Code of Conduct

Preamble

Our aim as a company is to offer our managers and employees not just jobs, but scope for creativity. People who join us don’t look for titles, they drive issues forward and take responsibility. And that’s what it’s all about here. Responsibility is the core corporate value for us and our way of working.

This Code of Conduct is intended to serve as a compass for the decisions that we all make every day in the course of our work for Valtech Mobility GmbH. The principles set out in this Code of Conduct apply at all locations and in all business units of Valtech Mobility GmbH and cover our dealings with all colleagues, customers, suppliers, business partners and public bodies. We expect our business partners to behave accordingly. The Code of Conduct cannot exhaustively cover all the topics listed in it. Any individual topics can be regulated in more detail in the accompanying guidelines and policies of Valtech Mobility GmbH. There is therefore no principle of exclusion, but rather the Code of Conduct and any other policies and guidelines complement each other.

This Code of Conduct aims to prevent legal violations and misconduct and thus prevent damage to the company and our employees. However, if mistakes and violations occur, we must take responsibility and act. On the one hand, this involves clarifying the facts and limiting the damage, and on the other, learning and recognizing any new or previously unrecognized risks and dealing with them proactively. We want to be a learning organization that thinks and acts in an entrepreneurial and at the same time legally compliant manner. Valtech Mobility GmbH therefore reserves the right to adapt the Code of Conduct.

1.This is how we do it – this is Valtech Mobility

1.1 Lawful conduct

The applicable law is both the basis and the framework for Valtech Mobility GmbH’s business activities. This Code of Conduct is therefore concerned with ensuring compliance with and observance of the applicable legal provisions. Valtech Mobility GmbH organizes its business operations in such a way that its executive bodies, managers and employees act in compliance with the law. This is done in the knowledge that violations of the law can lead to massive damage and disadvantages for Valtech Mobility GmbH. This is not only about avoiding fines and claims for damages, but also about any damage to the company’s image. The latter are generally difficult to remedy. Compliance with applicable law is therefore crucial for the long-term success of Valtech Mobility GmbH.

Culpable violations of this Code of Conduct will not be tolerated by Valtech Mobility GmbH. Anyone who violates it must expect appropriate consequences. Depending on the severity of the violation, these may range from measures under labor law to claims for damages under civil law and criminal sanctions.

1.2 Human rights & fair working conditions

The United Nations Universal Declaration of Human Rights and the European Convention for the Protection of Human Rights and Fundamental Freedoms centrally regulate the requirements and expectations of the international community regarding respect for and compliance with human rights. As a company, it goes without saying that we respect human rights. At the same time, we reject child, forced and compulsory labor as well as all forms of modern slavery and human trafficking.

1.3 Equal opportunities & equal treatment

The composition of the workforce at Valtech Mobility GmbH is colorful, diverse and varied. And that is important to us. We do not tolerate discrimination on the basis of ethnic or national origin, gender, religion, ideology, age, disability, sexual orientation, skin color, political views, social background or other legally protected characteristics. Equal opportunities and equal treatment are core values of our company. The selection, recruitment and further development of our employees are always based on their respective qualifications and skills.

Employees who have experienced discrimination or harassment at work can contact Valtech Mobility GmbH’s trusted persons if they do not wish to use Valtech Mobility GmbH’s whistleblower reporting office.

1.4 Occupational health and safety

As a company, the health and safety of our employees is very important to us.  We therefore ensure occupational health and safety in accordance with the applicable legal provisions in order to prevent physical and mental illness in the working environment.

1.5 Use of company resources

In addition to the company budget, work equipment and corresponding equipment for Valtech Mobility GmbH employees, company resources naturally also include intellectual property – i.e. tangible and intangible assets. Careful, responsible handling of these assets within the framework of the applicable regulations and requirements of Valtech Mobility GmbH and its corporate objectives as well as the law is mandatory.

1.6 Benefits & prevention of corruption

We do not tolerate corruption. It can lead to fines for the company and criminal prosecution of employees, not to mention reputational damage for our company. What does that mean in concrete terms? We only make business decisions for objective and comprehensible reasons in the interests of the company. We therefore do not accept any benefits, in particular gifts or invitations, that could influence our business decisions. At the same time, we do not offer any such benefits to our business partners or other contacts and contact persons. This also applies in particular to contact with authorities and public officials, for whom stricter requirements regularly apply than in the non-official sector. Small and customary, i.e. socially appropriate, gifts of a reasonable size remain unobjectionable, especially if they are not related to business decisions. You can find information on the evaluation of gifts and invitations in a separate policy.

