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

2. KONE Corporation
Confidential | © KONE Corporation

3. 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)
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4. 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

5. We encourage employees who have a compliance question or concern to speak up
Reporting channels
Manager, Legal, HR or Compliance
Compliance by (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 (resulting in 16 investigations)
KONE does not tolerate retaliation against anyone who makes a report in good faith.
25 October 2019
Confidential | © KONE Corporation

6. 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

7. 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

8. 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

9. 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?

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