KONE Corporation Compliance Investigations Suzanne Innes-stubb Head of global compliance Mont blanc circle retreat 12-13 april 2018 25 October 2019 Confidential | © KONE Corporation

KONE Corporation Confidential | © KONE Corporation

Compliance supports our strategic targets and helps us to Win with Customers To maintain customer trust To ensure employee confidence (recruitment and retention) To minimize risk (financial, reputational, resources) To help business do its job (through advice, tools and processes) TO MINIMISE RISK We face increasing compliance obligations and risks We want to avoid financial penalties (e.g. competition, sanctions, anti-bribery/corruption laws), including penalties/imprisonment for individuals, fines/debarment for companies We need to mitigate reputational risk Any breach would seriously impact our customer relationships and our employees TO HELP BUSINESS DO ITS JOB We want to avoid disruption to business operations (e.g. smooth compliance processes to avoid delays to customers) Confidential | © KONE Corporation

KONE Compliance Organisation Head of Global Compliance + 3 FTE in HQ Finland Compliance Director + 1 FTE for North America VP Compliance + 5 FTE for Greater China Global Compliance Committee meets quarterly (EVP HR, EVP CFO, EVP M&A and Legal Affairs, Head of Global Compliance) Regional Compliance Committees for North America and Greater China also meet quarterly 25 October 2019 Confidential | © KONE Corporation

We encourage employees who have a compliance question or concern to speak up Reporting channels Manager, Legal, HR or Compliance Compliance by email (Global, North America, Greater China) Compliance Line Confidential web/phone SpeakUp® system hosted by People Intouch Available in 60+ KONE countries and 40+ languages Separate hotline by Lighthouse in North America For reports of serious misconduct Approx. 35 reports since January 2017 (resulting in 16 investigations) KONE does not tolerate retaliation against anyone who makes a report in good faith. 25 October 2019 Confidential | © KONE Corporation

How does the Compliance Line work in practice? 1. Employee makes a report using the Compliance Line via phone or web in his/her native language 2. Third party (People Intouch) translates the message to English and posts the translated (or transcribed) message in the system. EMPLOYEES 3. Global Compliance Team receives notification of a new message on the system. Global Compliance reads the message and posts a reply. GLOBAL COMPLIANCE TEAM People can remain anonymous in this process. But providing details with help us with the investigation. If reluctant to identify oneself at least provide some evidence – screenshots, names, documents --- to help with the investigation. Is the message really confidential? Yes. Only the Head of Global Compliance and Compliance Manager can access the system to see messages and communicate with the messenger. 4. Employee can access the reply in the system in his/her own language and post a new comment/upload documents. 5. The cycle continues and the case may lead to an internal investigation. 25 October 2019 Confidential | © KONE Corporation

Investigation process Step 1 Assessing the allegation How did the issue arise? Confidentiality Step 1 Initial actions Step 2 Planning the investigation Step 3 Collecting and evaluating information/evidence Step 4 Reporting Step 5 Remediation & sharing learnings Step 6 Closing the case Step 6 By Global Compliance Step 2 Team (internal/external) Scope Evidence Interviewees, Schedule Step 5 Especially control or process weaknesses Step 3 Document review Forensic analysis Interviews Step 4 Local to Global Compliance 25 October 2019 Confidential | © KONE Corporation

Investigations 2017 INVESTIGATIONS Total in 2017 (whether or not substantiated) Material cases 57 All cases 110 Key materiality criteria All allegations of corrupt practices or competition law related cases Involvement of local management or widespread practice May lead to dismissal of an employee Loss of €5000 or more Authority investigations 10/25/2019 Confidential | © KONE Corporation

QUESTIONS FOR GUIDANCE Does this feel right to you? Does it comply with laws and regulations? Does it follow our KONE Code of Conduct, policies and values? Would your manager approve? Would you be comfortable reading about your action in the local news or social media? If you answer “Yes” to each question, go ahead! If you answer “No” to any question, STOP and ASK! 1. Does this feel right to you? At the end of the day, you know the difference between right and wrong. Consider the morality of the situation. 2. Does it comply with laws and regulations? Obviously everything that we do has to be legal. If you are unsure about whether something is legal or not, don’t act. Contact management, legal, or compliance for guidance first. 3. Does it follow our KONE Code of Conduct, policies and values? A sure way to judge a situation is to start by checking the KONE Code of Conduct. Familiarizing yourself with the full content will help make you every step of the way. 4. Would your manager approve? Ask yourself, “What would your manager say about this situation?” 5. Would you be comfortable reading about your action in the local news or social media? If your actions were covered in a report by your local news station, would it be a good or bad message for yourself and KONE?

Confidential | © KONE Corporation Subtitle Arial 20pt all caps 25 October 2019 Confidential | © KONE Corporation