1.7 Conflicts of interest, review of business partners

Conflicts of interest can arise in particular from close personal relationships with business partners and other contacts in connection with entrepreneurial activities for our company. To avoid this, we always separate personal interests from company interests and make business decisions exclusively on the basis of objective criteria. Any personal connections in the context of company-relevant decisions must always be disclosed. Products and services are purchased via our purchasing department in accordance with internal procurement principles.

As a matter of principle, we carry out business partner due diligence before entering into business relationships in order to avoid surprises in business relationships. We check the identity of our customers and business partners with the aim of only entering into business relationships with reputable partners. In particular, this also involves compliance with the applicable requirements of foreign trade law and the fight against money laundering.

1.8 Donations & sponsoring

As a company, we are aware of our shared responsibility in society. Therefore, when we make a social commitment in the form of donations, it is always on a voluntary basis and without expectation of anything in return. We do not make donations to political parties or party-affiliated foundations and institutions. The allocation of donations is checked in advance with this in mind and is always transparent, i.e. the purpose, donation recipient and donation receipt of the donation recipient are documented and verifiable. If, on the other hand, we act as a sponsor, this is of an advertising nature with the aim of brand and image cultivation.

1.9 Business secrets, confidentiality & non-disclosure

The protection of business secrets and the confidential handling of confidential information are essential to our success as an innovative company. We therefore handle all information and documents in our company, our know-how, our intellectual property, any sensitive data and other business secrets with care and protect them. All information and documents that are not suitable for disclosure to unauthorized third parties must therefore be treated confidentially and protected against access by unauthorized third parties. Reference is made to the law on the protection of business secrets. Data protection is regulated as a separate point in Section 1.12 of this Code of Conduct.

1.10 Public image & communication

We are aware of our shared responsibility for the reputation of Valtech Mobility GmbH when we act on behalf of our company, especially when we communicate publicly and privately. This applies in particular to the use of social media. You can find our guidelines on the Intranet.

1.11 Antitrust law

The principle of fair and free competition is a central pillar of our market economy and is protected by competition and antitrust laws. In particular, agreements and concerted practices between competitors that have as their object or effect the prevention or restriction of free competition are prohibited. Violations can result in severe fines and penalties, not to mention reputational damage. We therefore consistently comply with the requirements of competition and antitrust law.

1.12 Data protection

Data protection regulates the protection of personal data and thus also in our company and in our company’s relationships with our employees, business partners and other contacts. The processing of personal data always requires a legal basis. We adhere to this principle and use technical measures to protect personal data as comprehensively as possible. The aim is always to protect the rights of data subjects. Here too, violations can result in severe fines and penalties, not to mention reputational damage.

1.13 Cybersecurity

As a tech company, reliable protection against cyber risks is crucial for our customers’ and business partners’ trust in us and therefore for the success of our company. We are constantly working on improving our measures to achieve comprehensive protection against cyber risks and map this in the Mobility Information Security Manual. You can read the current status on the Intranet.

2 And if something has happened?

If errors have occurred or if there are violations of this Code of Conduct or if you have questions about how to deal with its content, you can always contact your direct line manager. The legal department is also available to provide you with advice and assistance. Last but not least, you can report violations or suspected violations – also anonymously – via the whistleblower reporting office. Information on the whistleblower reporting office and relevant violations can be found on the Mobility Manual. In general, it is important to us that the aforementioned offices are not misused to report false or defamatory information. This can have consequences under civil and criminal law.

Policy on handling invitations and gifts in a business context

Dealing with gifts and invitations (= gratuities) in a business context

1.Fundamentals

• Dispatch and delivery of benefits: exclusively via the business address; the same applies accordingly to the acceptance of benefits from business partners,
• not accepting or giving gifts of money or money-like gifts,
• no benefits dependent on the making of operational decisions and also not immediately before or after a business decision (exception: appropriate meal invitations),
• no claims for benefits from business partners or employees of Valtech Mobility GmbH,
• No benefits to third parties who are related to employees of business partners, or demands for benefits to third parties who are related to employees of Valtech Mobility GmbH,
• In principle, no benefits to decision-makers in the area of procurement or purchasing (alternatively: transparency through clarification with the management).

