DECLARATION OF PRINCIPLESON RESPECTING AND PROTECTINGHUMAN RIGHTS AT VON ARDENNE
DATE DECEMBER 2023

DECLARATION OF PRINCIPLES ON RESPECTING AND PROTECTING HUMAN RIGHTSDECLARATION OF PRINCIPLES ON RESPECTING AND PROTECTING HUMAN RIGHTSDECLARATION OF PRINCIPLES ON RESPECTING AND PROTECTING HUMAN
RIGHTS AT VON ARDENNERISK ANALYSIS, PREVENTIVE & REMEDIAL MEASURESAt VON ARDENNE we have a sense of responsibility for our business activities and for respecting and protecting
human rights in conjunction with those activities. We are committed to protecting these rights and helping ensure
they are upheld by taking both preventive and remedial action should our activities cause or contribute to risks topeople or the environment.
This aspiration applies to all business activities undertaken by our national and international corporate affiliates
in their relevant locations and application areas, where we exert a decisive influence. We also call on our direct
suppliers to ensure that human and environmental rights are protected and respected in their own commercial
operations and in the wider supply chain and to establish appropriate due diligence processes.
Our conduct in this area is aligned with internationally recognized guiding principles for business and human rights.
As guidance, we refer to the key principles and requirements set out in the following standards:o United Nations Universal Declaration of Human Rights (link)o Core Labor Standards issued by the International Labor Organization (ILO) with its 5 basic principles (link)		

o Freedom of association and the right to collective bargaining		

o Elimination of forced labor		o Abolition of child labor		

o Prohibition of discrimination in employment and occupation		o Occupational health and safety

o OECD Guidelines for Multinational Enterprises (link)
We also support the United Nations Sustainable Development Goals with our initiatives. In particular, we aim tocontribute to the following goals:
o Goal 7 – Affordable & clean energy
o Goal 8 – Decent work & economic growtho Goal 9 – Industry, innovation & infrastructureo Goal 10 – Reduced inequalities
o Goal 12 – Responsible consumption and production patterns
o Goal 13 – Climate protection measures
Our expectations for social and ethical conduct in our dealings with employees and business partners are set outin the VON ARDENNE Code of Conduct. The declaration of principles on respecting and protecting human rights isbinding for all employees and management executives at the VON ARDENNE Group as well as in all the companies itcontrols.

Pia Von Ardenne
Managing Director of the VON ARDENNE GroupIn order to meet our due diligence obligations, at VON ARDENNE we regularly analyze potential risk factors withregard to the violation of human and environmental rights. This involves instigation of an analysis and evaluation ofannual procurement activities and the supplier base for each of our locations at the start of every financial year. Inaddition to this internal risk assessment, which focuses on volume and country risks as well as risks from conflictminerals, we use metrics from internationally recognized institutions to evaluate corruption and legal risks. This isdone based on the following indices:o Transparency International — Corruption Perceptions Index (link)o ITUC — Global Rights Index (link)
To improve our annual risk evaluation process for direct suppliers, we are planning to introduce a systematic
analytical solution from an external provider. Our aim here is to further enhance transparency and risk assessment
for our supply chains.
To analyze and assess the legal risks in our own business area, the executive management team has set up acompany-wide Compliance Board with representatives from all the relevant corporate areas. The Compliance
Board evaluates new compliance-related challenges, assesses the need for adjustments, derives risk management
measures and promotes their implementation within the company. The Compliance Board is tasked with preparingan annual compliance report outlining the risk analyses, the measures taken and any incidents that have occurred,
which can indicate additional risks relating to the violation of human and environmental rights.
In order to take prompt action against potential violations of human or environmental rights, we also have awhistleblower and complaints system (link) for internal and external stakeholders. This system serves to preventand detect legal infringements and is designed to help strengthen the compliance culture and uphold human andenvironmental rights throughout the supply chain. We actively communicate this reporting option to encourage
anyone affected to support us in identifying and eliminating potential risks. The confidential and anonymous
whistleblower / complaints office is part of our compliance management system and associated processes. As partof this complaint procedure, any cases reported are also subjected to a risk assessment in the internal area and for
direct suppliers.
The combined assessment of all evaluated risks forms the basis for identifying appropriate measures to be taken in
the internal business area as well as by our direct suppliers. In addition, we use the results as the basis for creatingand (where necessary) adapting internal regulations, processes and training to meet the changing requirements ofour due diligence processes.
In this context, we have identified the following key topics for the VON ARDENNE Group, where potential risks ofviolations of human and environmental rights could arise:

Supplies & preliminary products
Our business activities are at the end of multi-stage supply chains. In our manufacturing processes, we use raw
materials, semi-finished and finished products, e.g. made of steel, stainless steel and other metals. Most of ourprocurement expenditure is attributable to semi-finished products and supplier components to be integrated in
our own products. A high proportion of supplies are procured from national suppliers at our respective locations.
However, international procurement of goods also plays an important role in our project implementation.
Production of the goods we purchase requires upstream procurement and processing of raw materials. This involves
our suppliers also availing themselves of procurement options on international markets. The procurement of raw
materials and the production of these goods at earlier stages in the international area could result in risks relating tohuman and environmental rights. To secure our commitment to human rights and environmental issues, our Codeof Conduct also applies to our direct suppliers, and we require their active agreement to comply with this code.
Furthermore, compliance with our requirements is reflected in our general supply conditions.

