Code of Conduct

Code of Conduct

contents

1 Introduction

2. Working conditions and human rights

2.1 Human Rights Compliance Provisions

2.2 Working conditions at Balzer & Co GmbH

3. Occupational health and safety

3.1 Workplace Conditions and Environment

3.2 Accident and incident management, page

4. Business Ethics

4.1 Dealing with Business Partners and Third Parties

4.2 Conflicts of Interest

4.3 Transparency in Handling and Protection of Information

4.4 Counterfeiting and Intellectual Property

5. Environmental protection

5.1 Management of natural resources

5.2 Chemicals and Hazardous Substances

Scope and Implementation

Foreword by the management

At Balzer, we strive for exemplary quality in products and processes, but also in behavior. Our corporate values form the basis for this. Because we are firmly convinced that respecting and maintaining our Balzer values will continue to form the basis of our success in the future.

Committed to these Balzer business principles, we have introduced rules and procedures in our company that ensure that we can meet all of the high demands placed on ourselves.

These rules and procedures are constantly reviewed and adapted to current and legal requirements. They are accessible to all employees*.

These principles are divided thematically into:

- policies on working conditions and human rights,

- guidelines on occupational health and safety,

- Business ethics policies and

- Environmental protection guidelines.

These guidelines are summarized in our Code of Conduct, which we also require all business partners to comply with.

The following guideline on working conditions and human rights gives a detailed overview of the most important principles for us to comply with human rights and working conditions at Balzer & Co GmbH.

For us, strict observance of these rules is one of the principles of good corporate governance, which is why we commit ourselves and all our employees to complying with them.

These guidelines are summarized in our Code of Conduct, which we also require all business partners to comply with.

Joachim Balzer
managing Director

1 Introduction

The trust of our customers, suppliers, business partners and the general public in our company depends decisively on the behavior of each individual employee. The basis of this trust is the constant observance of the law and all of our internal company rules. In return, we ask all business partners to also comply with these rules.

Balzer & Co GmbH is aware of its responsibility towards society and acts accordingly. We recognize the joint responsibility of the company and our employees for the common good. That is why we have summarized the most important rules in this code of conduct, thus continuing the culture of honesty and decency that we have practiced for a long time. At the same time, we provide every employee with guidelines that are intended to support them in their independent actions that are shaped by the well-being of the company. This personal responsibility is both a right and a duty. Every employee is responsible in his area of responsibility for ensuring that his behavior always complies with the rules summarized here. Due to their role model function, we require our managers not only to communicate these rules, but also to set an example themselves and demand them from their employees. Our managers are the first point of contact for their employees in all questions related to this code of conduct. As a general rule, we comply with the laws of the countries in which we operate. This is in line with our core values and applies regardless of the penalties that may be imposed. Illegal conduct is not in the interest of our company because it is unethical, leads to a serious loss of reputation and can result in criminal prosecution, damages and loss of business. Employees who act illegally must be aware that they themselves are at risk of prosecution. Law-abiding behavior therefore serves to protect the employee. Every employee is therefore obliged to inform themselves about the regulations applicable in their area of responsibility and to comply with them. In cases of doubt, the supervisor should be consulted for clarification.

2. Working conditions and human rights

Balzer & Co GmbH is aware of its responsibility towards society and acts accordingly. We recognize the joint responsibility of the company and our employees for the common good. For this reason, we are committed to the Universal Declaration of Human Rights of the United Nations and actively promote compliance with it.

2.1 Human Rights Compliance Provisions

We therefore have a zero-tolerance policy towards the use of child labour, forced or compulsory labor and human trafficking, as well as towards harassment and discrimination. If a violation of one of the following regulations by one of our employees or business partners becomes known, the employment or business relationship will be terminated immediately and without notice. In order to ensure that human rights are respected, the following principles apply to us.

2.1.1 Child Labor and Young Workers

We do not tolerate child labor. Any activity that could endanger the development of young employees is prohibited.

2.1.2 Forced or Compulsory Labor and Human Trafficking

All activities in our working environment are carried out by our employees voluntarily and without coercion or threat of punishment. Forced labour, debt bondage, involuntary prison labor and slavery or human trafficking should not be used by any business and we strictly condemn them.

2.1.3 Harassment

We respect and protect the dignity of our employees and treat them with respect. We advocate that all employees can work in a work environment free of sexual, psychological and physical harassment.

2.1.4 Non-discrimination

We offer equal opportunities for all employees and, as a matter of principle, do not tolerate any kind of discrimination based on ethnic origin, national and social origin, gender, religion or belief, political opinion, disability, age, sexual identity or any other reason .