2. Appropriateness of the benefit

Benefits must always be appropriate. The decisive factor is that they are not suitable for improperly influencing business decisions in the individual circumstances of each case. And what is “appropriate”? These are relatively low-value gifts that are considered socially appropriate, i.e. customary and customarily recognized (different standards apply to public officials; see below). And how do you actually assess this? The following questions, which you must answer honestly, can help:

• Do customary practices permit the gift or is it appropriately related to the occasion?
• Would you tell the management or colleagues about the gift or invitation or would you want to avoid it?
• Are the gift or invitation likely to influence the recipient’s business decision to such an extent that the giver or inviter is unfairly favored?
• If you were the recipient – would you feel indebted to the giver/inviter?

3. Procedure and value limits for accepting and giving gifts

Below you will find the value limits for accepting and giving gifts. These are company-specific, i.e. set by Valtech Mobility GmbH. It is therefore possible that business partners may not be allowed to accept gifts due to different company regulations.

• No acceptance or granting of individual gifts with a gross value of more than EUR 50,
• per employee per business relationship: no higher total value of all gifts accepted or granted of more than EUR 300 gross in a calendar year,
• without informal written approval (e-mail ok) from the superior: no acceptance or giving of gifts between EUR 50 gross (individual) and EUR 300 gross (cumulative),
• without informal written approval (e-mail ok) from the management: no single or multiple gifts cumulated within one calendar year in excess of EUR 300 gross per person and business relationship,
• if the value of a gift is unknown or unclear, it must be estimated in gross terms according to market value.

4. Procedure and value limits for the acceptance and awarding of meal invitations

• no acceptance of meal invitations with a gross value of more than EUR 50 per person,
• Total value of all meal invitations accepted or granted by an employee per calendar year per business relationship: not > EUR 300 gross,
• Without informal written approval (e-mail ok) from the line manager: no acceptance or issuing of meal invitations worth > EUR 100 gross per person.

5. Procedure and value limits for accepting and issuing invitations to events

The acceptance and awarding of invitations to events must always be considered and classified holistically. The invitation may only be accepted or issued to business partners if the criteria for the event are predominantly positive in accordance with the following aspects. In case of doubt, the supervisor or management must be consulted.

Positive expression:

• Objective: no unfair competitive advantage or breach of duty towards the company,
• Position of the recipient: high-ranking business partner from the business world,
• Relationship of the parties involved: no operational business contacts,
• Procedure: Transparency of the benefit (e.g. through approval by the line manager),
• Value: appropriate,
• Number: occasionally, 1-2x in a period of 12 months,
• Timing: independent of specific business decision,
• Presence of the inviting party or a representative: present, guest support therefore available,
• Duration: < 24h,
• Circle of invitees: open

Negative expression:

• Objective: unfair advantage in competition or breach of duty towards the company,
• Position of the recipient: Public official,
• Relationship of the parties involved: (close) operational business points of contact,
• Procedure: no transparency of the benefit (e.g. through approval by the superior),
• Value: high value or inappropriate,
• Number: frequently, e.g. weekly or monthly,
• Timing: proximity to a business decision, e.g. directly before or after,
• Presence of the inviting party or a representative: present, guest support therefore available,
• Duration: > 24h incl. overnight stay/s etc.,
• Circle of invitees: exclusive invitation, invitation of related parties

Special case: Benefits to public officials

Public officials are not only civil servants in public authorities, but also members of the federal and state governments as well as managers and employees of companies in which public authorities hold majority shareholdings. In cases of doubt, the Legal Department will be happy to answer any questions. The decisive factor is in which function and in the context of which activity (e.g. mandate activity or specific administrative tasks assigned) an allowance is made.

Due to the restrictive criminal law regulations, benefits may not be granted to German, European and foreign public officials. Exceptions may be made in the following cases:

• small gifts (e.g. advertising / promotional items) with a gross value of up to EUR 10 or customarily recognized benefits (e.g. invitation to a cup of coffee, cab ride from the airport to a meeting),
• customary and appropriate events in which the office holder participates as a representative of his office or as part of his social obligations,
• Approval (= in advance) or immediate approval (= retrospective) by the competent authority to accept the approvable grant.

To clarify: All gratuities that are aimed at the performance of official duties by the public official in breach of duty are prohibited. This is the case if the public official violates their official duty, i.e. the official act itself violates a law, an official regulation or a specific individual instruction from their superior.

Tax aspects

Gifts to employees are generally subject to taxation as income for the recipient. This does not include so-called promotional items (e.g. pens) up to a value of EUR 10. Please therefore note that certain tax aspects must be taken into account when accepting and giving gifts and invitations (including lump-sum taxation in accordance with Section 37 b EStG). In this respect, please refer to the Finance department.

