrity at every level of the organisation. Local management is responsible for communicating and implementing the Code, providing appropriate training, and monitoring compliance. Every employee is responsible for applying the Code in their daily work.

2. Integrity in Business Operations

Within the PMC Hydraulics Group, we conduct our business honestly, responsibly, and with respect for fair and open markets.

Compliance with Laws and Regulations

We are committed to conducting our business in full compliance with all applicable laws and regulations in every country where we operate. Acting lawfully is fundamental to building trust, protecting our reputation, and operating responsibly.

Compliance goes beyond meeting minimum requirements. It requires sound judgment, integrity, and awareness of how our actions affect colleagues, partners, customers, and society. We are all expected to understand the legal obligations relevant to our roles and act accordingly.

We engage openly and professionally with public authorities, cooperating with regulators and law enforcement when required. We do not seek to influence decisions improperly and ensure that all information provided is accurate, complete, and timely.

When legal requirements are unclear, we seek guidance before acting. Compliance is a shared responsibility and a core part of how we conduct business.

Contributing to Fair and Effective Competition

Competition drives innovation, economic growth and prosperity. Our success is built on competing fairly, on the strength of our products, services and people, and we are committed to full compliance with all applicable competition laws and regulations. We must always act in accordance with the PMC Hydraulics Competition Instruction and ensure that our conduct, at all times, reflects this commitment.

What this means in practice

Competition law is complex and the consequences of non-compliance can be severe — both for the Group and for individuals personally. Breaches can result in significant fines, reputational damage and, in some jurisdictions, criminal liability. It is therefore essential that everyone within the Group understands the basic principles and acts accordingly.

Within the PMC Hydraulics Group, we:

Never agree or collaborate with competitors to restrict or distort competition, whether regarding prices, market sharing, bid rigging or any other form of anti-competitive coordination.
Never exchange competitively sensitive information with competitors, such as pricing, costs, capacity, strategy or customer data, whether directly or through a third party.
Recognise that competition laws apply not only to relationships with competitors, but also to our dealings with distributors and suppliers, including restrictions we may seek to impose on them.
Respect the special responsibility that comes with market strength. Where we hold a stronger position in a market, we take care not to abuse that position in a way that harms competition or customers.
Seek guidance before acting whenever a situation may raise competition concerns.

Conflicts of Interest

A conflict of interest arises when our personal interests, or those of people close to us, influence, or appear to influence, our ability to act objectively and in the best interests of the PMC Hydraulics Group. Even the appearance of a conflict can harm the Group’s reputation. We must therefore identify and handle all actual, potential, or perceived conflicts transparently.

We base all decisions on sound business judgment and arm’s length principles. We act loyally and keep personal interests separate from business decisions.

Personal interests include those of ourselves, our family members, close associates, or any entity we control. Examples include:

Ownership or board roles in a customer, supplier, or competitor.
Close personal relationships with business partners.
Gifts, payments, or benefits from parties we do business with.
Outside work or activities that compete with or affect our responsibilities.

What we must do

Be transparent: Disclose any actual, potential, or perceived conflict as soon as you become aware of it.
Step aside: Do not take part in decisions where a conflict may exist; ensure the matter is handled independently.
Keep interests separate: Do not let personal relationships or financial interests influence our decisions.
When in doubt, disclose: If unsure, seek guidance from a manager, your CEO or the Group Head of Compliance.

Failing to disclose a conflict or putting personal interests ahead of the Group’s is a serious breach of this Code.

3. Market Integrity and Confidential Information

Within the PMC Hydraulics Group, we do not engage in insider trading or misuse non-public information. Confidential and proprietary information, whether related to the PMC Hydraulics Group, our customers or partners, must be protected and used only for legitimate business purposes and in accordance with the law and the PMC Hydraulics Data Privacy Instruction.

Protecting Personal Data

We are committed to handling personal data responsibly and in full compliance with applicable data protection laws and regulations, including the EU General Data Protection Regulation (GDPR). Personal data, that is, any information relating to an identified or identifiable individual, must be collected, processed and stored lawfully, fairly and transparently, and only for specified and legitimate purposes. Anyone who handles personal data as part of their work must:

Process personal data only to the extent necessary for legitimate business purposes.
Keep personal data accurate, secure and confidential.
Never share personal data with unauthorised parties or use it for purposes other than those for which it was collected.
Report any suspected personal data breach to the relevant data protection contact without delay.

Protecting Confidential Information

In the course of our work, we regularly handle information that is confidential, whether it relates to the Group, our customers, suppliers, business partners or other third parties. Confidential information includes, but is not limited to, business strategies, financial data, customer and supplier details, technical know-how, pricing, contracts and any other information that is not publicly available and that could be of value to others if disclosed.

