Code of Conduct

The objective of this Code of Conduct is to summarize the measures taken in a transparent form and to present them to the public.

The measures and behavioral objectives contained therein correspond to our lived awareness and serve, among other things, our Corporate Social Responsibility (CSR) principles. We are aware that most of the obligations of the Code of Conduct have already been lived by us and our employees as a matter of course for years.

However, we also know that there is always a need for further development and continuous improvement. Sustainability requires a change in thinking in many areas, which is initiated by a clear commitment on the part of our management and by our management setting an example.

New employees are personally handed the Code of Conduct by the HR department or their manager when they start work.

Our Code of Conduct applies uniformly to DS AUTOMOTION GmbH and its employees and employees for whom DS AUTOMOTION GmbH does not directly exercise the employer function. Foreign subsidiaries may take national peculiarities into account when implementing the Code of Conduct, if these override fundamental rules of conduct. Our Code of Conduct is to be understood as a binding basis for trust, reliability, transparency and quality and serves as orientation in our operational and strategic business. The Code of Conduct fulfills two tasks: On the one hand, it is intended to encourage our employees to act on their own responsibility and, on the other, it reflects the maxims of our corporate actions.

In our business relationships, we strive together with our national and international partners to disseminate the Code of Conduct's rules of behavior, for example in the areas of occupational safety and human rights. However, we would like to point out that no claims by third parties can be derived from the Code of Conduct.

As an internationally active company, we are committed to ethical principles in our business policy. In our own interest and in the interest of our employees, we want to avoid conflicts of interest or loyalty.

Our guiding principles in the area of business ethics are:

• Only gifts of negligible value may be accepted from our employees. These also include entertainment invitations within the framework of normal social customs.
• We are committed to fair, international competition and oppose all forms of corruption.
• In the event of indications of violations of business ethics, we report this immediately to one of our contact persons (direct supervisors or works council members).
• As a company, all our business activities are subject to laws, regulations and standards based on them. We must comply with international and national regulations as well as regional and local regulations, which relate to occupational safety or environmental standards, for example, and which may differ from one another.

We have set ourselves the goal of operating within these constantly changing frameworks and expect our employees to behave accordingly. It is a matter of course for us to take all measures ourselves. to inform our employees about the relevant laws and regulations or to instruct them in their application and implementation.

However, we do not only operate within the legal framework, but are also subject to societal, cultural and social rules in our various markets. We also take these into account in our decisions and actions as far as possible.

One of our primary goals is to meet or, if possible, exceed the requirements and expectations of our customers. We want to offer our customers adequate, efficient, reliable, cost-optimized, but also sustainable solutions in long-term business relationships.

Our guiding principles in the customer area are:

• We treat our customers fairly and in a service-oriented manner, responding to their needs and wishes as much as possible.
• We support fair competition and explicitly speak out against obstructions to legitimate competition such as price fixing.
• We provide our customers with comprehensive, truthful and up-to-date information.
• By adapting our range of services and providing ongoing training for our employees, we try to keep our finger on the pulse of the times and to always be at the cutting edge of technology. This also includes, for example, the use of environmentally friendly aids or alternative technologies.

With our partner companies and suppliers, we primarily strive for long-term business relationships based on mutual respect, trust and reliability. Together with our suppliers, we work on optimal solutions for our customers and also feel committed to sustainability in our relationship with suppliers.

Our partner companies and suppliers are required to communicate the Code of Conduct and the resulting obligations to their employees. Our business partners are also required to pass on these principles to their suppliers and to work to ensure compliance. In our ordering process, compliance with the contents of this Code of Conduct is required.

Our guiding principles in the supplier area are:

• Our suppliers & subcontractors are partners at eye level for us.
• Procurement processes are transparent and - despite long-term business relationships - are based on the principles of free competition.
• DS AUTOMOTION expects its suppliers to prohibit and refrain from any kind of child labor and forced labor in their companies. For the definition of child labor the regulations of the united nations apply.
• Suppliers who do not meet the required quality criteria or who do not duly consider occupational health and safety, safety and remuneration guidelines will be excluded from the awarding of contracts. This also includes the applicable regulations on compliance with working hours.
• We attach particular importance to the fact that our suppliers also have sustainability requirements and to their own suppliers.
• We require our suppliers to maintain water and air quality, strive for energy efficiency, use renewable energy, and avoid harmful greenhouse emissions.
• Our suppliers are required to use chemicals in a manner that complies with current safety and environmental laws.
• We do not maintain business relationships with suppliers who are publicly known to violate the principles outlined here. In the event of suspected violations, we expect supply chain disclosure.
• We also expect our suppliers to comply with all applicable legal requirements relating to conflict minerals. If the use of conflicting minerals (tin, tantalum, tungsten, gold) cannot be avoided, DS AUTOMOTION expects suppliers to ensure transparency in your supply chain upon request

As an owner-managed company, we traditionally feel a close bond with our employees. We offer long-term employment relationships with interesting areas of responsibility and promote personal careers in the individual companies with the help of personnel development programs. For example, in the sense of a "leadership pipeline" we are able to recruit managers and specialists from within our own ranks, thus ensuring the retention or transfer of knowledge within the Group.