Code of Work Ethic

1.Preamble

Valtech Mobility GmbH regards responsible, sustainable and lawful conduct as an essential part of its corporate strategy. In this sense, this Code of Work Ethic reflects the views of Valtech Mobility GmbH on working conditions and human rights. The principles set out in this Code of Work Ethic apply at all locations and in all business areas of Valtech Mobility GmbH and cover dealings with all colleagues, customers, suppliers, business partners and public bodies. We expect our business partners to behave accordingly. The Code of Work Ethic supplements the Code of Conduct of Valtech Mobility GmbH as well as all other guidelines and policies of Valtech Mobility GmbH. Any individual topics can be regulated in more detail in accompanying guidelines and policies of Valtech Mobility GmbH. The Code of Work Ethics and any other policies and guidelines complement each other. Valtech Mobility GmbH reserves the right to adapt the Code of Work Ethics.

2 Work Ethic at Valtech Mobility GmbH

2.1 Lawful conduct

The applicable law is the basis and at the same time the framework for the business activities of Valtech Mobility GmbH. This Code of Work Ethic is therefore concerned with ensuring compliance with and observance of the applicable legal provisions. Valtech Mobility GmbH organizes its business operations in such a way that its executive bodies, managers and employees act in compliance with the law. This is done in the knowledge that violations of the law can lead to massive damage and disadvantages for Valtech Mobility GmbH. This is not only about avoiding fines and claims for damages, but also about any damage to the company’s image. The latter are generally difficult to remedy. Compliance with applicable law is therefore crucial for the long-term success of Valtech Mobility GmbH.

Culpable violations of this Code of Conduct will not be tolerated by Valtech Mobility GmbH. Anyone who violates it must expect appropriate consequences. Depending on the severity of the violation, these may range from measures under labor law to claims for damages under civil law and criminal sanctions.

2.2 Human rights and fair working conditions

The United Nations Universal Declaration of Human Rights and the European Convention for the Protection of Human Rights and Fundamental Freedoms centrally regulate the requirements and expectations of the international community regarding respect for and compliance with human rights. As a company, it goes without saying that we respect human rights. At the same time, we reject child, forced and compulsory labor as well as all forms of modern slavery and human trafficking.

2.3 Remuneration and benefits, working hours

The remuneration paid or services rendered by Valtech Mobility GmbH correspond at least to the legally valid and guaranteed national minimum, but regularly exceed it. Valtech Mobility GmbH recognizes the principle of equal pay for work of equal value, in particular between different genders. At the same time, Valtech Mobility GmbH recognizes the principle that working hours must at least comply with the respective national legal requirements.

2.4 Equal opportunities and equal treatment

The composition of the workforce at Valtech Mobility GmbH is colorful, diverse and varied. And that is important to us. We do not tolerate discrimination on the basis of ethnic or national origin, gender, religion, ideology, age, disability, sexual orientation, skin color, political views, social background or other legally protected characteristics. Equal opportunities and equal treatment are core values of our company. The selection, recruitment and further development of our employees are always based on their respective qualifications and skills.

Employees who have experienced discrimination or harassment at work can confidentially contact Valtech Mobility GmbH’s trusted persons in this regard if they do not wish to use the whistleblower reporting office.

2.5 Occupational safety, health, fire and environmental protection

As a company, we are aware of the importance of occupational safety, health, fire and environmental protection and – as a result – healthy working conditions. With this in mind, we guarantee occupational safety, health and fire protection in the workplace free of charge for employees, at least within the framework of the respective nationally applicable laws. In this respect, we take appropriate measures within this framework and comply with them. We try to systematically identify risks in the company and in our employees’ day-to-day work and take appropriate protective and preventive measures. This is done using a risk matrix and in risk assessments. The latter serve to prevent incidents and accidents. It is important to us that workstations are equipped with ergonomic aspects in mind (workplace ergonomics). If machines or technical equipment are used at Valtech Mobility GmbH, the aspect of machine safety is ensured appropriately. As Valtech Mobility GmbH does not handle heavy equipment or chemical and biological substances, it is not necessary to provide protective equipment. The identified risks and the corresponding protective and preventive measures are regularly reviewed. First aiders, fire safety assistants and occupational safety specialists are established. The same applies to operational environmental protection measures. In this regard, we refer to our corporate mission statement on environmental protection.