We are all required to:

Handle confidential information with care and discretion, both during and after their employment with the PMC Hydraulics Group.
Use confidential information only for legitimate business purposes and never for personal gain.
Never disclose confidential information to unauthorised persons, inside or outside the Group, without appropriate authorisation.
Ensure that confidential information shared with third parties is covered by appropriate confidentiality obligations.
Return or securely delete confidential information upon leaving the Group or upon request.

The obligation to protect confidential information continues after the employment relationship ends.

Information Security

The integrity, availability, and security of the PMC Hydraulics Group’s information and systems are essential to our operations and customer service. Cyber threats, data breaches, and unauthorised access can cause serious operational, financial, and reputational harm.

We are all responsible for protecting the Group’s information assets and must:

Use IT systems and devices responsibly and in line with company policies.
Never share passwords or access credentials.
Stay alert to phishing and other cyber threats, and report suspicious activity promptly.
Avoid installing unauthorised software or accessing systems or data beyond our role.
Handle sensitive information securely and report any actual or suspected security incident without delay.

4. Anti-Corruption and Financial Integrity

Within the PMC Hydraulics Group, we have zero tolerance for corruption, bribery, or financial crime and are all required to always act in accordance with applicable legislation and the PMC Hydraulics Anti-corruption Instruction.

Anti-Corruption and Bribery

We do not offer or pay bribes, kickbacks, or any other improper benefits to actual or potential customers, agents, contractors, suppliers, government officials, employees of such entities, or any other party.

Gifts, Hospitality and Benefits

When offering or accepting gifts, hospitality or expenses, you must always make sure that such benefits are not contrary to applicable legislation or constitute improper benefits as defined in the PMC Hydraulics Anti-corruption Instruction.

Financial Crime Prevention

The PMC Hydraulics Group has zero tolerance for financial crime. We do not engage in, facilitate, or knowingly support any form of financial misconduct, including, but not limited to:

Tax evasion, tax fraud or other fraud
Money laundering
Financing of terrorism or other criminal activities

All employees must ensure that financial transactions are lawful, transparent, and properly authorized. This includes:

Recording all transactions accurately, completely, and in a timely manner
Ensuring that transactions are supported by appropriate and truthful documentation
Never creating or using false, misleading, or incomplete records

We comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and tax laws in all jurisdictions where we operate. We must remain alert to unusual or suspicious transactions and report concerns promptly through established internal channels.

We do not attempt to circumvent financial controls, reporting requirements, or approval processes. If you are unsure whether a transaction or arrangement is appropriate, stop and seek guidance before proceeding.

Sanctions, Export Control and Trade Compliance

The PMC Hydraulics Group operates internationally and is subject to sanctions, export control laws, and trade restrictions in multiple jurisdictions. These rules protect international security and apply not only to sales, but also to the transfer of products, technology, software, and information.

We strictly comply with all applicable EU, UN, US, and local sanctions and export control regulations. We must:

Screen customers, suppliers, and business partners where required
Comply with restrictions related to countries, individuals, entities, products, and technology
Follow the PMC Hydraulics Sanctions and Export Control Instruction

We must never circumvent trade restrictions, directly or indirectly, or ignore warning signs related to sanctions or export control risks.

If you are unsure whether a transaction, destination, customer, or transfer of information is permitted, stop and seek guidance from the Group Head of Compliance, either directly or via local management, before proceeding. Non-compliance may expose both the PMC Hydraulics Group and individuals to severe legal and reputational consequences.

5. Know Your Business Partners

The PMC Hydraulics Group’s reputation is built not only on how we conduct ourselves, but also on the partners we choose to work with. When we enter into business relationships, whether with customers, suppliers, agents, distributors, joint venture partners or other third parties, we are, to some extent, associated with their conduct. It is therefore essential that we understand who we are doing business with and that our partners share our commitment to ethical and responsible conduct. Working with the wrong partner can expose the PMC Hydraulics Group to serious risks — legal, financial, and reputational.

What we expect

Before entering into a significant new business relationship, and on an ongoing basis where appropriate, we carry out proportionate due diligence on our business partners. The level of scrutiny should be proportionate to the nature, value, and risk profile of the relationship. This means we:

Verify who we are dealing with. We confirm the identity, ownership structure, and background of potential business partners before we commit to working with them.
Assess the risk. We consider the country or region in which a partner operates, the sector or industry involved, the nature of the business relationship, and any other factors that may indicate elevated risk — such as the involvement of government officials, connections to sanctioned parties, or unusual payment arrangements.
Look out for warning signs. We remain alert to red flags that may indicate that a business partner is not acting with integrity, including requests for unusual payment arrangements, a reluctance to provide basic information about their business, or a reputation inconsistent with our values.
Act on what we find. If due diligence reveals concerns about a potential or existing business partner, we escalate those concerns to management or Group Compliance. We do not proceed with, or continue, a business relationship if we know or reasonably suspect that it could expose the Group to legal or ethical risks.
Keep records. We document our due diligence process and findings in accordance with Group procedures and applicable law.