CODE OF CONDUCTDECLARATIONOF PRINCIPLES ON RESPECTING AND PROTECTING HUMAN RIGHTSDECLARATION OF PRINCIPLES ON RESPECTING AND PROTECTING HUMAN RIGHTS

The risk analysis via our business partners forms the basis for identifying appropriate measures. On-site audits
have been an integral part of the quality assessment and inspection of our existing supplier base for many years. To
consolidate our requirements for the protection of employees and the environment in the supply chain, our audit
questionnaire has been supplemented with important topics relating to compliance with legal provisions and due
diligence obligations. We will be adding more detail and expanding the auditing process in this area in the comingyears.

CONTINUITY IN REVIEW & REPORTINGIdentifying risks and tracking the effectiveness of measures is a regular process in VON ARDENNE’s internalbusiness units. A meeting is held every two months under the remit of the Compliance Board. A consolidated
report on the identified risks as well as on the issues dealt with during the reporting period is to be made available
to the executive management on an annual basis.

Environmental considerations

One aspect of monitoring our direct supply chains involves carrying out audits at the production facilities
of selected suppliers. In addition to a focus on auditing quality management, technological and economic

Activity at our sites for producing coating systems leads to the use of resources such as land, water, energy andperformance, audits also consider occupational health and safety and environmental issues. For suppliers in high-hazardous substances and thus also generates waste and emissions. We have recognized the need to reducerisk regions, we aim to pay greater consideration to criteria relating to human rights in future audits. As part of ourthe impact of our business activities on the environment. The foundation for improving our corporate processes

supplier audits, the results are logged and measures to be taken are documented. Depending on the agreement

involves the introduction and continuous improvement of management systems in the areas of environment andwith the supplier, we may assist them in implementing the agreed improvements. In every case, we follow up inenergy. In addition, we strive to continuously reduce basic energy requirements at our locations through energy-

subsequent review audits to ensure the identified risk has been eliminated.

related measures and by switching to renewable energies.
In addition to our regular risk assessment, we engage in non-routine assessments where required to evaluate
To reduce emissions, we carry out analyses to determine appropriate measures and to optimize the overall carbon

potential risks relating to the violation of human and/or environmental rights. This occurs if there are changes tofootprint for our corporate group. Particularly important contributions can be made here by using recycled raw

our business activities, e.g. entry into a new business area or region, the launch of new products or working withmaterials, by improving energy requirements for production processes, and by considering transportation options

new business partners.

for our international delivery routes.

Occupational health & safety
As a manufacturing company that carries out the installation and commissioning of coating systems and services
internationally, accidents represent a risk that we endeavor to avoid. In compliance with all local legal requirements
relating to occupational health and safety, we ensure that all our employees and subcontractors are appropriately
qualified and have successfully completed the necessary specialist training to carry out their tasks. Regular risk
assessments are conducted to identify necessary measures in order to improve our occupational health and safetyactivities.

Equality
Within our international corporate structure, we employ people from many different countries. With numerous
activities in different countries and regions, there is a potential risk of cultural misunderstandings and discrimination.
It is part of our fundamental understanding that we absolutely reject any kind of unequal treatment or unfair
practices. To develop an understanding of the cultural characteristics of particular regions, we conduct regular
cultural training for the relevant areas. To promote positive ethical and social behavior, we have defined basic rules
as part of our Code of Conduct and in the “VA Together” guidelines, which we incorporate in regular internal training.
As an employer with an international customer structure, we actively promote the recruitment of international
applicants. We also aim to increase the recruitment of women, particularly in technical fields. We actively consider
the compatibility of work and family in our corporate processes and company agreements in order to ensure
maximum flexibility for our employees.

Responsibility & monitoring
Responsibility for meeting our human rights due diligence obligations lies with the Management Board at VONARDENNE SE & CO KGaA, the directors responsible for managing the entities within the corporate group, and themanagers of our business units.
Implementation of these obligations is part of the group-wide sustainability program, via its steering andimplementation officers from the Sustainability Working Group. This consists of the individuals responsible for thevarious key topics and is managed by the Sustainability unit. An individual has been appointed with responsibility
for coordinating human rights issues centrally, with considerable support from the Purchasing, Legal, HR andQuality departments.
This Declaration of Principles on Human Rights was issued by the Management Board of VON ARDENNE SE & Co
KGaA on December 21 2023, and applies to employees of the VON ARDENNE Group worldwide.

Pictures: shutterstock © VON ARDENNE Holding SE & Co. KGaA I Am Hahnweg 8 I 01328 Dresden I Germany I www.vonardenne.com I 12/2023