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Foreword

Dear associates,“In the long term, an honest and fair approach to doing busi­
ness will always be the most profitable. And the businessworld holds such an approach in much higher esteem thanis generally imagined.” Written by Robert Bosch in 1921,
these words express a belief we still firmly hold today: reli­ability, credibility, responsibility, fairness, and above alllegality are essential components of our business success.
For us on the board of management, for all associates, andfor all the companies that make up the Bosch Group, thisclear commitment is a common bond that transcends
national and cultural differences. Its significance cannot be
overstated. To explain just how significant it is, we have doc­
umented where we stand with respect to legal requirements
and ethical issues in this “Code of Business Conduct.” Itsets out how we act in our day to day business. In conjunc­tion with the Bosch values, it provides a rock-solid founda­tion on which trust can grow – trust that is essential if weare to thrive as a company.

Stefan Hartung
Chairman of the boardof management,
Robert Bosch GmbH

Stefan Grosch

Member of the boardof management,
Robert Bosch GmbH2
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Code of Business Conduct

Introduction
For us as a company, observing the principle of legality andpracticing business responsibly and fairly have always been
paramount. Indeed, they are central Bosch values. Numer­
ous guidelines and directives govern our actions as associ­ates of the Bosch Group. At all times, we familiarize our­selves with them and comply with them. To facilitate thiscompliance, the essential aspects of these company rules
are summarized in simplified form in this Code of BusinessConduct. Should the above-mentioned guidelines and direc­
tives contradict this Code of Business Conduct, or if any
other questions should arise, we contact the complianceorganization or the legal department (C/LS).

If more specific guidelines or central directives exist
for the issues addressed in this Code of BusinessConduct, they must be observed. Specific company
regulations must not contradict the basic principles of
the Code of Business Conduct.

Certain activities may also be governed by laws or rules
from one or more different legal systems. We always comply
with the law that is applicable in each individual case. This
also includes the laws of the country for which a certain
product or service is intended. If we are in doubt, we findout about the prevailing local laws, also by enlisting the sup­port of the relevant regional subsidiary or operating unit. If
this Code of Business Conduct conflicts with local laws, local
laws take precedence. If the situation is unclear, we contact
the compliance organization or the legal department.

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“We comply withthe law and act
responsibly.”

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The principles that guide us

1. Basic principles

Lawful, regulation-compliant, responsible, and fairconduct
We adhere to the principle of legality in all dealings, actions,contracts, and other activities of the Bosch Group. In par­ticular, we do not deceive customers, government agencies,or the public, nor do we collude in such deceit by third par­ties.
Adhering to the principle of legality also includes paymentof applicable taxes and customs duties, compliance withcompetition and antitrust laws, a strict prohibition ofcorruption and money laundering, application of state-ofthe-art technology, procurement of the required official
licenses, compliance with export control laws, and respect
for the legal rights of third parties. This basic principle is not
driven solely by consideration of the grave consequencesof violations and the harm that can be done to the company
as a result of prosecution, fines, and claims for damages.
Instead, we support the principle of strict legality regardlessof whether the Bosch Group benefits from it. Legality andthe Bosch values take precedence over customer requests
and other business interests.
We are responsible for abiding by the laws that apply in
our field of activity and are required to assess our working
environment continuously from the standpoint of legality,
responsibility, and fairness. If we are unsure as to the deci­sion to make from the standpoint of legality, responsibility,and fairness, we contact our supervisor, the complianceorganization, or the legal department.

Regardless of any legal sanctions, a violation of this Codeof Business Conduct will, as a matter of principle, result in
disciplinary action, up to and including termination and theright to assert claims for damages against those involved.
Reporting suspected irregularities
We are expected to report any possible violations of therules embodied in this Code of Business Conduct to oursupervisors. We can also contact the compliance organiza­tion at any time. In this case, there is the option of reporting
our suspicions to the compliance hotline. While this should
preferably be done personally, anonymous reporting is also
possible. Reports will be treated confidentially. In addition,
reports made in good faith will not result in any disadvan­
tage whatsoever for Bosch associates or business partners.
This is also the case if the report is subsequently found to
be unjustified.