Our managers therefore bear a special responsibility not only to our company but also to our employees. They act both as role models for responsible behavior and as contact persons for their team members in the event of any conflicts that may arise.

DS AUTOMOTION complies with local laws regulating working hours at all locations. We offer our employees competitive and performance-based compensation, and the protection and promotion of our employees' health is a top priority.

We are committed to recruiting people from our host countries as employees. It is a matter of course for us that, wherever possible, the same standards of employee protection, occupational medicine and safety technology apply to these employees as to our employees working in Austria.

In addition, we provide assistance to partner companies in implementing the high standards in the aforementioned areas that are a matter of course for us.

Our guiding principles regarding employees are:

• All our employees are treated equally and fairly. We do not accept any discrimination with regard to ethnic origin, gender, sexual orientation, cultural background or age.
• Interaction with each other in our company is characterized by mutual respect, fairness and professionalism. The individual personality of each of our employees is taken into account, with attention being paid to a work-life balance wherever possible. We regard this basis as an essential prerequisite for a permanently high willingness to perform and thus as an important contribution to the success of our company.
• Wherever possible, we support our employees in their professional and personal development and reach ambitious but realistic target agreements with them.

The areas of occupational safety and accident prevention have a particularly high priority for us

Our guiding principles in the area of occupational safety & accident prevention are:

• We continuously train our employees in occupational safety and accident prevention. In the course of lessons learned, we also record and evaluate near misses in order to identify potential hazards in good time and "defuse" them in future projects. All safety guidelines must be strictly followed, with the same safety standards applying to subcontractors as to ourselves.
• The consumption of alcohol and other legal intoxicants and narcotics while on duty is prohibited and violations will be strictly enforced.
• For reasons of health prevention as well as occupational safety, we have decided to declare our premises generally non-smoking, with the exception of designated smoking areas.
• When handling explosive and/or hazardous substances on our premises or on those of our customers, smoking is strictly prohibited. Violations of this rule will be severely punished.

As part of our social responsibility, we are committed to complying with national and international statutory data protection. In addition to compliance with the EU Data Protection Regulation by our employees, this also includes the unconditional obligation to maintain secrecy and confidentiality, a workplace design that complies with data protection requirements, and permanent monitoring and further development of our measures to ensure data protection.

All employees are responsible for ensuring that personal data is protected against unauthorized access by third parties and that the necessary precautions are taken to prevent unauthorized use.

Our guiding principles in the area of data protection are:

• We protect personal data of our current and former employees, suppliers and other data subjects.
• We collect, gather, process, use and store personal data only in accordance with legal requirements.
• We take into account that the collection, storage, processing and other use of personal data only happens with the consent of the data subjects.

We are aware that our international business activities also leave a not inconsiderable ecological footprint. All the natural raw materials we consume, for example, require a certain base area to grow back, and in order to break down the waste we generate, nature has to use its resources.

We therefore want to do our part through conscious sustainability to keep our ecological footprint as small as possible.

Our guiding principles in the area of environment & sustainability are:

• We therefore actively support the preservation of water and air quality, the pursuit of energy efficiency, the use of renewable energy, and the avoidance of harmful greenhouse emissions.
• We monitor chemicals in compliance with safety and environmental laws. Our environmental policy focuses on reducing or substituting hazardous chemicals that have a major impact on the environment.
• We use our resources sparingly and seek to further reduce consumption and minimize emissions as far as possible through permanent optimization in the technical area.
• We optimize our purchasing processes in order to further increase the share of recycled materials in new procurement or to introduce more environmentally friendly auxiliary materials (mordants, lubricants, etc.).
• We have been meticulously separating our waste for a long time and feeding it into the various recycling channels.
• We support a precautionary approach in dealing with environmental problems.
• We take initiatives at home and abroad to create a greater sense of responsibility for the environment.
• We promote the development and dissemination of environmentally friendly technologies and are partly involved in this ourselves with our own developments.

Working conditions and human rights
We are committed to full compliance with human rights and labor standards in our businesses. We also expect this from our internal and external stakeholders. In our role as an employer, we are committed to social responsibility and see ourselves as a responsible part of the respective community at national and international level. We promote social developments by means of initiatives in the social, ecological and cultural areas and also support the voluntary commitment of our employees in this respect.

Our guiding principles in the area of working conditions and human rights are:

• We respect and support the protection of international human rights within the scope of our possibilities.
• We ensure that we are not complicit in human rights abuses.
• We respect freedom of association and the effective recognition of the right to collective bargaining.
• We advocate the elimination of all forms of forced labor.
• We advocate the elimination of child labor.
• We advocate the elimination of discrimination in respect of employment and occupation.

Corruption

We are committed to fair competition and oppose all forms of corruption. Corruption leads to decisions made for improper reasons, prevents progress and innovation, distorts competition and harms society. We point out that corruption is prohibited and that corruption can result in criminal sanctions for employees involved.

