SUPPLIER CODE OF CONDUCTMAHLE’s principles stand for innovation, responsibility, fairness and customer orientation. Ourbehavior is based on these values. Not only do these values govern how we deal with eachother and work together, they also apply to our relationships with customers, suppliers, andother business partners.
Being a global company, MAHLE1 is aware of its legal, social and environmental responsibility
and is committed to these principles. In particular, MAHLE is committed to climate protection
in line with the Paris Agreement and has set the target to reduce carbon emissions by 49%
until 2030 and to become carbon neutral until 2040 (Scope 1+2). Responsible business andrespect for human rights in line with the International Bill of Human Rights, the UN Guiding
Principles on Business and Human Rights, the Fundamental Conventions of the International
Labor Organization (ILO), and the OECD Due Diligence Guidance for Responsible BusinessConduct constitute fundamental elements of our corporate social responsibility.
To ensure compliance with legal and other requirements within MAHLE, we have developed
a global compliance structure. MAHLE’s approach to doing business reflects its continuous
pursuit of excellence. Employees as well as interacting external parties are held to the samehigh standard compliant with all applicable anti-corruption, competition and antitrust laws, aswell as with all applicable social and environmental provisions and other applicable laws. It isimperative to prevent false behavior and every employee is expected to uphold the company’spublic reputation.
In order to ensure compliance with statutory provisions and ethical, social and environmental
principles within its own supplier base, MAHLE has developed this Supplier Code of Conduct
for all suppliers of MAHLE and all suppliers must ensure compliance with these provisions.

RESPONSIBLE BUSINESS CONDUCT & ETHICS
MAHLE is committed to competing globally with honesty, integrity and in full compliance withall applicable laws and regulations. MAHLE prohibits all forms of corruption, extortion andembezzlement, and will not conduct business with any supplier engaged in such practices.
MAHLE requires the supplier to comply with all applicable laws and regulations relating to its
behavior with business partners. The supplier commits to upholding its social andenvironmental responsibility in all business dealings in the countries where it conducts
business. At a minimum, the supplier is obliged to comply with the following:
1. Prevention of Corruption. The supplier will not seek, accept, offer or grant unfair
advantages.
Advantages are any kind of gratuity that the beneficiary has no claim to and which
objectively improves the beneficiary’s economic, legal or personal situation.
An advantage is unfair when it is not customary and inappropriate in light of all thecircumstances of the particular case.

1“MAHLE” includes all fully-consolidated MAHLE companies

Page | 1 MAHLE Supplier Code of Conduct, Edition December 2022, ©MAHLE 2022

MAHLE public (CL1)2. Competition Law and Antitrust Law. The supplier conducts its business in line withfree and fair competition and in accordance with all applicable competition and antitrustlaws.
3. Foreign Trade. The supplier complies with all applicable export control, customs, taxand foreign trade regulations, including without limitation, applicable EU- and USsanctions, embargoes and other laws, regulations, government orders and policies
controlling the transmission or shipment of goods, technology and payments.
4. Fraud and Anti Money Laundering. The supplier takes appropriate measures toprevent any form of fraud and to ensure that the business relationship to MAHLE is
not abused for money laundering or for any other unlawful activity (for example terrorist
financing).

5. Conflicts of Interest. The supplier makes business decisions independently andmakes sure to keep business interests strictly separate from private interests.
6. Confidentiality. The supplier must keep trade and business secrets as well as allother confidential information strictly confidential. Such information is to beappropriately protected from disclosure to and against access by third parties.
7. Data Protection. The supplier has to process (like collection, recording, organization,structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure bytransmission) personal data in strict compliance with all freedom of information acts,in particular with the European Union Freedom of Information Act, data protection laws
like the EU General Data Protection Regulation and the German Federal Data
Protection Act and all applicable regulations.
8. Intellectual Property. The supplier respects intellectual property rights. The supplierperforms the transfer of technology and know-how transfer in such manner that all
intellectual property rights of MAHLE are protected.
9. Counterfeit Parts. The supplier develops, implements, and maintains methods andprocesses appropriate to its products and services to minimize the risk of introducing
counterfeit parts and materials into products.