Who can we report violations to?
In addition to our supervisors or the department
responsible, we can report violations to thecompliance officer (directly or via the compliancehotline). The compliance officer responsible canbe found on the BGN under “Compliance” (https://
bgn.bosch.com/alias/compliance). This page also
includes a link to the compliance hotline.

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What is the compliance hotline?
The compliance hotline offers us an additional
option for safely and confidentially reporting
possible violations of our compliance principle.
In most countries, reports can also be madeanonymously.
Operated by a specialized service provider, thecompliance hotline is a reporting system that isavailable over the internet to all associates aswell as to people from outside the company. This
worldwide system is available around the clock inmany languages.
Additional information can be found on the BGN
under “Compliance.” Alternatively, go tohttps://www.bkms-system.net/bosch-compliance or
http://www.bosch.com/complianceIf, as supervisors, we receive information about possible
violations by associates or third parties, we contact the
department responsible. We forward legally significant
matters to the department responsible for legal advice.
Reports about possible violations are dealt with immediately
in internal investigations. If the reports are substantiated,
the necessary actions are initiated.
Cooperation with authorities
In its dealings with the authorities, Bosch pursues a coopera­
tive approach. As Bosch associates and supervisors, we fully
cooperate when lawful investigations are conducted by Boschor the authorities. This does not affect legal privilege, the rightto withhold information, and any other procedural rights.
Supervisors’ responsibility
Our responsibility as supervisors is to ensure that there are
no violations of legal regulations or of this Code of Busi­
ness Conduct in our area of responsibility which could havebeen prevented or impeded through appropriate controls.
We ensure that compliance with statutory and internal regu­

lations is continuously and properly monitored in our par­ticular area of responsibility. As supervisors, we also ensurethat our associates are aware that violations of the principleof legality and the Code of Business Conduct are prohibited
and will, as a matter of principle and regardless of the asso­
ciate’s position in the company, result in disciplinary action.
If an associate reports a possible violation to us, we ensurethat no disadvantage whatsoever results for that associatefrom a report made in good faith. This is also the case if thereport is subsequently found to be unsubstantiated.
As supervisors, we act as role models for our associates,
inform them about the rules embodied in this Code ofBusiness Conduct, discuss these rules with them, and –together with the compliance organization and the legal
department − make ourselves available as a contact part­ner. We are the driving force behind the compliance dialogs
we regularly conduct in our departments.
Social responsibility
On our own initiative and in the interest of the company, we
act responsibly, also taking our impact on society and theenvironment into account. When working with others in thecompany and with business partners, we believe our suc­cess depends on fairness. We reject any violation of humanrights (for instance, forced or child labor), also on the partof our business partners. When performing our tasks, we
keep the reputation of the Bosch Group in mind. We abideby the principle of legality and uphold the basic principles of
responsible and fair action.
Conduct with respect to fellow associates
We respect and defend the personal dignity of each individ­
ual. We do not tolerate any discrimination or harassment of
our fellow associates, and encourage diversity.

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“We respect anddefend the dignity ofeach individual.”

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“We act in the bestinterest of Bosch.”

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How we protect relationships based on trust

2. Avoiding conflicts of interest
Secondary employment and shareholdings
We take on secondary employment only with theprior consent of our employer. This consent will be
granted if the secondary employment does not com­
promise any justified interest of the company. As
associates, furthermore, we may only be involved incompetitors, suppliers, or customers after notifying
the company in writing of each individual case inadvance. In the case of shareholdings, this rule does
not apply if the shareholding is less than ten per­cent. We must notify the company in writing before
we engage in business with companies in which we,
our spouse or partner, or close family members
have a shareholding or perform an executive func­tion, provided we can influence the business rela­tionship and there is a potential conflict of interest.

