HELLA GmbH : Verhaltenskodex für die FORVIA HELLA Gruppe Englisch

Table of Contents

Foreword	5
1. Acting Lawfully and with Integrity	8
2. Scope of Application	9
3. Labor and Social Principles	10
3.1	Diversity and Inclusion	10
3.2 No Child Labor	11
3.3 No Forced Labor	11
3.4	Freedom of Association and the Right to Collective	11
	Bargaining
3.5 Working Hours	11
3.6 Remuneration	11
4. Environment, Health & Safety, Product Safety	12
4.1	Environment, Health & Safety (EHS)	12
	4.1.1 Health & Safety	12
	4.1.2 Environmental Protection	13
4.2	Product Safety	13
5. Fair Business Practices	14
5.1	Fair Competition	14
5.2	Anti-corruption	15
	5.2.1 No Corruption	15
	5.2.2 Offering and Receiving Benefits	15

Table of Contents

5.3	Conflicts of Interest	16
5.4 Anti-money Laundering	17
6. Handling of Information	18
6.1	Confidential Information	18
6.2	Information Security	18
6.3	Data Privacy	19
6.4	Insider Information	19
6.5 Public Communication	19
6.6	Accurate Record-keeping	20
6.7	Correct Reporting	20
7. Handling of Company and Third-party	21
Property & Intellectual Property
8. Foreign Trade & Export Control and Tax	22
8.1	Foreign Trade & Export Control	22
8.2 Tax	22
9. Complying with the Code of Conduct	23
9.1	Responsibility	23
	9.1.1 Employee's Responsibility	23
	9.1.2 Management Responsibility	23
9.2 Reporting a Breach of the Code of Conduct	24
	9.2.1 Duty to Report Breach	24
	9.2.2 Direct Reporting	24
	9.2.3 tellUS!	24
9.3 Dealing with Reported Breaches	24
9.4 Breaches and Sanctions	25

Equal rights is one of FORVIA HELLA's basic principles. For better readability, where the following text refers to a specific gender, it should be understood to address all genders.

Dear Colleagues,​

FORVIA HELLA's reputation and long-lasting success is based on a corporate culture which was established over 100 years ago and continues to be lived. It forms the foundation for the trust that customers, suppliers, other business partners and third parties have in FORVIA HELLA. FORVIA HELLA's corporate culture is based on six values: drive, accountability, teamwork, agility, respect and open-mindedness. These six corporate values serve as a benchmark for our daily actions and work within the global FORVIA HELLA network.​

This Code of Conduct embodies FORVIA HELLA's corporate values and frames the behavioral expectations of every single FORVIA HELLA employee. It helps to determine right from wrong behavior and to master legal challenges that arise in our daily work with colleagues, customers, suppliers, other business partners and third parties. Consequently, it can be understood as a kind of compass that provides direction in daily cooperation and actions.​

The FORVIA HELLA Code of Conduct must be upheld and is binding on all FORVIA HELLA Group employees worldwide. This is important for FORVIA HELLA as well as for each individual. Therefrom arises the expectation that each of us at FORVIA HELLA feels personally responsible for upholding the Code of Conduct and always acts lawfully and ethically.

Lippstadt, January 2024​

Bernard Schäferbarthold	Dr. Frederik Born
CEO	Group General Counsel & Chief
	Compliance Officer

FOREWORD

CODE OF CONDUCT | 5

"Compliance is a duty for all of us - for everyone, everywhere, every day at FORVIA HELLA. But Compliance is more than that. It is our conviction and aspiration.

It guides our daily actions."

Bernard Schäferbarthold

CEO

FOREWORD

CODE OF CONDUCT | 6

"Compliance with laws and rules is at the heart of our daily activities. Acting with accountability is a core FORVIA HELLA value and means, especially, making the right decisions, ethically and lawfully."

Dr. Frederik Born

Group General Counsel & Chief

Compliance Officer

FOREWORD

CODE OF CONDUCT | 7

1Acting Lawfully and with Integrity

"FORVIA HELLA's continued success and reputation depends on each of us always behaving lawfully and honestly."

1. ACTING LAWFULLY AND WITH INTEGRITY

FORVIA HELLA's continued success and reputation depends on each of us always behaving lawfully and honestly.

We must obey and comply with all laws and regulations, wherever we do business, as well as FORVIA HELLA's internal rules in our daily work. Violations are not tolerated and can result in severe consequences for the FORVIA HELLA Group and those involved.

Furthermore, we must uphold FORVIA HELLA's values in all of our actions.

1. ACTING LAWFULLY AND WITH INTEGRITY

CODE OF CONDUCT | 8

2Scope of Application

"This Code of Conduct applies to and is binding for all of us… regardless of our position, function or level of employment."

2. SCOPE OF APPLICATION

This Code of Conduct applies to and is binding for all organizational units and holding companies in which HELLA GmbH

• Co. KGaA directly or indirectly holds shares of more than 50 % (FORVIA HELLA Group). In the case of minority share- holdings and memberships in organizations, those of us who represent the FORVIA HELLA Group on the respective decision-making bodies shall take all necessary measures to ensure compliance with the principles set forth in this Code of Conduct.

This Code of Conduct applies to and is binding for all of us, as employees of the FORVIA HELLA Group and members of the corporate bodies of the FORVIA HELLA companies, regardless of our position, function or level of employment.

2. SCOPE OF APPLICATION

CODE OF CONDUCT | 9

3Labor

and Social Principles

"We cultivate an environment

where teamwork and respect are

self-evident."

3. LABOR AND SOCIAL PRINCIPLES

We cultivate an environment where teamwork and respect are self-evident.

So, we treat our employees, business partners and other third parties with dignity, respect and in observance of the internationally recognized human rights standards and we act in accordance with the following principles.

3.1. Diversity and Inclusion

We value diversity and we encourage an inclusive work environment.

We respect all employees, business partners and other third parties regardless of gender, ethnic origin, social back- ground, nationality, skin color, sexual orientation, religion or belief, union activity, age, disability and other characteristics protected by law.

Employees are recruited and promoted based on their qualifications and skills.

We reject any behavior that creates an offensive, hostile or intimidating work environment as well as all forms of ha- rassment, including sexual harassment and mental or physical abuse.

3. LABOR AND SOCIAL PRINCIPLES

CODE OF CONDUCT | 10