20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

The adherence to laws and regulations is important in conducting our business. We not only require compliance with our Code of Conduct but rather we want to build on experience and ensure that our staff and business partners share the same understanding of compliant behavior and business
dealings.

We introduced a compliance management system in 2012, which is continuously improved. The Fenix Outdoor CMS concept complies with the standard IDW PS 980 and ISO 19600. As with our sustainability report, the CSO submits an annual compliance report to the CEO and the board. Risks in compliance related terms arise from our global supply chain and from business udertakings in risk countires. However, the CSO and the CEO together have drawn-up a list of no-go countries and frequently monitor corruption and political risks developments. Following the Compliance Guideline, the Chief Compliance Officer (CCO) submitted his annual report to the board in April 2018. As part of the compliance system, all managers are obliged to sign and declare on an annual basis that they are following the compliance rules and that staff members are aware of the system. We held two Compliance Committee meetings at Globetrotter level.We had no cases of corruption and achieved compliance and dialogues about our compliance rules throughout the company during various trainings and refresher trainings.New restrictions in offering/receiving invitations and gifts have been imposed. For more information, see compliance table on page 10 in CSR Report 2018. Our compliance system is working and all our goals (see Fenix Way) have been achieved thusfar.