2.6 Freedom of association & right to collective bargaining

Valtech Mobility GmbH recognizes the right of all employees to form employee representative bodies within the framework of the applicable laws and to conduct collective bargaining to regulate working conditions. Employees are neither favored nor disadvantaged because of their membership or non-membership in a trade union or employee representative body. At the same time, and regardless of the above, it is important to us to foster a culture of trusting and constructive cooperation within the company. Regular dialog between employees and management is therefore encouraged and promoted.

Preamble

Valtech Mobility GmbH attaches great importance to its business partners actively contributing to the company’s success. Cooperation based on partnership is of central importance in order to create long-term business relationships that bring mutual benefits. Valtech Mobility GmbH therefore emphasizes the importance of close cooperation with its business partners.

In line with the principle of sustainability, Valtech Mobility GmbH is aware of its responsibility to consider the economic, ecological and social impact of its actions. The company expects the same from its business partners.

The following requirements specify Valtech Mobility GmbH’s expectations regarding the attitude and behavior of its business partners in business operations. These requirements form the basis for successful and responsible business relationships.

1. objectives and scope of application

In this “Code of Conduct for Business Partners” (hereinafter referred to as the “Code of Conduct”), Valtech Mobility GmbH has formulated its demands, expectations and requirements for business partners with regard to sustainability (hereinafter referred to as the “Sustainability Requirements”).

Sustainability includes aspects such as respect for human rights and environmental protection, ethical and legally impeccable business conduct and the responsible procurement of raw materials.

The Code of Conduct is binding for all suppliers, sales partners and other B2B business partners (hereinafter referred to as “business partners”) of Valtech Mobility GmbH who maintain a business relationship with the company.

The business partners undertake to contractually pass on the sustainability requirements to those business partners (in particular suppliers) who are associated with the contractual relationship with Valtech Mobility GmbH. They are required to introduce appropriate control measures to verify that the sustainability requirements are passed on in the supply chain.

If individual contractual agreements with business partners deviate from these principles, these take precedence.

The sustainability requirements are based, among other things, on the Ten Principles of the United Nations (UN) Global Compact, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and the conventions of the International Labor Organization (ILO). In particular, the fundamental rights at work and the guiding principles of the Drive Sustainability initiative are taken into account.

In addition, this Code of Conduct is based on nationally and internationally recognized standards such as the Universal Declaration of Human Rights, which are set out in particular in the International Covenant on Civil and Political Rights (ICCPR) and the International Covenant on Economic, Social and Cultural Rights.

2. basic sustainability requirements

General

Valtech Mobility GmbH considers compliance with the sustainability requirements to be indispensable for any business relationship.

Business partners are expected to integrate the values of these sustainability requirements into their day-to-day business through structured and knowledgeable management. Business partners’ management should identify and evaluate legal and other requirements and train employees accordingly to ensure compliance.

Business partners are obliged to comply with applicable law at all times. If the sustainability requirements exceed the requirements of the applicable law, these must also be taken into account.

Creation and application of management systems

The legal obligations of our customers with regard to sustainability and supply chain management require the introduction of management systems along the entire supply chain. In order to be prepared for future requirements and audits, we also recommend that our business partners introduce such a management system.

Business partners with production sites employing more than 100 people should strive for certification in accordance with the international ISO 14001 standard or the European Union’s EMAS Regulation for these sites.

For business partners with production sites employing more than 1,000 people, we also recommend certification in accordance with the international standard ISO 45001 or a comparable standard for these sites.

Company declaration

Business partners commit to social, ethical and ecological standards in a company declaration (e.g. a code of conduct). This declaration should be written in languages that are understood by local employees.

Sustainability officer

Business partners should appoint a sustainability officer or a comparable officer who reports to the management on sustainability goals and measures in the company.

Training

Business partners are encouraged to develop their own training programs to improve the establishment of policies, implementation of processes and communication of expectations to their employees. Employees are expected to receive continuous training.

3. sustainability requirements in environmental protection

Valtech Mobility GmbH attaches great importance to ensuring that its business partners are aware of and comply with its environmental policy.

Greenhouse gas emissions

Business partners are required to take measures to reduce air emissions, including greenhouse gases, which pose a risk to the environment and health. This includes proactively reducing greenhouse gas emissions throughout the supply chain by increasing the use of carbon-neutral energy sources.

When delivering products or providing services to Valtech Mobility GmbH, business partners should provide information on total energy consumption in MWh and CO2 emissions in tons (Scope 1, 2 and 3) at product level upon request in order to improve environmental performance indicators.

In addition, we encourage our business partners to set science-based and time-bound emission reduction targets and the use of renewable energy that are in line with the Paris Agreement and promote decarbonization throughout the value chain.