2.2 Working conditions at Balzer & Co GmbH

Productivity and humanity are together essential for sustainable corporate success. The economic success of Balzer can only be ensured by and with our employees. For this reason, the following regulations apply.

2.2.1 Wages and Benefits

Working hours Wages, salaries, social benefits and other claims arising from the employment relationship are paid directly by us after the end of each pay period in accordance with the statutory regulations. A statutory minimum wage must never be undercut. All overtime is worked voluntarily by the employee and remunerated accordingly. The maximum weekly working time must be observed.

2.2.2 Freedom of Association and Assembly

We respect our employees' right to freedom of association and collective bargaining, as well as the right to form interest groups. An employee must not suffer any disadvantages as a result of membership in a trade union.

3. Occupational health and safety

The protection of our employees is our top priority. For this reason, we have drawn up extensive regulations on occupational safety, which are regularly trained. Every manager is responsible for knowing the safety regulations and instructing their employees accordingly or ensuring that third parties instruct them accordingly. All employees are equally responsible for consistent compliance. For more detailed information on the subject of occupational safety, please refer to the Occupational Health and Safety Policy.

3.1 Workplace Conditions and Environment

We ensure a safe and healthy working environment. This includes in particular the following fields of action.

3.1.1 Use of Resources

As a precautionary measure against accidents at work, all company facilities and systems may only be used for the appropriate official purposes, unless private use is expressly permitted. All facilities should be managed responsibly to protect tangible and intangible assets and ensure their security.

3.1.2 Workplace ergonomics

In addition, we set up all workplaces according to legal, safety and occupational health regulations, so that the work can be carried out accident-free and with little stress.

3.1.3 Health Promotion

We support this by providing ergonomic aids and protective equipment as well as preventive programs and health promotion measures that maintain and promote the health, performance and job satisfaction of our employees.

3.2 Accident and Incident Management

Our accident and incident management is primarily based on the principle of prevention. In addition to the aforementioned regulations for the direct occupational health and safety protection of our employees, this primarily includes protection against fire, accidents and toxic substances.

3.2.1 Emergency Preparedness

On the one hand, we achieve protection through preventive measures. This includes clear work instructions and regulations for accident prevention. These are supported by various technical facilities. On the other hand, we achieve this protection through regular emergency training as part of our annual occupational safety training, which all employees must attend.

3.2.2 Accident Reporting

Should an accident at work or other disruptions nevertheless occur, this must be reported and documented immediately. The accident report must contain the course of the accident, the consequences of the accident, the cause of the accident and the planned measures to avoid similar accidents in the future. These measures should be implemented as soon as possible.

3.2.3 Fire safety

Behavior in the event of a fire is also taken into account in the safety briefing. In addition, trained fire protection assistants are appointed to support our employees with questions. All of our facilities and systems are designed to minimize the risk of fire.

4. Business Ethics

In addition to the high quality of our products and services, a high level of professionalism and absolute integrity is a fundamental requirement. It is therefore of the utmost importance to us that business decisions are always based on objective criteria such as quality, reliability, competitiveness and taking into account recognized compliance standards and the meet the principles of good corporate governance.

4.1 Dealing with Business Partners and Third Parties

4.1.1 Corruption, Extortion and Bribery

We have zero tolerance for all forms of bribery, corruption, extortion and embezzlement that constitute an abuse of power for personal gain or to distort competition.

4.1.2 Fair Competition

We observe the rules of fair competition and support all efforts to enforce a free market and open competition nationally and internationally. We therefore refrain from any order that can only be obtained by violating laws or other relevant regulations. In particular, agreeing on prices and conditions, dividing up markets and regions, allocating customers and coordinating supply, development or production strategies and coordinated behavior are prohibited.

4.1.3 Money Laundering

We ensure that the applicable legal provisions against money laundering, i.e. the smuggling of illegally earned money or illegally acquired assets into the legal financial and economic cycle, are observed.

4.1.4 Export Controls and Economic Sanctions

We comply with all applicable import and export control laws, sanctions and embargoes that place restrictions on exporting or re-exporting to certain destination countries and prohibitions on transactions involving certain countries, regions, organizations and individuals.

4.2 Conflicts of Interest

We strictly separate business and private interests. We make our decisions on the basis of a solid factual judgement, which is not clouded by favoritism resulting from personal relationships and opinions. Business partners must not be given preference in business decisions out of private interest. In addition, our employees do not use their work at Balzer to obtain private benefits. Secondary business activities require the prior approval of the management.

