Compliance declaration

Contents

• Scope of application
• Principles of behaviour
• Avoidance of conflicts of interest
• Dealing with knowledge and information
• Implementation of the compliance declaration
• Contact persons in the GARREIS Group

Scope of application

This compliance declaration applies to all employees of the GARREIS Group.

This declaration describes principles of behaviour for all employees. It is to be regarded as a guideline and is intended to help employees make decisions in accordance with the applicable laws, rules and values at GARREIS in their day-to-day work. This serves to protect the company and thus its employees.

The regulations in this compliance declaration are binding. If certain country-specific circumstances or different business models of the GARREIS companies require further regulations, these will be supplemented after examination and approval by the management.

Furthermore, these principles of behaviour also apply when dealing with customers, suppliers, business partners and interested parties.

We expect them to feel bound by these rules as well. Compliance with the law, honesty, reliability, respect and trust are the universal foundations of good co-operation.

Principles of behaviour

We pay attention to the reputation of our companies in everything we do.

The perception of the GARREIS Group is essentially conveyed by the behaviour of its employees. Incorrect behaviour can lead to damage, disruption and even penalties that can affect individual employees and the company.

In our work, we take care to protect and promote the reputation of GARREIS. Trustworthiness and reliability are cornerstones of our corporate culture.

We win our orders because we inspire our customers with solutions and service. We negotiate with our suppliers in a spirit of partnership and are consistent and fair in our dealings. Concluded contracts and agreements are honoured.

We comply with applicable laws and internal regulations everywhere.

As a company, we are part of the global society in which we operate. We are subject to its rules and laws. As employees of the GARREIS Group, we see it as our duty to comply with the applicable laws and regulations in every country and in every situation. The same applies to internal instructions and guidelines.

Lawful behaviour requires knowledge of the relevant national and international laws and regulations. It is the responsibility of employees to inform themselves independently about the laws and regulations necessary for their work.

Irrespective of this, it is the responsibility of managers to inform their employees about relevant laws and regulations and to ensure compliance with them.

Compliance with laws, rules and guidelines is a priority at all times.

We work together responsibly and with mutual respect.

The corporate culture at GARREIS is characterised by mutual respect and respectful interaction. This applies to our cooperation with customers, suppliers and business partners as well as to our cooperation with each other.

Through regular information, we want to inspire our employees for our corporate goals, motivate them and strengthen their sense of belonging to the company, our vision, strategy and goals.

At GARREIS, we cultivate a co-operative management style. We entrust our employees with responsibility and information for their work. Our managers make decisions transparent and understandable by providing additional information.

We grant personal responsibility and freedom of action as often and as far as possible.

We uphold human rights and respect human dignity.

We respect and protect the dignity of each individual, their privacy and personal rights. We see every person with their experiences and cultural differences
as an enrichment for our company.

We do not allow discrimination on the basis of ethnic origin, religion, age, disability, sexual identity or gender. Furthermore, we do not tolerate violence, intimidation, bullying or sexual harassment in the workplace.

Decisions are made exclusively on the basis of objective considerations. We adhere to the "Universal Declaration of Human Rights". We reject all forms of forced and child labour.

We treat the property of companies and interested parties responsibly.

The facilities, work equipment, business documents and data made available to us for the fulfilment of our tasks are the property of the GARREIS Group or its customers, suppliers and business partners. We handle these responsibly and carefully and only use them for their intended purpose.

Neither negligent nor intentional acts against the company's own or third-party property will be tolerated.

We provide workplaces that meet legal requirements and current standards.

The health of our employees is very important to us. Protecting them and avoiding hazards is our top priority. We want to offer our employees a modern, safe working environment. We therefore ensure that regulations, laws and standards on occupational health and safety are complied with.

We see it as our duty to comply with existing legal and internal regulations on working hours, breaks and rest periods.

We protect the environment by acting responsibly.

Our planet's resources are limited. We therefore endeavour to use them in an ecologically sound manner. This not only means that we comply with existing laws on environmental protection and sustainability, but also that we avoid wasting resources where this appears economically feasible and possible.

Every employee is encouraged to implement sensible measures to conserve resources and protect the environment.

We strictly reject corruption and bribery.

Corruption and bribery harm free competition and prevent innovation.

Both society and companies lose prosperity and reputation as a result. GARREIS does not tolerate corruption or bribery in any form. Neither offering and granting nor demanding and accepting inappropriate advantages is permitted.

We reject bribes to obtain orders or to speed up administrative processes and observe the guidelines of our customers, suppliers and business partners regarding the acceptance and granting of benefits.

These principles apply not only to all employees, but also to other persons and organisations acting on behalf of or in the interests of the GARREIS Group.

We are committed to free and performance-oriented competition.

The GARREIS Group is committed to a free and social market economy. This means that we do not participate in cartels or other unfair or anti-competitive practices.

We enter into agreements with market participants within the legally permitted framework.

We also do not participate in the exchange of competition-relevant or internal, sensitive information and do not spread rumors.

We call on our employees to act with caution, care and responsibility at all times when dealing with competitors.

If a competitor attempts to induce an employee of the GARREIS Group to enter into unauthorized agreements, the employee must refuse to do so and immediately inform his or her manager or a competent authority.

