SaarGummi Code of Conduct recitals

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2 SaarGummi Code of Conduct recitals The SaarGummi Group and its member companies recognise their societal responsibility within the framework of their entrepreneurial activity worldwide. The present Code of Conduct (hereinafter referred to as CoC) records as a guideline what this in particular means with a view to working conditions, social and environmental tolerability as well as transparency, trusting cooperation and dialogue. The contents of the present CoC are an expression of the joint basis of values of the SaarGummi Group as defined in the vision and mission of the SaarGummi Group and have in particular been recorded as a confession to social market economy.

3 1. Fundamental understanding of responsible corporate management for society The present CoC is based on a joint fundamental understanding of responsible corporate management for society. For the SaarGummi Group, this means that it assumes responsibility by considering the consequences of its entrepreneurial decisions and actions in an economical, technological and also social and ecological regard and brings about a suitable balance of interests. Within the framework of its possibilities and rooms for action in the individual case, the SaarGummi Group voluntarily contributes to the well-being and the lasting development of global society at the locations at which it is active. In this context, it orientates itself to generally valid ethical values and principles, in particular to integrity and rectitude and respect for human dignity. 2. Scope of application The present CoC applies to all branches and business units of the SaarGummi Group. The SaarGummi Group also engages to further compliance with the contents of the present CoC with its suppliers and in the further value-added chain within the framework of its possibilities and rooms for action in the individual case. 3. Cornerstones of responsible corporate management for society The SaarGummi Group actively aims for the values and principles stated below being lastingly observed and complied with. 3.1 Compliance with laws The SaarGummi Group complies with valid laws and other legal directives of the countries in which it is active. In countries with a weak institutional framework, it carefully examines the good entrepreneurial practice from its own home country which ought to be used in support of responsible corporate management.

4 Integrity and Organizational Governance The SaarGummi Group orientates its action to generally valid ethical values and principles, in particular to integrity, rectitude, respect for human dignity, openness and non-discrimination of religion, ideology, gender and ethics. The SaarGummi Group rejects corruption and bribery in the sense of the pertinent UN Convention. It supports transparency, upright action and responsible management and control in the enterprise in a suitable way. The SaarGummi Group pursues honest and recognised business practices and fair competition. In competition, it aligns itself to professional conduct and high-quality work. It has partner-like and trusting dealings with the monitoring authorities. 3.3 Consumers interests The SaarGummi Group protects consumers interest with directive protection and with suitable sales, marketing and information practices. Groups in need of special protection (e.g. juvenile protection) enjoy specific attention. 3.4 Communication The SaarGummi Group communicates openly and with an orientation to dialogue concerning the requirements of the present CoC and its implementation towards employees, customers, suppliers and other interest and contact groups. All documents and papers are produced conscientiously, not amended unfairly or destroyed, and are kept properly. Partners operational secrets and business information are treated sensitively and confidentially. 3.5 Human rights DThe SaarGummi Group commits itself to furthering human rights. It complies with the human rights pursuant to UN Human Rights Charta 3, in particular the following:

5 The SaarGummi Group protects private sphere. The SaarGummi Group maintains the health and industrial safety, guaranteeing a safe and health-beneficial working environment, in order to avoid accidents and injuries. The SaarGummi Group protects employees against physical punishment and against physical, sexual, mental or verbal harassment or abuse. The SaarGummi Group protects and maintains the right to freedom of opinion and freedom of expression. 3.6 Working conditions The SaarGummi Group complies with the following central working norms of the International Labour Organization ILO: The SaarGummi Group bans child labour, i.e. employment of persons younger than 15 years of age, to the extent that local legal directives do not set higher age limits and to the extent that no exceptions are admissible. The SaarGummi Group bans forced labour of any kind. The SaarGummi Group works with a view to remuneration, in particular with a view to the level of remuneration pursuant to valid laws and directives. The SaarGummi Group respects the employees rights to freedom of coalition, freedom of assembly and to collective and wage bargaining to the extent legally admissible and possible in the country in question.. The SaarGummi Group treats all employees without any prejudice or discrimination. 3.7 Working hours The SaarGummi Group complies with the working norms with a view to the maximum admissible working hours.

6 3.8 Environmental protection The SaarGummi Group fulfils provisions and standards on environmental protection affecting its individual companies and acts in an environmentally conscious way at all locations. It further deals responsibly with natural resources pursuant to the principles of the Rio Declaration. 3.9 Civic commitment The SaarGummi Group contributes to the societal and economic development of the country and the region in which it is active and supports matching voluntary activities by its employees. 4. Implementation and assertion The SaarGummi Group undertakes all suitable and reasonable efforts for continuous implementation and application of the principles and values described in the present CoC. By request and within the framework of reciprocity, contractual partners shall be given reports on the essential measures, with the result that the way in which compliance is guaranteed as a matter of principle can be understood. A claim to forwarding of operational and business secrets, of information relative to competition or otherwise worthy of protection shall not exist.

7 Editor CQLT SaarGummi Technologies S.à r.l. 9, Op der Kopp 5544 Remich Luxembourg T T group.saargummi.com CEO: Michael Lorig Registered office: Remich R.C.S. Lux B (Siège social)

8 Version 09/2017