A commitment to CO2 neutrality by 2050 is also recommended.

Resource efficiency

Business partners should take measures to ensure efficient use of energy, water and raw materials, use renewable resources and minimize damage to the environment and health.

Registration, evaluation and restriction of substances and raw materials

Business partners must implement suitable measures to avoid the use of substances and materials with adverse effects on the environment or health, such as carcinogenic, mutagenic or reprotoxic substances. International conventions and other legal instruments relating to the production, use, handling and disposal of certain substances, in particular the Minamata Convention on Mercury and the Stockholm Convention on Persistent Organic Pollutants (POPs), must be taken into account.

Raw materials from deep sea mining should be excluded from the supply chain wherever possible.

Circular economy and waste management

Business partners should take appropriate measures to avoid waste, reuse resources, recycle and dispose of residual waste, chemicals and waste water in a safe and environmentally friendly manner. These measures should be implemented primarily during development, production, product life and end-of-life recycling, as well as in other activities. International conventions on the transboundary movement of hazardous waste, such as the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, must be observed.

The use of secondary materials is recommended where this is technically possible and economically viable.

Business partners should promote closed-loop systems.

Water

Business partners are encouraged to take measures to minimize water consumption at their sites and along their supply chains, especially in water-scarce regions. The right to water should be respected at all times.

Business partners who supply products to Valtech Mobility GmbH are required to provide information on total fresh water consumption at product level on request.

People affected by the business partner’s operations should have access to safe, acceptable and affordable water in sufficient quantities for personal use at all times.

Biodiversity

Business partners must protect natural ecosystems, especially endangered wildlife habitats, and ensure sustainable use of natural resources.

They should strive for supply chains that avoid deforestation and degradation and comply with international regulations on biodiversity, such as the resolutions and recommendations of the Center for Biological Diversity (CBD) and the International Union for Conservation of Nature (IUCN).

The ethically sound and species-appropriate treatment of animals is also supported and promoted by the business partners.

4. sustainability requirements in the area of human rights and the labor rights of employees

The business partners undertake to respect the conventions of the International Labor Organization (ILO) in their current version, in particular with regard to fundamental rights at work.

Abolition of child labor and protection of young workers

Business partners must comply with the minimum age for employees in their activities and supply chains. They shall ensure that the minimum age is set in accordance with applicable law and ILO standards to prevent child labor.

No modern slavery, no human trafficking, no unethical recruitment

Business partners shall take appropriate measures to prevent debt bondage, forced labor, modern slavery and human trafficking in their business and supply chain. They ensure that employment relationships are entered into voluntarily and with appropriate notice periods. Employment contracts are written in understandable language and truthfully.

Protection of physical integrity, no corporal punishment

The business partners are strongly committed to the protection of physical integrity and prevent any involvement in acts of violence such as kidnapping, torture or killing. Corporal punishment as a disciplinary measure is prohibited.

Remuneration and benefits

The business partners undertake to pay their employees an appropriate wage. This appropriate wage should at least correspond to the statutory minimum wage and also guarantee the standard of living of the employees and their families (living wage). Payment must be direct, complete and punctual.

Health and safety in the workplace, fire protection

Business partners are obliged to comply with all applicable labor, health and fire safety laws. To this end, they must introduce a process that enables the continuous reduction of health and safety-related risks in the workplace and improves occupational health and safety and fire protection. The costs of occupational health and safety measures must not be imposed on employees.

In particular, business partners are required to implement the following measures:

1. Employees must be informed about identified hazards and preventive and corrective measures to minimize risks in a language they can understand.
2. Appropriate training measures must be implemented to prevent work-related health problems, avoid accidents at work, implement first aid measures, master chemical management and ensure fire protection.
3. The necessary protective equipment and protective clothing must be made available to employees free of charge.
4. Appropriate fire protection measures (technical, structural and/or organizational) must be taken to minimize damage in the event of fire.
5. Monitoring and control of work-related health and safety hazards (such as chemical, biological, physical and physiological hazards) and appropriate protective measures are required.
6. All chemicals used must be labelled in accordance with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) or, in European countries, the Classification, Labelling and Packaging (CLP) Regulation. The storage, transportation and handling of chemicals must comply with legal and contractual requirements.
7. Appropriate emergency plans must be drawn up and first aid, fire protection and medical supplies as well as appropriate materials and transportation for further treatment must be provided.
8. Sufficient emergency exits, escape routes and assembly points must be provided and clearly marked throughout.

