LEONI : Code of Conduct (Final CoC EN)

Code of Conduct

The LEONI way: Inspired by values, led by integrity!

Foreword

The LEONI

way: Inspired

by  values,

led by

integrity!

Dear LEONI team,

LEONI is a company that stands for both, tradition and development, history and future. As such, our goal has always been to create a ­sustainable and solid business that is able to face new challenges and react to transformations in a global business environment.

We, as members of the Executive Board of the LEONI Group, truly believe that this can be reached when there is a clear and unwavering commitment - by the company itself and every employee - to act with integrity!

This LEONI Integrity Commitment can be seen as a common thread that runs through all of our company's decisions and actions.

Our Integrity Commitment means that all employees have a common understanding of what it means to behave in a morally correct manner and can rely on common and shared values as a basis for doing business.

Our Integrity Commitment and our common

Corporate­ Values define what we, as a

­company, are living and achieving every day.

Integrity is embedded in our Corporate Values and we integrate the Corporate Values in our day-to-day work, by having them as a guideline and inspiration, what to do and what to refrain from.

Integrity and LEONI's understanding of integrity is the reason that our Corporate Values don't

just sound good but are also implemented and put into practice. Combined, they establish the boundaries within which we can act confidently­.

In adopting this approach, we seek to ensure stability, secure the future of our company and contribute to the sustainable development of LEONI.

We are counting on every one of you to

support­ us on our continuous journey to ­integrity, ­because every single employee matters.

Klaus Rinnerberger	Dr Harald Nippel	Ingo Spengler
Chief Executive Officer	Chief Financial Officer	Chief Operations Officer

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Content

1	Values and Integrity	4
2	Integrity towards Society
and Environment
	2.1	Human Rights	8
	2.2	Protection against Discrimination	8
		and Harassment; Equal Opportunities, ­
		Diversity and Inclusion
	2.3	Decent Work and Working Conditions	8
	2.4	Society, Environment and	9
		Sustainability

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3

4

Integrity in the Workplace

3.1	Safety, Health and Environment	11
3.2	Company Assets and Company	12
	Resources
3.3	Information Security and Data	12
	Protection

Integrity and Compliance

4.1	Antitrust Law and Fair Competition	13
4.2	Corruption Prevention and Gifts	13
	and Benefits
4.3	Donations and Sponsorships	13
4.4	Anti-Money Laundering, Economic	14
	Sanctions and Export Controls
4.5	Taxes, Customs and Financial	14
	Compliance
4.6	Conflicts of Interests	14
4.7	Product and Quality Requirements	14

5

6

Leading with Integrity

5.1 Complying with the Code of Conduct	15
5.2	Guidance and Support	15
5.3	Treatment of Potential Violations	15
	and Reporting via the Integrity
	Platform (Whistleblower System)
Integrity Test Board	17

1 VALUES AND INTEGRITY 2 INTEGRITY TOWARDS SOCIETY AND ENVIRONMENT

1

3 INTEGRITY IN THE WORKPLACE

4 INTEGRITY AND COMPLIANCE 5 LEADING WITH INTEGRITY 6 INTEGRITY TEST BOARD

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Being a global company with international focus, it is crucial for LEONI to live a common culture. We, as employees, are creating, shaping and changing the culture of the company every day.

The Integrity Commitment described in this Code of Conduct and represented by every single one of our Corporate Values builds the basis for trust - among us as employees from every part

Values and

Integrity

Code of Conduct

of LEONI and with external stakeholders. Hence, following this commitment creates a strong ­foundation for our cooperation and success!

Embedding our understanding of integrity in our Corporate Values and being led by integrity will help us contribute both in an individual and companywide way to put the whole Integrity Commitment into practice!

Values

Our Corporate Values are:

Care

• means recognizing the needs of others and considering them in our actions.

Respect

… means treating each other as equals in an open manner while ­considering diversity.

Result Orientation

• means knowing and achieving
  goals and expected­ results.

Collaboration

… means working for a common cause based on trust and diversity of opinion.

Responsibility

• means accepting it, acting reliably, standing up for one's actions and
  being­ accountable for them.

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1 Values and Integrity

How does the Integrity Commitment manifest itself within each of our Corporate Values?

Integrity and Care

At LEONI, we take care of each other and recognize the needs of each other and our stakeholders. For our Integrity Commitment, this means showing care in a morally and legally acceptable way by being honest, trustworthy and incorruptible. We care for our company's interests and assets.

Integrity and Result Orientation At LEONI, we know our goals, work in

a committed­ and result-oriented manner and

focus­ on the important steps to reach these goals. For our Integrity Commitment, this means that we know the goals we are aiming at can only be reached when acting in full compliance­

with all applicable laws.

Integrity and Respect

At LEONI, we respect and support decisions made, while treating each other as equals with respect and openness. For our Integrity

­Commitment, this means that we respect and treat every person with equity. We do not discriminate against anybody. We respect fundamental ­human rights and consider them in every decision.

Integrity and Responsibility

At LEONI, we understand our responsibilities, stay accountable, and act accordingly. For our Integrity Commitment, this means that we ­accept and also fully assume responsibility for the impact that we, as a company, have in ­society, like for the protection of the environment, the promotion of further sustainability topics and our social responsibilities with our employees.

Integrity and Collaboration

At LEONI, we collaborate based on trust and reliability, encouraging different opinions and celebrating our joint successes. For our Integrity Commitment, this means that we demand and promote reliable collaboration in all our premises. We provide a safe and healthy ­workplace and also support union cooperation and collaboration.

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Inspired by values, led by integrity!

