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.

2.2. Waste management
Effective, sustainable waste management is a key part of GEBA-Autoteile GmbH’s responsibility. In this context, GEBA-Autoteile GmbH is committed to preventing the creation of waste, promoting reuse and recycling and safely handling hazardous waste. This voluntary commitment aims to promote a holistic waste management system that minimises environmental impacts, preserves natural resources and helps to meet international environmental and social standards.

GEBA-Autoteile GmbH follows the waste hierarchy principle and focuses on preventing waste by means of efficient processes and product design. Any waste produced is duly separated, sorted and appropriately recycled. GEBA-Autoteile GmbH develops and supports measures aimed at reuse, recycling and resource-saving product life cycles. It handles hazardous waste in compliance with all the applicable laws, standards and safety precautions – and also collaborates with specialist waste disposal firms. Employees, partners and suppliers regularly receive information and training on eco-friendly waste management.

2.3. Resource preservation
GEBA-Autoteile GmbH is committed to the responsible use of natural resources along its entire supply chain. It is committed to identifying and minimising environmental risks as well as organising its business activities in a sustainable manner. GEBA-Autoteile GmbH particularly strives to reduce the use of water, energy, commodities and materials and promotes the use of sustainable, recycled alternatives. GEBA-Autoteile GmbH favours technologies, processes and products that minimise the use of resources.

GEBA-Autoteile GmbH improves awareness of resource preservation among its employees, partners and suppliers by means of training and joint projects. GEBA-Autoteile GmbH sets
measurable resource preservation targets and regularly reviews progress achieved.

2.4. Energy efficiency
GEBA-Autoteile GmbH feels duty-bound to sustainably reduce energy consumption, both within the company and along its supply chain. By using energy responsibly, GEBA-Autoteile GmbH aims to help alleviate climate change, while promoting compliance with international environmental and social standards.

For this purpose, GEBA-Autoteile GmbH systematically records energy consumption, identifies hotspots and analyses energy intensity risks. GEBA-Autoteile GmbH continuously optimises its processes, plants and facilities with the aim of reducing energy consumption per unit of economic output. Wherever possible, GEBA-Autoteile GmbH uses electricity from renewable sources and helps its partners transition to sustainable energy sources. In addition, GEBA-Autoteile GmbH invests in modern, energy-
efficient technologies and digital solutions for monitoring and managing energy flows. Both employees and business partners regularly receive information and training on potential energy savings.

2.5. Water consumption
Water is one of the most important natural resources and a fundamental requirement for the survival of people, animals and ecosystems. GEBA-Autoteile GmbH recognises its responsibility to prevent negative impacts on the availability and quality of water – both within its own operations and along its supply chain. GEBA-Autoteile GmbH is therefore committed to ensuring the careful, sustainable use of water.

GEBA-Autoteile GmbH strives to continuously reduce water consumption by means of technical, organisational and procedural improvements. Water risks are regularly assessed at GEBA-Autoteile GmbH sites, waste water is handled appropriately and only discharged in compliance with statutory requirements and environmental standards. GEBA-Autoteile GmbH uses water-saving processes and promotes innovations to reduce and reuse water. Employees are regularly made aware of the responsible use of water and receive appropriate training.

2.6. Emissions and air quality
GEBA-Autoteile GmbH recognises the protection of the environment and human health as a central responsibility along its entire supply chain. Air pollution and climate-damaging emissions pose both ecological and human rights risks. GEBA-Autoteile GmbH is therefore committed to systematically reducing emissions and improving air quality in all the relevant business processes. The aim of this voluntary commitment is to measurably reduce climate-damaging greenhouse gas emissions and other air pollutants, implement air quality control measures and prevent negative impacts on the environment and health along the supply chain.

For this purpose, GEBA-Autoteile GmbH regularly records and analyses direct and indirect emissions (scope 1–3) and sets specific reduction targets.

GEBA-Autoteile GmbH reduces emissions of pollutants such as particulates, nitrogen oxides (NO2), sulphur dioxide (SO2) and volatile organic compounds (VOCs), wherever possible. It promotes measures to reduce CO2 emissions, e.g. by means of energy efficiency, switching to climate-friendly mobility and renewable energies, uses low-emission production processes and prioritises low-emission products and services during procurement. Employees and business partners regularly
receive information and training on emission issues, air quality control obligations and climate risks.

2.7. Sustainable procurement
Sustainable procurement practices are intended to minimise environmental and human rights risks, promote fair working conditions and increase the use of resource-saving materials and services. In addition to financial aspects, GEBA-Autoteile GmbH also considers environmental, labour and social standards, as well as ethical principles, when selecting and evaluating its suppliers. Sustainability criteria are determined in its procurement guidelines and supplier agreements, and suppliers are expected to meet defined standards.

GEBA-Autoteile GmbH prioritises the use of verifiably sustainably sourced commodities (e.g. certified, recycled or fairly traded) and avoids problematic materials such as conflict minerals, wherever possible. GEBA-Autoteile GmbH strives for maximum transparency in its supply chain and endeavours to ensure that the origin and sustainability performance of products and services can be traced. If risks are identified, GEBA-Autoteile GmbH implements targeted measures to prevent and reduce negative impacts.

2.8. Environmental awareness and training
GEBA-Autoteile GmbH acknowledges its responsibility towards the environment, society and applicable statutory frameworks. It is committed to promoting environmental awareness in all areas of the company and using targeted training to ensure that all employees and relevant business partners understand the environmental aspects of their activities and act responsibly. For this purpose, GEBA-Autoteile GmbH conducts mandatory training on environmental and climate protection issues for all the relevant employees – especially those in procurement,
production, logistics and management. Training content is tailored to the target audience, e.g. managers, operational staff or suppliers. GEBA-Autoteile GmbH creates a working environment that actively supports, communicates and
recognises environmentally responsible conduct. Employees continuously receive information about environmental legislation, internal guidelines, best practice and current developments in environmental protection. Environmental and sustainability issues are part of the new employee induction programme. GEBA-Autoteile GmbH regularly evaluates the success of its training measures and adapts them to new challenges, standards and statutory requirements.

2.9. Compliance with environmental regulations
Protecting the environment is a key social function and integral part of responsible corporate governance. GEBA-Autoteile GmbH recognises its legal and ethical responsibility not only to comply with environmental regulations, but also to actively contribute to preserving natural resources. In this context, GEBA-Autoteile GmbH is committed to consistently observing environmental legislation, standards and regulations.

GEBA-Autoteile GmbH complies with all the relevant environmental legislation, directives and official requirements at a local, national and international level. Applicable environmental regulations are regularly reviewed and existing processes adapted accordingly. GEBA-Autoteile GmbH avoids practices that are harmful to the environment and health, especially when handling hazardous substances, waste, emissions and waste water.

GEBA-Autoteile GmbH requires it suppliers to comply with the relevant environmental regulations and verifies this based on risk by means of voluntary assessments, audits or supporting
documentation. In the event of violations of environmental requirements or legislation, GEBA-Autoteile GmbH reserves the right to take appropriate action – up to and including the
termination of business relationships.

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.