We regard sponsoring and support for initiatives in the social and environmental spheres as instruments for fulfilling our social responsibility. Transparency is a matter of course for us.

Our guiding principles in the area of corruption are:

• We are committed to fair, international competition and take a stand against all forms of corruption.
• We convince our customers with our products and services and not through undue influence. Nor do we allow ourselves to be unduly influenced; instead, we make decisions for objective and comprehensible reasons.
• We inform ourselves independently about internal regulations before accepting gifts, invitations or hospitality, or making them ourselves.
• If there are indications of corruption, we report this immediately to one of our contact persons (direct superiors or employee representatives).
• We only grant donations in cash and in kind to institutions that are recognized as non-profit organizations or are authorized to accept donations by special regulations.

Financial responsibility

Our business policy and financial responsibility form the desire to continue to be a financially sound company with sustainable revenue growth and stable profit growth that fully meets the needs of our partners, shareholders and customers regardless of their size or business focus. Accurate, timely, complete financial records and information are the basis for our business policies and financial responsibility, which are necessary for managing our business relationships.

Our guiding principles in the area of financial responsibility are:

• We implement effective internal financial controls and procedures to safeguard assets.
• We generally maintain complete financial records for the purpose of meeting obligations to shareholders, government agencies and the public.
• We organize processes so that all business financial information can be accurately and timely recorded in accounting records.

Conflict of Interest

Conflicts of interest arise when the private interests of one of our employees collide with the interests of DS Automotion GmbH. We respect the personal interests and private lives of our employees. However, we attach importance to avoiding conflicts between private and business interests in order not to harm the company as a result.

Our guiding principles in the area of conflicts of interest are:

• We make our decisions exclusively on the basis of factual criteria and do not allow ourselves to be influenced by personal interests and relationships.
• We undertake to disclose existing or potential conflicts of interest and to seek a solution together.

Intellectual property

Our know-how - our intellectual property - is the basis of our business success. Intellectual property includes, for example, inventions, product developments, developments of new technologies or self-created computer software. Unauthorized disclosure of such knowledge can cause great damage to our company, and it is important to protect this knowledge. We would like to point out that unauthorized disclosure may result in labor, civil and criminal penalties for the employees concerned.

Our intellectual property guidelines are:

• All employees of the company protect the intellectual property extremely carefully by not disseminating or forwarding any information about it to competitors.
• If such confidential information is made available to a business partner following approval by the supervisor then the business partner must sign a non-disclosure agreement.
• We ensure that intellectual property is not misused by third parties and we avoid unauthorized usage of external intellectual property.

Counterfeit parts

Our products have clear labels and are transparent within the delivery chain. We only use parts from suppliers that we acquire by means of a professional selection process in order to minimize the risk of introducing plagiarism and counterfeit materials. In case of noncompliance, we will immediately take legal steps in order to protect the market and our customers.

Export controls and economic sanctions

We are committed to strict compliance with foreign trade regulations and follow economic sanctions or export restrictions. Restrictions are generally in place for military products; however, special restrictions, for example, arms or luxury goods embargoes, apply for specific goods and countries.

We do not maintain any business relationships with people or companies who are on sanction lists independent of the delivery process. The employees of the departments concerned stay up-to-date about current sanction lists at all times. The employees responsible for the business processes are required to arrange the processes so that any kind of economic criminality is prohibited.

Our export control and economic sanction guidelines are:

• Employees strictly comply with the foreign trade regulations as far as they are responsible. In cases of doubt they seek advice from the authority in charge of customs and foreign trade legislation.
• As a global company, we observe national and international economic sanctions and support the international community in the fight against money laundering and the financing of terrorism.
• We arrange business processes so that financial crime is prohibited.

Whistleblowing and protection from retributive justice

It can occur that employees detect or suspect breaches to EU law, the code of conduct or other internal guidelines. In order to promote open and trustful communication, DS Automotion GmbH declares herewith that no negative consequences of any kind will arise due to this for employees who report detected or reasonably suspected breaches.

This applies equally to other people who make important information available to bring such misconduct to light. We assure that all incoming reports are handled confidentially and are inspected very carefully in an objective manner.

An employee's direct supervisor is their first point of contact if they are not sure about what to do in a certain situation. Moreover, employees can also contact the works councils.

It is fundamental protection requirement for the whistleblower to be honest, i.e. that the whistleblower has good reason to believe their information is the truth. It is not tolerated to make false allegations although it is well known that they are incorrect. Moreover, this can have penal consequences. We reserve the right to take action against employees who knowingly make false allegations.

Our whistleblowing and retributive justice protection guidelines are:

• If there are any signs of possible misconduct, employees can approach their point of contact (direct supervisor or works councils) in order to solve problems early on and to prevent bigger disadvantages for those concerned.
• We declare that all incoming reports are handled confidentially and are inspected carefully.
• We assure that no negative consequences will arise for all honest employees who report verifiable or suspected breaches to EU law, the code of conduct or other internal guidelines.
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