We follow the lead of integrity by working and behaving   responsibly.    To fulfill our   Integrity Commitment   all employees¹ are obligated to work and behave within the boundaries set by this   Code of Conduct. 

 We do not tolerate­any unlawful and /or inappropriate conduct, which contradicts this Code of Conduct. All provisions in this Code are   binding   for all employees of the LEONI group.

¹ The terms "we" and "employees" includes members of managing bodies and managers of all levels.

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Integrity towards Societyand Environment

2.1 Human Rights

At LEONI, we assume responsibility for respecting human rights and we strive to avoid human rights violations. Among others, we are deeply committed to the International Bill of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the OECD¹ Guidelines for Multinational Enterprises, as well as the ILO² Core Labor Standards and the principles of the United Nations Global Compact.

In accordance with our Human Rights and Working Conditions Policy, internal regulations and guidelines we are committed to preventing and mitigating adverse impacts on human rights within our business operations around the world, to the utmost extent. Our Human Rights and Working Conditions Policy defines our efforts for respecting human rights and establishes mandatory standards for all employees regarding our specific commitments and actions.

LEONI is promoting respect for human rights. We are strictly opposed to any form of child labor, in particular all worst forms of child labor such as dangerous work that may harm the health, safety or morals of children. We are

also strictly opposed to forced or compulsory labor of any kind in accordance with the ILO Core Labor Standards. We commit to avoid any unlawful eviction of resources which secure livelihood. We respect the rights of indigenous people and local communities.

2.2 Protection against Discrimination and Harassment; Equal Opportuni- ties, Diversity and Inclusion

At LEONI, it is essential to avoid and prevent any form of discrimination or harassment. LEONI employees are always treated with dignity and respect. No one shall be discriminated against, given preferential treatment or harassed on the basis of characteristics such as national and ethnic origin, social origin, health status, gender, skin color, political opinion, religion or belief, disabili- ty, age, sexual orientation, marital status or union membership, veteran status or other characteristics protected by local laws. Our employees shall be protected from individual arbitrary actions from personnel.

We think that empowering women to participate fully in economic life in all sectors is essential to strengthening the national economy, achieving

internationally agreed development and sustainability goals, and improving the quality of life for women, men, families and communities.

We provide equal opportunities and equal treatment to our employees and refuse to tolerate any unacceptable treatment of individuals such as mental cruelty, sexual harassment or discrimination including gestures, language and /or physical contact that is sexual, coercive, threaten- ing, abusive or exploitative.

We promote diversity within our sphere of influence and strive to create programs for vulnerable groups in order to ensure equal treatment, inclusion and integration and prevent discrimination.

2.3 Decent Work and Working Conditions

At LEONI, we attach particular importance to the observance of human rights and good working conditions for our ­employees.

We commit to ensure health and safety in the workplace beyond the scope of applicable laws and to support the continuous improvement of working conditions with the aim of having no

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1 Organisation for Economic Co-operation and Development. 2 International Labour Organisation.

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occupational accidents and illnesses across all our entities.

We adhere to all applicable wage and compensation regulations globally, including those relating to minimum wages, overtime and legally mandated benefits. The same applies to compliance with applicable collective labor agreements. LEONI is committed to paying fair wages that are at least equal to the minimum wage established under applicable law. LEONI explicitly adheres to the principle of "equal pay for equal work".

At LEONI, we ensure a high standard of safe and healthy working conditions and guaranteed work breaks, appropriate limitations of working hours and regular, paid vacation in accordance­

with applicable local laws and collective labor agreements. We ensure compliance with the applicable standards on working hours which ­include at a minimum the standards of the relevant ILO conventions at the place of employment.

To enable a high level of performance and quality work, we promote the education and

development­of all employees on the basis of equal opportunity, and we hire, train and promote employees on the basis of their individual skills.

At LEONI, we support the freedom of association and the right to collective bargaining. Employees have the right to form interest groups to represent common purposes and goals. They are neither favored nor disadvantaged if they belong or do not wish to belong to a trade union or employee representation. The rights of our workforce to choose to be a member of a trade union and

to bargain collectively as permitted by local laws and regulations must not be interfered with or restricted. In situations or countries in which the rights regarding freedom of association and collective bargaining are restricted by law, parallel permissible means to enable freedom of association and collective bargaining, which may be legally non-binding, shall be considered and facilitated.

2.4 Society, Environment and Sustainability

At LEONI, thinking and acting in an environmentally conscious manner are among the forward-looking factors for successful

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development­. We have created our ReWire sustainability programme with its focus areas climate protection, material efficiency and resource conservation as well as decent­

work.

Beyond this, we are also doing our best effort to make an impact for the protection of natural ecosystems, in particular the protection of endangered habitats of wild animals, and the sustainable use of natural resources. We take care to protect biodiversity in relation to legal deforestation and conversion of other natural ecosystems and to eliminate legal deforestation and ecosystem conversion in our value chain.

We have implemented activities aimed at

­reducing our environmental impact, including reducing greenhouse gas emissions generated in our own operations as well as ­throughout our­ value chain, collecting, calculating and evaluating relevant greenhouse gas data ­according to international standards, and making the data available on demand, increasing

energy efficiency­ and the use of renewable ­energies, ­improving air quality and emissions management, supporting waste reduction,

including through reuse and recycling and the ­provision of ­sustainable ­materials, improving

water­ ­quality and consumption­management, ­preventing ­deforestation and conversion

of natural ecosystems, the prevention of noise ­emissions, avoiding harmful soil degradation

and the responsible­ handling of chemicals used in operations and products. We have also ­implemented engagement for the society, which includes active support for the development of communities where LEONI is located.

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