We do not participate in money laundering and terrorist financing.

We strictly reject the concealment of the origin of funds from illegal sources such as terrorism, drug trafficking, bribery, etc. We only want business relationships with reputable partners who obtain their funds from legal sources and do not participate in the financing of illegal activities.

We comply with applicable laws against money laundering and terrorist financing. We comply with legal requirements and cooperate with the relevant state authorities. Our employees are required to report suspected cases.

We comply with all applicable export control and customs laws.

When trading our goods and services internationally, we observe export bans, sanctions and embargoes. The export processes are followed by our employees. If we have any questions or uncertainties, we contact the relevant authorities.

Information and technologies are also affected by the restrictions. These may not be passed on without authorization. Violations can lead to damage for the GARREIS Group.

All employees are called upon to act prudently and not to pass on information without authorization. In cases of doubt, our employees can and should contact their manager or the relevant departments within the company.

Avoidance of conflicts of interest

We do not compete with GARREIS companies.

An employee of the GARREIS Group may not work for a company that is in competition with GARREIS companies and/or acquire or participate in such a company.

In particular, we avoid conflicts between private and business interests. Regular secondary employment of employees must not conflict with the interests of GARREIS and is only permitted with the prior consent of the management.

We welcome employees' voluntary work in the community and support this as far as possible.

Handling knowledge and information

We do not exploit our internal knowledge for our own benefit or that of third parties.

We often have knowledge of GARREIS companies or their customers, suppliers and business partners that is not known to outsiders and is therefore not publicly accessible. Such insider information can be of value as it may influence developments and decisions on the market.

It is therefore forbidden to pass on this knowledge to others inside and outside the company with or without benefit, or to use insider information to buy or sell securities etc. or to recommend their purchase or sale to third parties.

We handle data responsibly.

Confidential information of the company and its customers, suppliers and business partners must always be kept secret. It must not be passed on to unauthorized persons and must be protected against access.

Such confidential information includes, for example, business and internal reports, presentations, communications, product and market information as well as instructions or business and trade secrets.

Only the responsible and authorized body of the GARREIS Group communicates to and with external bodies (e.g. management, executives, HR department or contracted consultants such as legal, tax and management consultants).

The obligation to maintain the confidentiality of information also applies beyond the duration of employment and contractual relationships.

We all adhere to data protection and data security.

We handle personal and business data with care and ensure that privacy and personal rights are protected in our business processes, taking into account the applicable data protection laws.

The creation of records, files etc. for which confidential company information is used is only permitted if this is in the interests of GARREIS and the rights of third parties are taken into account.

The protection of our data and the prevention of data misuse is a priority.

When it comes to technical protection against unauthorized access, the standards corresponding to the state of the art must be observed.n verbleibt und diese ihr digitales Leben selbst bestimmen und gestalten kann.

We make our contribution to responsible digitalization.

Shaping the digital transformation of our society and economy in a sustainable way is our aspiration and guides our actions - in the interests of our customers, partners and employees.

We use digital technologies to drive the development of our companies without unconditionally implementing everything that is technically possible. This is our contribution to the responsible use of digitalization and the use of artificial intelligence (AI).

We are committed to ensuring that everyone has access to technological achievements as they arise. In doing so, we strive to ensure that the sovereignty over personal data remains with the respective person and that they can determine and shape their digital life themselves.

Implementation of the compliance declaration

GARREIS Group employees make decisions.

In specific situations in our day-to-day work, we often have to make decisions that are not clearly described in the Compliance Statement, other GARREIS guidelines or applicable laws.

We make conscientious decisions. In doing so, we are guided by our common sense and our sense of values, decency and integrity.

If we are unsure about a decision, we do not proceed with actions but consult with our managers or the management.

Management and executives act as role models.

Management and executives lead through exemplary behavior, friendly assistance and constructive suggestions and not through rigid instructions. They are available to their employees in the event of ambiguities and for questions and help them to fulfill their tasks and duties.

Instructions are made transparent and understandable by providing additional information.

The behavior of managers and the close contact with their departments support the motivation of employees.

Every manager must emphasize the importance of ethical conduct and compliance with laws and guidelines, address them and promote them through their management style and regular training.

Management and executives are also available as trusted contacts to whom employees can turn if they have professional or personal concerns.

However, the responsibility of managers does not release employees from their own responsibility.

Contact persons in the GARREIS Group

We call on all employees not to tolerate misconduct.

If there is reasonable suspicion that someone is violating our compliance declaration, applicable law or binding rules, we will report this and act accordingly.

We can only react appropriately if we deal openly with possible violations. This helps us to prevent damage to GARREIS, our employees and our customers, suppliers and business partners.

The doors of the management and divisional management are open to everyone.

The first point of contact is the divisional manager. Employees can also approach the management directly at any time. The relevant HR department is also a suitable point of contact for personnel issues. Reports are treated in strict confidence. The whistleblower will not suffer any disadvantage.

As management, we do not tolerate any violations of the compliance declaration.

Violations can lead to serious disadvantages for the GARREIS Group. We therefore do not tolerate any disregard of laws, the Compliance Declaration or internal guidelines.

Depending on the severity of the violation, misconduct may result in consequences under labor law, civil law or criminal law for those affected.