The Code of Conduct (“Code”) contains general standards of conduct applicable to all Keter Group employees across the globe. It should be used as a guide to your daily business practices, whenever and wherever you are conducting Keter business. Our reputation depends on the moral, ethical and legal behavior of all our employees. Our leadership team is responsible for setting and maintaining the standards of business ethics for our Company and its employees. Each of us is expected to act with the highest degree of integrity, honesty and professionalism and abide by this Code at all times. The Code is not intended to be an all-encompassing list of rules or laws that may apply to you, but the guidelines contained in this Code are to assist you in making the right decisions every day. If you have any questions about this Code, please discuss with a member of management or Human Resources. Additional helpful resources such as the Keter Group Anti-Corruption Policy, Keter Group Work Relationship Policy, Keter Group Privacy and Data Protection Policy and the Keter Global IT Policy as well as regional employee handbooks are available to you for further information and guidance. If you have any questions regarding this code, please contact your Manager or Human Resources.

The Code of Conduct is designed to work in conjunction with and in support of our Keter DNA: Innovation, Accountability, One Team, Respect, Entrepreneurship and Agility. All Keter employees are expected to behave in a way that demonstrates our company’s values in all business interactions.

All Keter employees are expected to conduct business in a professional manner. Employees are strictly prohibited from any conduct or relationship with any vendor, supplier, customer, contractor, family member or other person or organization that might be perceived as a conflict of interest. As employees, we must ensure that our personal interests do not conflict with our responsibilities to the Company. We must avoid even the appearance of a conflict of interest. Examples may involve: outside employment, an employee or his or her family member with a significant financial interest in an outside enterprise that does business with, or is a competitor to the Company, an employee’s family member who receives personal benefit because of the employee’s role with the Company, or any other arrangement including family or other personal relationships which may dissuade the employee from acting in the best interest of the Company. If a potential conflict of interest exists, employees must notify their manager immediately.

No person is authorized to offer or accept anything of value to or from a customer or supplier. Business meals are to be given or accepted only if intended and understood as a simple business courtesy meant to further communications or goodwill. In any event, employees should ensure that the meal is consistent with customary business practices, is reasonable in cost, and not intended to influence or give the appearance of influencing the recipient. Cash gifts of any kind are strictly prohibited. If you have any questions on this policy, review with your manager prior to proceeding.

All Keter employees are expected to treat one another professionally and with dignity and respect. Keter is committed to equal employment opportunity and a diverse workforce. Keter does not discriminate against any employee or applicant for employment because of race, color, religion, sex, disability, sexual orientation, gender identity, genetic information, marital status, national origin, age, ancestry, pregnancy, veteran or military status, or any other protected category with respect to any terms of employment. The Company does not tolerate harassment of any kind. Harassment can reasonably interfere with an individual’s work performance or create an intimidating or offensive work environment. Harassment has the potential to impact an employee’s overall health and wellbeing and will not be permitted. Employees who are aware of any suspected discrimination or harassment should report to Human Resources immediately. No employee will suffer any adverse action for reporting in good faith any suspected violations of the Code or questioning any employment practice.

The health and safety of all our employees is of utmost importance to Keter. Each of us is responsible for working safely at all times and complying with company and plant safety policies and procedures and all applicable health and safety laws. Any safety incident or potential safety risk must be reported immediately to the EH&S Manager and your supervisor.

All information the Company produces is considered a record. Examples include financial, accounting, technical, sales, production information, personnel information, safety data, contracts, and manufacturing processes, marketing information and business plans. Employees must ensure that all company records are accurate and clearly describe relevant facts.

All employees are required to safeguard confidential information they may have access to. Employees shall only use Keter confidential information for authorized Company business and only as authorized by Company management. Company confidential information should only be shared with Keter employees on a need-to-know basis. Confidential employee information should never be disclosed or distributed to anyone outside the Company except by authorized members of Human Resources, and only when required. The responsibility to keep information confidential extends beyond an employee’s employment with Keter. Employees acknowledge that the Company has the right to take legal measures, if necessary, to protect confidential, proprietary or private information belonging to the Company if any employee fails to maintain confidences after their employment is discontinued.

Proper protection and use of company resources is the responsibility of each employee. While limited personal use of certain resources is permissible, employees should never take this for granted or assume that we have a right to privacy when using these resources. Company assets include physical property, information, data, records and intellectual property. Company assets include computers, networks, internet access, software, telephone and voice mail systems, and personal digital devices. Employees must safeguard these resources and protect company data stored on these systems.

Supervisors have added responsibilities under the Code. They must ensure that those they supervise understand this Code and what applies to them. They have an obligation to enforce this Code and report any suspected Code violations. As a member of management, supervisors are expected to set the tone for their department, and proactively demonstrate and communicate their commitment to the Code. All supervisors are expected to role model the behavior described in the Code of Conduct.

Any suspected violations of this Code can be reported to your Manager, Human Resources or any member of Management. Additionally, if you prefer to place an anonymous report in confidence, you can use our hotline, hosted by a third-party provider, EthicsPoint. The information you provide will be sent to us by EthicsPoint on a totally confidential and anonymous basis if you so choose. Violations can be reported by phone and on-line (EthicsPoint - Keter Group). Every effort will be made to investigate all reported violations promptly and confidentially. While anonymous complaints are welcome, enough details need to be provided so that a proper investigation can be conducted. It is the goal of any investigation to uncover the facts and resolve issues. Keter will not tolerate retaliation of any kind towards employees that report violations of the code in good faith. Knowingly making a false or untrue accusation of another employee is also a violation of the Code of Conduct. Employees that are found to have violated this Code will be subject to disciplinary action up to and including termination of employment.