CODE OF CONDUCT

Preamble

Due to the number of employees on its books, GEBA-Autoteile GmbH shall not be subject to the requirements governing corporate duty to prevent human rights violations in supply chains according to the Supply Chain Due Diligence Act or Lieferkettensorgfaltspflichtengesetz (Section 1 (1) LkSG).

Nevertheless, GEBA-Autoteile GmbH remains committed to ensuring ecologically and socially responsible corporate governance and understands the importance of adhering to such standards also when it comes to choosing suppliers, irrespective of size or location. GEBA-Autoteile GmbH guarantees in this context that it and its employees shall voluntarily comply with the due diligence obligations outlined below, and that, going forward, it shall continue to emphasise the importance of maintaining these principles both in the production of goods and in the provision of services.

The following Code of Conduct is based primarily on national laws and regulations such as the Supply Chain Due Diligence Act (LkSG) as well as international conventions such as the United Nations Universal Declaration of Human Rights, guidelines on children’s rights and business conduct, the United Nations Guiding Principles on Business and Human Rights, the international labour standards of the International Labour Organisation (ILO), and the United Nations Global Compact. This declaration does not constitute an independent obligation on the part of GEBA-Autoteile GmbH to comply with the measures outlined in the aforementioned legal principles.

1. Human Rights

1.1. Ban on Child Labour
GEBA-Autoteile GmbH condemns all forms of child labour. In general, therefore, at no point during production shall GEBA-Autoteile GmbH permit the employment of a child under the age at which compulsory education ends according to the law of the place of employment, whereby, irrespective thereof, the age of employment must never be less than 15 years. The above obligation also encompasses the ban on the worst forms of child labour for children under the age of 18. The worst forms of child labour include, in particular, all forms of slavery or practices similar to slavery as well as forced and compulsory labour and any labour which, by its nature or because of the circumstances under which it is performed, is likely to be harmful to the health, safety or morals of children. GEBA-Autoteile GmbH is also committed to ensuring that its suppliers and indirect upstream suppliers comply with this ban on all forms of child labour and that this condition is also adhered to in the procurement of raw and other materials.

1.2. Ban on Forced Labour
GEBA-Autoteile GmbH does not tolerate the employment of persons in forced labour. The ban on forced labour includes, among other things, any work or service required of a person under threat of punishment and for which he or she has not voluntarily made himself or herself available. It also includes any form of slavery and practices similar to slavery, servitude or other forms of domination or oppression in the workplace environment, such as economic or sexual exploitation and/or humiliation. Furthermore, GEBA-Autoteile GmbH is also committed to prohibiting the hiring or use of private or public security guards if, due to lack of instruction or control in the use of the security guards, the risk arises that employees might be subjected to inhuman or degrading treatment, life or limb might be endangered, or freedom of association might be impaired.

1.3. Health and Safety in the Workplace
GEBA-Autoteile GmbH shall comply fully with the applicable occupational health and safety regulations. Both GEBA-Autoteile GmbH and its suppliers shall therefore ensure that they are in compliance, especially with regard to the obligations of occupational health and safety applicable under the laws of the place of employment, in particular if a disregard of such provisions might create a risk of accidents at work or work-related health hazards. In relation to the above, this also means: blatantly insufficient safety standards shall not be permitted in the provision and maintenance of the workplace and work equipment; proper safety measures shall be taken to prevent exposure to chemical, physical or biological substances; measures shall be taken to prevent excessive physical and mental fatigue caused, in particular, by inappropriate work organisation in terms of working hours and rest periods; and insufficient training and instruction of employees, where this might pose a safety risk to employees or third parties, shall not be permitted.

1.4. Freedom of Association
GEBA-Autoteile GmbH is committed to ensuring that both its employees and those of its suppliers are free to form or join employee associations, coalitions and other organisations. In particular, it shall be ensured that employees are permitted to form or join labour unions, that the formation, joining and membership of a labour union may not be used as a reason for unjustified discrimination or retaliation, and that labour unions may operate freely and in accordance with the law of the place of employment; this includes the right to strike and the right to collective negotiations. Employees shall not be discriminated against based on the fact that they have formed, joined or are a member of such an organisation.

1.5. Ban on Discrimination
GEBA-Autoteile GmbH rejects all forms of discrimination in the workplace. This includes all forms of unequal treatment, for example, on the basis of national and ethnic origin, social origin, health status, disability, sexual orientation, age, gender, political opinion, religious or philosophical convictions, and other personal or physical and mental characteristics. However, unequal treatment also includes, in particular, the payment of unequal salary for work of equal value. The personal dignity, privacy and personal rights of each individual shall be respected.

1.6. Fair Compensation
GEBA-Autoteile GmbH is committed to providing fair compensation. In particular, refusal to pay a reasonable wage which, at a minimum, is set by the minimum wage stipulated in the applicable law, is prohibited. Penalising employees through wage deductions is not permitted. tGEBA-Autoteile GmbH is committed to providing its employees with a clear, detailed and regular breakdown of their compensation package in writing.

1.7. Preservation of Natural Resources
GEBA-Autoteile GmbH is committed to the preservation of natural resources and condemns all forms of unlawful deprivation of natural resources by individuals. GEBA-Autoteile GmbH therefore prohibits all activities that cause harmful soil alteration, water pollution, air pollution, harmful noise emissions, or excessive water consumption that would significantly impair the natural basis for the preservation and production of food, deny a person access to safe drinking water, prevent or destroy a person's access to sanitary facilities, or harm the health of a person. This also includes a prohibition on unlawful eviction and unlawful deprivation of land, forests and waters in connection with the acquisition, construction or other exploitation of land, forests and waters which provide a livelihood to one or more persons.

2. Ecological Responsibility

2.1. Handling Waste and Hazardous Substances
GEBA-Autoteile GmbH is committed to preventing avoidable environmental risks. GEBA-Autoteile GmbH shall therefore comply, in particular, with the provisions from the Minamata Convention, the Stockholm Convention on Persistent Organic Pollutants (POPs), and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, and shall call on its suppliers to do likewise.

Specifically, compliance with these provisions means that

• the manufacture of products containing mercury is prohibited; the use of mercury and mercury compounds in manufacturing processes is prohibited; it is prohibited to treat mercury waste contrary to the provisions of the Minamata Convention;
• it is prohibited to produce and use chemicals with persistent organic pollutants (POPs); it is prohibited to handle, collect, store and dispose of waste in a way that is not environmentally friendly according to the Stockholm Convention;
• and it is prohibited to export hazardous waste according to the Basel Convention.

3. Implementation of Requirements

GEBA-Autoteile GmbH is committed to ensuring that the human rights and environmental duties laid down in this Code of Conduct shall be appropriately observed both in its offices and in its supply chains with the aim of preventing or minimising human rights risks and environmental risks or ending any violations of human rights-related or environmental obligations.

In this context, GEBA-Autoteile GmbH shall establish an appropriate and effective risk management system and conduct a risk analysis to determine the human rights risks and environmental risks in both its own business area and at its direct suppliers. In this context, GEBA-Autoteile GmbH shall also maintain appropriate internal grievance procedures to be used to highlight human rights risks and environmental risks as well as violations of human rights-related or environmental obligations arising as a result of economic activities in its own business area or activities carried out by a direct supplier.