In the event of an accident, first aid measures and medical care must be guaranteed. In the event of health hazards such as pandemics, business partners must take all necessary protective measures for their employees and society. All measures issued by the local authorities must be fully observed and complied with.

Working hours

Business partners shall ensure that working hours comply with applicable national regulations and standard industry requirements.

Working and living conditions

Business partners shall provide their employees with appropriate facilities such as toilets, access to drinking water and hygienic catering facilities. If sleeping accommodation is necessary, appropriate conditions are ensured.

Environmental protection

Business partners shall take care not to cause harmful effects on the environment, including land degradation, water pollution, air pollution or excessive water consumption.

Human rights activists

Business partners respect the right to freedom of expression and freedom of association and do not tolerate threats, intimidation or violence against human rights or environmental activists.

Freedom of association and collective bargaining

Business partners recognize the right of employees to form and join trade unions and employee representative bodies. Discrimination or retaliation against trade union activities is prohibited.

No discrimination and no harassment

Business partners shall refrain from any form of discrimination, intimidation or harassment in the workplace, including discrimination based on race, gender, religion, health and other personal characteristics.

Use of security forces

Business partners shall ensure that the engagement of security forces does not cause human rights violations and does not lead to unlawful control of extraction sites or supply chains.

Minorities, vulnerable groups and indigenous peoples

Business partners respect the living conditions of minorities, vulnerable people and local communities.

Diversity and inclusion

Business partners promote an inclusive culture that values diversity and ensure that all employees can reach their full potential. Collaboration with diverse business partners is also encouraged.

The above principles shall be adhered to and respected by business partners to ensure ethical and socially responsible business practices.

5. sustainability requirements for corporate ethics

Business partners act with integrity at all times and take appropriate measures to remedy any violations identified.

Avoidance of conflicts of interest

Business partners make their decisions exclusively on the basis of objective criteria and do not allow themselves to be influenced by irrelevant interests or relationships.

Prohibition of corruption

The business partners reject any form of corruption, including facilitation payments for routine official acts. They ensure that their employees, subcontractors or representatives do not give, offer or receive bribes, kickbacks, improper donations or other improper payments to public officials or third parties.

Safeguarding free competition

The business partners respect fair and free competition as well as the applicable competition and antitrust regulations. No anti-competitive agreements or arrangements are made with competitors, suppliers, customers or other third parties, and they do not abuse any possible dominant market position.

Compliance with import and export controls

The business partners pay strict attention to compliance with the applicable laws for the import and export of goods, services and information. The relevant sanctions lists are also observed.

In addition, they ensure that all taxes, duties and license fees levied in connection with the extraction, trade and export of minerals in conflict and high-risk areas are paid in accordance with the applicable law.

Prohibition of money laundering

Business partners shall ensure that all applicable legal provisions for the prevention of money laundering are complied with in their business operations.

Protection of intellectual property

Business partners shall respect intellectual property rights and ensure that data is protected accordingly.

Safeguarding confidential information

Business partners shall ensure that sensitive data such as business secrets and personal information is collected, processed, secured and deleted appropriately and in accordance with the law. Your employees are obligated accordingly. Data worthy of protection may not be passed on to third parties without authorization or published in any other way and must be protected accordingly.

Use of artificial intelligence

Data protection and data security are fundamental prerequisites for the use of artificial intelligence (AI). The business partners ensure that all AI-based developments comply with the applicable laws and regulations. AI systems must be designed to be reliable and non-discriminatory, with AI applications being controlled by humans.

Support for armed groups excluded

Business partners shall ensure that their business activities do not contribute to the direct or indirect support of non-state armed groups.

Disclosure and information

Business partners shall collect information about their business activities, working practices, health, safety and environmental protection measures. This information will be made available by Valtech Mobility GmbH upon request, provided that the disclosure is in accordance with legal requirements.

6. sustainability requirements for responsible supply chains

Transparency

Transparency is an essential part of Valtech Mobility GmbH’s efforts to identify and minimize sustainability risks in its supply chain. Therefore, the company’s business partners will, upon request, disclose information about their supply chains that is necessary to fulfill Valtech Mobility’s legal obligations. This disclosure requirement will also be passed on to the business partners’ suppliers.

As part of these transparency requirements, it may be necessary for business partners to disclose detailed information about their supply chain down to the origin of the material, including interfaces such as smelters and refineries, to Valtech Mobility GmbH. They must also provide evidence of management systems or third-party verifications in order to exclude or reduce sustainability risks in the supply chain.