RESPONSIBLE WORKING CONDITIONS AND PROTECTION OF HUMAN RIGHTSThe supplier respects and supports compliance of internationally recognized human rights, inparticular the International Bill of Human Rights, the UN Guiding Principles on Business andHuman Rights, and the Fundamental Conventions of the International Labor Organization(ILO), attesting to the following:
1. No Forced or Underage Labor, Slavery or Human Trafficking. The supplier rejects
all forms of forced labor and does not employ any person who is under the statutory
minimum age as stated in the applicable laws. The supplier does not participate in andrejects all forms of slavery and human trafficking. In particular, the supplier ensures

Page | 2 MAHLE Supplier Code of Conduct, Edition December 2022, ©MAHLE 2022

MAHLE public (CL1)that no exploitative child labor within the meaning of ILO Convention no. 182 is or wasinvolved in producing or processing the products to be delivered, as well as that theseproducts do not violate any obligations resulting from the implementation of thisConvention.
2. Diversity, Non-discrimination and Equal Opportunity. The supplier values diversity
in its workforce and commits to building an inclusive work environment. The suppliercommits to the principle of equal opportunity when selecting and promoting its
employees and other employment decisions. In doing so, the supplier refrains fromany discriminatory treatment on the grounds of gender, ethnic and cultural origin,religion, political views, nationality, membership of an employee organization,disability, age, or sexual orientation
3. Anti-harassment. The supplier does not tolerate coercion, harassment or bullying in
the workspace. The supplier does not threaten or subject employees to any form ofpsychological, physical, sexual or verbal abuse, intimidation or harassment, andprohibits the same.
4. Freedom of Association and Right to Collective Bargaining. The supplier respects
the right of its employees to associate freely in accordance with local laws. The supplier
treats employees fairly who act as employee representatives or who are members oflabor unions. The supplier respects collective bargaining, as a process of negotiations
between employers and a group of employees aimed at reaching an agreement thatregulates working conditions. The supplier will strive for a trustful cooperation with theresponsible employee representatives and labor unions.
5. Working Hours and Wages. The supplier complies with all applicable laws regarding
working hours, minimum wages and benefits. In addition, working conditions mustallow an appropriate standard of living, securing workers’ livelihood and social andcultural participation.
6. Health and Safety. The supplier complies with all applicable health and safety-related
laws and regulations. The supplier takes proactive measures to ensure andcontinuously improve safe and healthy working conditions for its employees,contractors and visitors.
7. Protection of Local Communities and Indigenous Peoples. The supplier respects
the rights of local communities and indigenous peoples who may be affected by doing
business at the supplier’s locations and to take into account the local impact of its
business activities.
8. Conflict Raw Materials. The supplier is committed to identify and replace materials
and products containing minerals from conflict-affected and high-risk areas and avoid
the use of such minerals. The supplier shall investigate the source of these minerals
and undertake due diligence measures in their supply chains to ensure that conflictminerals are only sourced from mines and smelters outside of conflict-affected andhigh-risk areas or use smelters and refiners validated as conformant to an independent

Page | 3 MAHLE Supplier Code of Conduct, Edition December 2022, ©MAHLE 2022

MAHLE public (CL1)3rd party responsible mineral sourcing validation program. The supplier is also
required to extend the responsible sourcing and due diligence requirements to sub-tiersuppliers and report any identified risk in the supply chain.
If requested by MAHLE, the supplier provides a Conflict Minerals Reporting Template(CMRT) and/or CRT (Cobalt Reporting Template) on an annual basis. Suppliers of3TG (tin, tantalum, tungsten, and gold) and suppliers that use these raw materials intheir products must identify and disclose all the smelters and refiners in their supplychains.

ENVIRONMENTAL SUSTAINABILITY AND CLIMATE PROTECTION
MAHLE believes it is crucial to harmonize the future of humanity with technical progress.
MAHLE is continuously evaluating and improving its products and processes to ensuresustainable use of resources and efficient use of energy limiting the impact of our operations
and products on climate change and natural resources. MAHLE expects the same of its
suppliers.
The supplier ensures that it complies with all applicable environmental laws and environmentalregulations. In addition, the supplier respects the requirements of the international conventionsof Minamata (mercury), Stockholm (persistent organic pollutants), and Basel (hazardouswaste). The supplier maintains all required environmental permits up-to-date and complies
with reporting requirements and regulations. In addition, the supplier has or will implement
environmentally friendly and sustainable business practices, including:
1. Climate Protection / Reduction of Greenhouse Gas Emissions. The supplier
implements a strategy to reduce CO2 emissions in order to contribute to MAHLE’scommitments in line with the Paris agreement (e.g., corporate goals for its scope 1, 2and 3 emissions). If prompted by MAHLE, the supplier regularly reports on its
progress, especially with regards to its CO2 footprint at product level.
In case MAHLE sets binding material- and component-specific CO2 targets as part of
the awarding process they are binding during project execution.
2. Protection of Water Resources. The supplier takes action to reduce water
consumption and the generation of wastewater. In addition, measures are taken toprevent the contamination of surface water or groundwater.
3. Circular Economy, and Waste Management. The supplier takes actions to reduce
the environmental impacts of its products and services during their life cycle (i.e.,conception, development, production, transport, use and recycling), and implements
measures to minimize consumption of energy and natural resources. The supplierensures that no waste is disposed of illegally and takes actions to eliminate andminimize waste generation by means of improvement, replacement, reuse andrecycling of materials.
4. Biodiversity. The supplier does not contribute to or benefit from illegal conversion ofnatural ecosystems through its business activities, i.e., preventing illegal deforestationsuch as the conversion of natural forests into usable areas