4.3 Transparency in Handling and Protection of Information

4.3.1 Financial Responsibility

We document all essential business transactions in a comprehensible and timely manner. Financial records are to be prepared in accordance with applicable law and generally accepted principles of proper accounting. Internal and external reports must be correct and complete so that the recipient can get an accurate picture. Documents needed for internal investigations or government investigations may not be destroyed, removed, or altered.

4.3.2 Disclosure of Information

Accordingly, we disclose information in accordance with applicable regulations and standard industry practice.

4.3.3 Privacy

We only use the personal data of our employees and contractors for the purposes for which they were made available to us and treat them confidentially. We also appropriately use and protect non-personal data resulting from a business relationship. With our data protection guidelines, we also ensure that data worthy of protection is collected, processed, secured and deleted appropriately. Confidential content will under no circumstances be published without authorization, passed on to third parties or made available in any other form.

4.3.4 Preserving Identity and Protection Against Retaliation

We are also particularly committed to protecting against retaliation and protecting the identity of any employee, business partner or other third party who reports known or suspected misconduct or violations. The reporting of violations or suspected cases must under no circumstances result in negative or repressive measures for the reporting party.

4.3.5 Patents and Trade Secrets

The constant further development of our proprietary technologies and improvements in our know-how is of crucial importance for maintaining our competitiveness. No employee or business partner may therefore pass on new findings, confidential information or business secrets to third parties in any form. This also applies after the termination of the employment or business relationship.

4.4 Counterfeiting and Intellectual Property

The market success of our products and services is inextricably linked to their quality. Our motto "Quality is the basis of our success" places high demands on all employees in terms of creativity, diligence, orderliness and precision. We do not tolerate deliberate or negligent behavior that results in a reduction in our quality. For this reason, the use of Plagiarism or falsification of materials is prohibited.In addition, we respect intellectual property and will not make unauthorized use or disclosure of intellectual property, especially intellectual property protected by patents, copyrights or trademarks.

5. Environmental protection

By environmental protection we understand the protection of all natural resources, such as water, air or energy. This includes the following principles, compliance with which is the central task of every employee. But we also demand compliance with these standards from our business partners:

• Compliance with relevant environmental regulations, standards and threshold values,

• protection of environmental elements from harmful effects,

• Avoidance or prevention of environmental damage,

• minimizing the amount and hazardousness of waste,

• Minimization of material and energy consumption.

5.1 Management of natural resources

5.1.1 Energy efficiency and resource consumption

In all work and activities, we try to keep the consumption of energy and other resources as low as possible. This also applies to all external companies that work in our company. In particular, this applies to air pollution control, the minimization of greenhouse emissions and water protection. In order to rule out environmental pollution, all machines and vehicles are always kept in perfect technical condition.

5.1.2 Waste prevention

All processes are designed to waste as few resources as possible and thus keep waste to a minimum. We also use renewable energy and recycled resources, further reducing the waste generated by our operations.

5.2 Chemicals and Hazardous Substances

Chemicals and hazardous materials that pose a hazard if released into the environment must be used responsibly and in compliance with applicable government regulations. Above all, this includes correct identification and ensuring the safety of employees and the environment in handling, storage, use, reuse and disposal. Employees who come into contact with chemicals or hazardous substances are therefore instructed accordingly. It is the duty of all employees and business partners to avoid any risk to the environment.

Scope and Implementation

This code of conduct is binding for all employees of Balzer & Co GmbH. Our managers have a special responsibility. They are called upon to exemplify the rules of conduct and values of Balzer described in this code and are the first point of contact for questions from their employees about the correct behavior in individual cases. They are also responsible for ensuring compliance with this Code in their area of responsibility. We also require all business partners to comply with the Code. Questions about this code or correct behavior in individual cases will be answered by the respective superior or the management. Violations of this Code will not be tolerated and will result in disciplinary action. These range from warnings to termination of the employment or business relationship. All indications of such violations will be investigated. In the case of information given in good faith, confidential treatment of the person giving the information is promised.

Balzer & Co GmbH

Lower Meadows 1

D-76669 Bad Schoenborn

Phone: +49 7253 80294-10

Fax: +49 7253 32830

info@balzer-co.de

www.balzer-co.de

Status: 08/2022

* For reasons of better readability, the simultaneous use of the language forms male, female and diverse (m/f/d) in the text is avoided.

All personal designations apply equally to all genders.