Raw material supply chains

Particular attention is paid to raw material supply chains, as they have a significant impact on people and the planet. All players along the raw material supply chain are therefore obliged to pay particular attention to respecting human rights and protecting the environment.

With regard to relevant raw materials, business partners must in particular exercise due diligence in accordance with the

“OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”.

7. verification of compliance with the sustainability requirements by Valtech Mobility GmbH

Basic principles

Valtech Mobility GmbH reserves the right to check compliance with the sustainability requirements regularly, randomly or on an ad hoc basis before awarding a new contract and during the entire business relationship.

This review may be carried out by means of a risk assessment of the relevant business area of the business partner, the business partner’s self-disclosure and/or by experts on site (on-site review). The on-site review shall only take place during regular business hours in the presence of representatives of the business partner and in compliance with applicable law, in particular with regard to data protection. The business partners shall take appropriate measures to grant Valtech Mobility GmbH the right to carry out corresponding audits at their own business partners, if this is required by law.

Pre-contractual review

If sustainability risks are identified during pre-contractual checks, the resulting measures are binding for the subsequently concluded contract. In this case, the business partner undertakes to examine any identified or imminent violation of sustainability requirements in its business area or supply chain within a reasonable period of time and to remedy it at no additional cost to Valtech Mobility GmbH. The result of the pre-contractual checks regarding the sustainability requirements is a relevant criterion for the award of the contract.

Violation of the sustainability requirements by a business partner

If a violation of the sustainability requirements by a business partner has occurred or is imminent, Valtech Mobility GmbH is entitled to immediately take appropriate measures to prevent, terminate or minimize the violation. In such a case, the business partner is obliged to take all reasonable steps to prevent, terminate or minimize the violation. If the breach cannot be remedied in the foreseeable future, the Business Partner shall promptly develop and implement a plan to terminate or minimize the breach (including a specific timetable). If required by law, Valtech Mobility GmbH shall be appropriately involved in the preparation of the concept.

Violation of sustainability requirements in the business partner’s supply chain

If there are concrete indications that suggest a possible violation of human rights or environmental obligations in the upstream supply chain (in the case of indirect suppliers of Valtech Mobility GmbH) (substantiated knowledge), the business partner must immediately

1. participate in a risk analysis by Valtech Mobility GmbH,
2. define appropriate preventive measures vis-à-vis the business partner concerned, and
3. adequately support Valtech Mobility GmbH in the creation and implementation of a concept for prevention, termination or minimization.

Other consequences

If a business partner violates or fails to comply with the sustainability requirements, Valtech Mobility GmbH reserves the right to take appropriate measures to protect its rights.

This may include the request to implement improvement measures, the review of reported improvements/measures, the exclusion from new orders and even the termination of the contract. However, Valtech Mobility GmbH may waive its right of termination if the business partner credibly assures and proves that it has taken immediate countermeasures to avoid similar violations in the future.

8. reporting of misconduct

Reporting misconduct and protection mechanisms

In order to ensure the well-being of employees, business partners, third parties and Valtech Mobility GmbH, it is crucial to recognize misconduct at an early stage, investigate it and remedy it immediately. This requires the attention of everyone involved and a willingness to report any concrete signs of serious breaches of the rules.

Complaints procedure for business partners

Each business partner shall set up a suitable complaints procedure for their company. This system enables employees and other potentially affected persons to raise concerns about business ethics, human rights or environmental aspects anonymously and confidentially without fear of reprisals.

Business partners undertake not to take any measures that hinder, impede or block access to the complaints procedure.They are also required to contractually pass on the obligations set out in the above sentence to their suppliers and to ensure that these obligations are passed on along the entire supply chain.

Valtech Mobility’s whistleblower system

Valtech Mobility GmbH attaches great importance to relevant information from business partners, customers and other external parties. If there are concrete indications of possible misconduct on the part of employees of Valtech Mobility GmbH, business partners or business partners of business partners during the cooperation with Valtech Mobility GmbH, the company offers all parties involved the opportunity to report this information via the Valtech Mobility GmbH whistleblower system.

Contact details for the whistleblower reporting office can be found in the imprint of the website.

Business partners are obliged to grant their employees unrestricted access to the Valtech Mobility GmbH whistleblower system and not to take any measures that hinder, impede or block this access.In addition, they undertake to contractually pass on the obligations set out in the above sentence to their suppliers and to ensure that these obligations are complied with throughout the supply chain.

9. final provision

Insofar as deviating contractual agreements have been made with the business partners in individual cases, these shall take precedence over the principles set out here.