Page | 4 MAHLE Supplier Code of Conduct, Edition December 2022, ©MAHLE 2022

MAHLE public (CL1)5. Hazardous Materials. The supplier implements processes and procedures to properly
identify, manage, handle, dispose and replace hazardous materials.
6. Recycled Material. The supplier provides MAHLE with information about its use of
secondary materials at product level via IMDS or CDX. The supplier shall increase theuse of recycled material as much as possible.
7. Material Compliance. The supplier respects legislation or regulations applicable in
the production countries and also in the countries/regions where the product or part issold or used (e.g. European Union) in terms of prohibition, restriction, registration,authorization and/or traceability of substances of concern for human health or theenvironment (e.g. REACH, RoHS, ELV, TSCA (Toxic Substances Control Act)).
Substance of very high concern (SVHC) based on the European REACH regulationmust be avoided in products and parts. In order to track and follow-up on substancesof concern and critical materials, Material Data Sheet (MDS) registration is mandatory
via IMDS or CDX in due time for all parts and materials delivered to MAHLE. Pleasefind more information on prohibition and declaration of substances on our website:
https://www.mahle.com/en/purchasing/prohibition-and-declaration-of-substances/.

DUE DILIGENCE & COMPLIANCE MANAGEMENT SYSTEM
The supplier implements and maintains a risk management process to identify, prevent,mitigate, and account for risks and impacts on the environment and people. The supplierperforms due diligence in the areas covered by this Supplier Code of Conduct in accordancewith international standards such as the OECD Due Diligence Guidance for Responsible
Business Conduct and the UN Guiding Principles on Business and Human Rights.
Every supplier is responsible for ensuring that its employees, representatives and agentscomply with this Supplier Code of Conduct in their business dealings with MAHLE. In order toeffectively evaluate and ensure that the supplier maintains compliance at all levels of its
operations, MAHLE expects the supplier to implement a compliance management system thatat a minimum includes the following:
1. Supply Chain. Processes to effectively communicate the principles of this Supplier
Code of Conduct to its suppliers and sub-suppliers and require its supply chain tocomply with the principles of this Supplier Code of Conduct to the best of its ability.
2. Risk Management. Measures to effectively monitor and verify compliance with theSupplier Code of Conduct, including maintaining documentation to demonstrate its
commitment to the Supplier Code of Conduct.
3. Training Programs. Training programs to educate its employees about the principlesof this Supplier Code of Conduct and any applicable laws and regulations referenced
herein.
4. Reporting Channel. If not already existing, the supplier has to implement an internalreporting channel for its employees to ensure that violations of applicable laws andPage | 5 MAHLE Supplier Code of Conduct, Edition December 2022, ©MAHLE 2022

MAHLE public (CL1)regulations can be reported. The supplier has to ensure the protection of the reporterand has to ensure that employees who report a violation do not need to fear any
negative consequences for themselves.
By accepting a purchase order from MAHLE and/or signing the Supplier Code of Conduct, thesupplier acknowledges its acceptance of the Supplier Code of Conduct and agrees to comply
with this Supplier Code of Conduct. MAHLE reserves the right to verify supplier’s compliancewith the provisions of this Supplier Code of Conduct by self-assessment questionnaires. Incase the supplier has received a self-assessment questionnaire from MAHLE or by anorganization commissioned by MAHLE, the supplier is obliged to fill-out and reply such selfassessment questionnaires within the given deadline. If there is a suspicion of non-complianceof the supplier, MAHLE reserves the right to conduct audits at the premises of the supplierduring normal business hours. In the event MAHLE determines the supplier is non-compliant,the supplier shall take immediate corrective actions or MAHLE may terminate the business
relationship.
MAHLE has established a whistleblowing platform where any violations of these requirements
can be reported to MAHLE by any partner in the supply chain. If a violation falls within thesphere of influence of the supplier, the associated risks must be remediated by the supplier
immediately.
The supplier makes its supply chains aware of the available channels for reporting complaints
and ensures that this information is passed on to the deeper levels of the supply chain.

Page | 6 MAHLE Supplier Code of Conduct, Edition December 2022, ©MAHLE 2022

MAHLE public (CL1)