Our Partners’ Obligations

We expect our suppliers, agents, and other business partners to uphold standards consistent with this Code. Where appropriate, we include provisions in our contracts reflecting our expectations on anti-corruption, human rights, and ethical conduct. We reserve the right to terminate a business relationship where a partner is found to be in material breach of these standards.

6. Our People and Human Rights

Our people are our most important asset. Within the PMC Hydraulics Group, we are committed to fostering a safe, inclusive and respectful working environment where every individual is treated with dignity and where fundamental human rights are upheld. We work systematically to promote decent working conditions, reduce our negative environmental impact, and combat corruption, unethical business conduct and discrimination. We encourage an open, informal culture within each company and strive to offer everyone opportunities to develop and grow.

We are committed to acting in accordance with applicable laws and in compliance with the PMC Hydraulics HR Instruction. Our commitment to human rights and decent work is grounded in internationally recognised principles relating to human rights, fair labour practices and non-discrimination. These principles guide how we conduct our business and shape our expectations of suppliers and business partners in their own operations.

Human Rights and Working Conditions

We are committed to upholding and respecting fundamental human rights across our operations and our value chain. This means:

We do not tolerate child labour or forced labour in any form, whether in our own operations or those of our suppliers and business partners. We expect compliance with these standards throughout our supply chain and will take measures to address violations where they are identified.
We respect freedom of association and the right to collective bargaining, and we do not retaliate against anyone for exercising these rights.
We are committed to fair and lawful employment conditions. The salaries, working hours and benefits we offer must always comply with applicable local law and collective agreements.
We do not tolerate any form of human trafficking or modern slavery.

Where we identify actual or potential human rights violations in connection with our operations or supply chain, we are committed to taking appropriate action to prevent, mitigate and remediate such violations.

Diversity, Equal Treatment and Inclusion

We are committed to fostering a diverse and inclusive workplace where equality is embedded in all aspects of employment. We recognise that diversity strengthens our organisation, drives better decision-making and enhances our working environment for everyone.

We do not tolerate discrimination on any grounds, including gender, age, ethnicity, nationality, religion or belief, disability, sexual orientation or any other characteristic protected by applicable law. This applies across all aspects of employment, including recruitment, development, promotion, compensation and termination.

We do not accept harassment, threats, bullying, violence or any other form of inappropriate conduct. We are all entitled to work in an environment that is safe, respectful and free from any form of abuse or intimidation, and we each have a responsibility to contribute to that environment.

Recruitment and Selection

We are committed to fair, transparent and consistent recruitment processes based solely on merit, qualifications and business requirements. We treat all candidates with equal respect and give them fair consideration, regardless of background or personal characteristics.

Health, Safety and Wellbeing

The health, safety and wellbeing of our people, as well as the contractors and visitors who work alongside us, is one of our highest priorities and a core part of how we operate. We are committed to providing a safe and secure working environment for everyone and to the continuous improvement of our health and safety performance.

We systematically carry out preventive safety work to identify, assess and eliminate unsafe working conditions, and we ensure compliance with all applicable health and safety laws, regulations and internal procedures.

Our goal is zero accidents. To achieve this, we:

Actively identify, assess and manage health and safety risks on an ongoing basis.
Document all safety-related work, risk assessments and training activities.
Report all incidents, accidents and near-misses promptly and in accordance with Group procedures.
Ensure that any Lost Time Accident (LTA) is reported to the company’s CEO within 48 hours.
Provide all members of our teams with appropriate health and safety training for their role and working environment.
Actively promote a safety-first culture in which everyone feels empowered to raise safety concerns without fear of negative consequences.

We also recognise that wellbeing extends beyond physical safety. We take mental health, stress and work-life balance seriously, and we encourage an environment in which everyone feels able to speak openly about their wellbeing.

Compensation and Benefits

We are committed to providing fair and competitive compensation that reflects the role, responsibilities, market conditions and individual performance. The compensation and benefits we offer always comply with applicable local law and any relevant collective agreements.

Working Time and Leave

We recognise that adequate rest and time away from work are essential for well-being and long-term performance. We provide annual leave in accordance with local statutory requirements and Company policy, and we offer sick pay in accordance with statutory obligations and Company provisions. We also provide additional leave, including parental leave and other special leave categories, in accordance with local legal requirements and Company policy. The working hours we set always comply with applicable law and any relevant collective agreements.

