Sustainability policy of Seichter GmbH

Respect for freedom and human rights constitutes an essential element of Seichter’s business activities. It creates the framework for our endeavors and is a prerequisite for our success. Seichter is committed to the principle of sustainability, which includes the responsible – i.e. effective and efficient – and sustainable use of available resources, now and in the future. As an advocate of the United Nations Global Compact, Seichter has committed itself to the ten principles it sets out in the areas of human rights, labor, the environment and anti-corruption.

Seichter is committed to honesty and integrity in terms of our overall conduct with respect to employees, customers, suppliers, competitors and other stakeholders. Seichter recognizes that legal and cultural requirements vary in a global market. Seichter expects all of its business partners to act with the same sense of fairness, honesty and responsibility and with the same commitment to corporate social responsibility in all aspects of their business.

This Business Partner Code of Conduct highlights important standards that are consistent with Seichter’s values and that we expect every business partner to observe and adhere to, including but not limited to suppliers, consultants, vendors, brokers, dealers, contractors, agents and others.

The business partner must comply with all applicable laws, rules and regulations in the countries in which it operates and take appropriate measures to ensure compliance with such laws, rules and regulations.

Combating slavery and human trafficking
The business partner will comply with all applicable laws, rules and regulations prohibiting slavery and human trafficking both in its own business and in its supply chain.

Compliance with antitrust laws
The business partner guarantees that its business practices are consistent with applicable antitrust and competition law and with other laws, rules and regulations relating for example to monopolies, unfair competition, restrictions of trade and competition, and relations with competitors and customers. The business partner will not enter into any agreements with competitors or undertake any other action that may unfairly impact competition, including but not limited to price fixing or market sharing.

Combating corruption
Seichter does not tolerate any form of corruption. By the same token, the business partner will also comply with applicable anti-corruption laws and regulations, including those relating to bribery abroad. The business partner repudiates any form of corruption, bribery, theft, embezzlement or extortion, and neither does it tolerate illegal payments, in particular payments or other benefits conferred on any individual, company or government official with a view to influencing decision- making processes, regardless of whether or not this violates applicable laws. In particular, the business partner will under no circumstances offer, give or accept bribes, payoffs, kickbacks or other illegal payments, inducements, gifts, hospitality, favors or other benefits or gratuities of value for the realization of business opportunities, or in any other way related to Seichter’s business activities.

Conflict minerals
The business partner is aware of the applicable legal requirements regarding “conflict minerals” including tin, tantalum, tungsten, their ores and gold originating in conflict areas and ensures compliance with such laws. In addition, the business partner will make every possible effort to avoid the use of raw materials in its products that directly or indirectly finance armed groups who violate human rights.

Import and export regulations
The business partner will comply with all applicable import and export control laws, including but not limited to sanctions, embargoes and other laws, regulations, government requirements and policies controlling the transfer or shipment of goods, technology and payments.

Prevention of money laundering
At Seichter, we expect our business partners to comply with all applicable statutes governing the prevention of money laundering and not to participate in any money laundering activities.

Employees are expected to act in the best interest of their company. Private interests and personal considerations do not influence business decisions. Both Seichter and the business partner avoid any activities or situations that could lead to a conflict between the private interests of a Seichter employee or business partner and the business interests of Seichter. Any business partner becoming aware of a conflict of interest will inform Seichter of it immediately.

Seichter respects human rights and actively promotes their observance. We follow the United Nations Universal Declaration of Human Rights, which calls on each individual, all bodies and institutions, and in the broader sense economic stakeholders and enterprises to contribute to the observance of these rights. In addition, Seichter respects the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy of the UN International Labour

Organization (ILO) as well as the OECD Guidelines for Multinational Enterprises. We at Seichter strive to provide people with goods while maintaining our competitiveness. The business partner will treat all individuals with respect and fairness and will observe fundamental human rights, as set out for example in the United Nations Universal Declaration of Human Rights and the Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy of the UN International Labour Organization (ILO), in particular the prohibition of forced or child labor and the provision of decent wages, social benefits, working hours, freedom of association and other fair working conditions in compliance with applicable laws.

The business partner will maintain a working environment free from repressive measures and free from discrimination, harassment and other dishonest conduct on the basis of gender, age, race, color, ethnic or national origin, citizenship, religion or religious beliefs, physical or mental disability, veteran status, sexual orientation or any other characteristic protected by law.

Seichter endorses the UN Women’s Empowerment Principles and believes that empowering women to participate fully in economic life across all sectors is essential to strengthening economies, achieving internationally agreed development and sustainability goals and improving the quality of life for women, men, families and communities.

Seichter strongly encourages its suppliers to:

• Join Seichter in formally endorsing the UN Women’s Empowerment Principles
• Ask business partners and colleagues to respect the company’s commitment to promoting equality and inclusion
• Respect the dignity of women in all marketing and other company materials

With our processes and products, Seichter makes a substantial contribution to the sustainable use of resources and to environmental protection, including climate protection in particular. Seichter strives to conserve resources by continuously adapting our production, quality and the performance of our products to environmental standards and by reducing our consumption of energy, water, raw materials and supplies.

The business partner will support Seichter in these efforts, by endeavoring for example to manufacture and supply safe products to Seichter and to provide a safe working environment that promotes accident prevention and minimizes health risks for the partner’s employees.

The business partner will comply with applicable laws and regulations on environmental protection and work to conserve resources and protect the environment to the greatest extent possible.

The business partner will comply with all applicable laws concerning data protection. The business partner is responsible for ensuring that any confidential business information or trade secrets made known by virtue of the partner’s business activities with Seichter (hereinafter “confidential information”) is held in strict confidence and is not used improperly or disclosed to third parties. In addition, the business partner will protect and safeguard Seichter’s intellectual property as confidential information.

Seichter considers the provisions of this Business Partner Code of Conduct to be essential to the business relationship between Seichter and the business partner, but reserves the right to amend them from time to time. Compliance with the provisions set out here is therefore essential for the business relationship between Seichter and the business partner, and this is acknowledged by and agreed with the business partner.

In the event of material breaches of this Business Partner Code of Conduct by the business partner, Seichter reserves the right to terminate the business relationship with the business partner, subject to applicable laws.

Seichter reserves the right to audit compliance by the business partner with this Business Partner Code of Conduct in an appropriate manner. Any audit will be scheduled to take place during business hours mutually agreed with the business partner, with the business partner providing detailed and informative documentation that clearly and transparently demonstrates compliance with this Business Partner Code of Conduct.

The business partner will make every effort to become familiar with the business practices of its suppliers, subcontractors and other business partners and to require all suppliers, subcontractors and business partners to comply with this Business Partner Code of Conduct or with comparable values.

The business partner and Seichter will discuss all issues relating to this Business Partner Code of Conduct in a spirit of confidence and respect.