7. Environmental and Social Responsibility

We believe that sustainable business is good business. As the PMC Hydraulics Group grows, we recognise that our responsibility extends beyond financial performance — to the environment, to the communities in which we operate and to society at large. This section sets out our commitments and expectations in respect of environmental and social responsibility, which we regard as fundamental to our long-term success.

Our approach is guided by internationally recognised principles and standards relating to human rights, labour conditions, environmental protection and responsible business conduct. These frameworks inform how we set priorities, manage risks and measure progress in our sustainability work.

Environmental Responsibility

We believe that an intelligent and proactive approach to environmental sustainability is essential for the PMC Hydraulics Group’s continued growth, development and profitability. We are committed to minimising the direct and indirect environmental impact of our operations and to contributing to a low-carbon, resource-efficient economy.

In practice, this means that we:

Integrate environmental considerations into important business decisions, from investment and procurement to product development and operations, in order to create long-term value for our customers, employees, shareholders and society.
Set clear targets for reducing our environmental footprint, including in respect of greenhouse gas emissions, energy consumption, water use and waste, and we work towards aligning our emissions reduction targets with the Science Based Targets initiative (SBTi).
Measure, monitor and report our performance on relevant environmental factors systematically and transparently, in accordance with recognised reporting standards and in response to the requirements of our customers, investors and other stakeholders.
Engage our supply chain, recognising that a significant part of our environmental impact occurs outside our direct operations. We expect our suppliers and business partners to share our commitment to environmental responsibility.
Comply with all applicable environmental laws and regulations, as a minimum standard, and strive to go beyond mere compliance where possible.

We are aware that many of the companies within our Group serve customers, including major industrial players, who apply rigorous sustainability ratings and impose specific environmental requirements on their supply chains. We take these requirements seriously and regard meeting them not only as a commercial necessity but as an expression of our own values.

Climate and Emissions

We recognise that climate change is a major challenge and that we have a responsibility to contribute to the transition to a low-carbon economy. We are committed to understanding and reducing our greenhouse gas emissions across our operations and value chain, including direct emissions, emissions from purchased energy and other indirect emissions. We also aim to set ambitious and credible targets to guide our efforts to reduce emissions over time.

Social Responsibility

Contributing positively to the communities in which we operate is integral to who we are as a company. We recognise that our operations have an impact that extends beyond our immediate business relationships, and we are committed to conducting ourselves in a way that benefits society more broadly.

In practice, this means that we:

Respect and support the communities in which we operate, engaging constructively with local stakeholders and seeking to understand and respond to their needs and concerns.
Create local value through employment, skills development, local procurement and investment, contributing to the economic and social fabric of the communities where our companies are based.
Uphold human rights throughout our operations and supply chain, in accordance with the UN Guiding Principles on Business and Human Rights and the ILO core conventions, as set out in greater detail in the Our People and Human Rights section of this Code.
Contribute to the UN Sustainable Development Goals that are most material to our business.
Engage responsibly with public authorities, trade associations and civil society organisations, and never seek to improperly influence public policy or regulatory processes.

Sustainability Ratings and Customer Requirements

We recognise that our customers increasingly assess their suppliers against sustainability criteria and expect demonstrable performance across environmental, social and governance (ESG) dimensions. We are committed to meeting these expectations and to maintaining the ratings and certifications required by our customers. We regard strong sustainability performance not only as a requirement but as a source of competitive advantage and a reflection of our values.

8. Company Assets

We protect all company assets, financial, physical, digital, and intellectual, from theft, loss, damage, misuse, or unauthorised access. Company assets must be used responsibly, with care, and primarily for legitimate business purposes, and misuse of assets or IT systems is not permitted. The same standard of care applies to the assets of our customers, business partners, and suppliers.

9. Speak Up

This Code applies to all entities, employees, and representatives of the PMC Hydraulics Group. Where any conflict arises between this Code and a local governing document, this Code shall take precedence, unless local legislation requires otherwise.

Each of us is individually responsible for reading, understanding, and complying with this Code.

We encourage everyone to speak up. If you become aware of, or suspect, a breach of this Code or of applicable law, you are expected to raise your concern promptly. You may do so by contacting the Head of Group Compliance or the Group CEO, either directly or through your manager, HR, or another appropriate corporate body.

Serious concerns may also be reported through our confidential whistleblowing service, which allows reports to be submitted both confidentially and anonymously. Where legally permissible, anyone raising a concern will have the option to remain anonymous.

We do not tolerate retaliation. The PMC Hydraulics Group is committed to ensuring that no one suffers any adverse work-related consequences as a result of raising a concern in good faith. Anyone who retaliates against a colleague for speaking up will themselves be subject to

10. Final Responsibility

This Code cannot cover every situation. You are expected to use good judgment and ask questions when in doubt. Acting with integrity means doing the right thing, even when it is difficult.