Engaging business partners for private
purposesIf our work means we are immediately involved in
the awarding or settlement of orders, and this gives
rise to a potential conflict of interest, we may only
engage a business partner of Bosch for private pur­poses after obtaining the advance written consent
of the executive management responsible. This does
not apply to generally available goods and services.

What is meant by “generally available
goods and services”?
Goods and services are regarded as
generally available if they are offered to all of
us on the same conditions (price, etc.). Retailgoods are an example. In contrast, a service
for which we obtain a specific estimate is
not generally available. One example is theestimate drawn up by a painter for renovating
our apartment.

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3. Dealing with information
Written documents
All records and reports, whether internal or external, mustbe accurate and truthful. We observe generally applicableaccounting principles, which require that data and otherrecords must always be complete, correct, up-to-date, andsystem-compliant. We may only use confidential company
information to create records, files, and the like if this
immediately serves the interest of Bosch.
Confidentiality
Confidential company information must be kept secret. Thisobligation remains in effect after our employment contractends.
Data protection and information security
In all business processes and in compliance with the appli­
cable statutory requirements, we ensure that privacy is safe­
guarded, personal data is protected, and all business informa­tion is kept secure. Technically and organizationally, andespecially with regard to protection against unauthorizedaccess and loss, we apply an appropriate standard thatreflects the state of the art and takes account of the associ­ated risks.
When developing Bosch products and new business models,
we ensure that the legal requirements governing data protec­
tion and information security are taken into account at an earlystage. In addition to the compliance organization and the legal
department, the primary contact for questions regarding how
to handle data properly is the data security officer.

Insider information
Insider information is information not known to the publicthat could affect the price of stock or other financial instru­
ments (“securities”). If we are party to insider information,
the following principles apply:(1) We do not purchase or sell any securities on the basisof this insider information. This applies regardless ofwhether these transactions are carried out for our own
account, for the account of third parties, or on behalf ofothers.
(2) We do not use our insider information to recommendthat anyone purchase or sell securities, nor do we induce
anyone to do so in any other way.
(3) We treat insider information strictly confidentially. We
never make such information available to third parties; thisalso applies to passwords that allow access to electronicallystored insider information. We only make insider information
available to fellow associates or consultants from outside thecompany if the recipient needs the information to performtheir tasks, and has been sworn to strict confidentiality.

How do I identify insider information?
Examples of insider information include sales figuresthat are not intended for publication, information
about M&A projects, major reorganizations, newappointments to the board of management andsupervisory board prior to their official publication,
conclusion or cancellation of a major contract witha customer or supplier, important legal disputes, ordealings with government agencies.

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“We keep confidential
information secret and handle
sensitive data responsibly.”

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How we shape our business relationships

4. Conduct toward business partners and third parties
Competition and antitrust laws
We observe the rules of fair competition as defined by appli­
cable law. In particular, we are aware that competitors are
not allowed to exchange information or reach agreements on
allocation of territories and customers, prices and compo­
nents of prices, supply relationships and the conditions gov­
erning them, production capacities, and the terms and condi­
tions of bids. The same applies to exchange of information
concerning market strategies and investment strategies. We
are aware that it is prohibited not only to make written agree­ments in this respect, but also to make verbal agreements
and to practice tacit, conscious parallelism (pricing strategies
that occur without actual agreement between the players).
Only in strictly defined exceptional cases do we collaborate
or exchange information relating to research and develop­
ment projects. We do not restrict customers’ and purchas­ers’ freedom to set their own resale prices, and make noattempt to exercise such influence. We comply with theapplicable national regulations governing anti-competitive
clauses in contracts with customers or suppliers. We do not
abuse a dominant market position to impose discriminatory
pricing, to make business deals dependent on the purchaseof other products, or to refuse delivery.
Supplier and customer relationships
The agreements we make with customers and suppliers arecomplete, unambiguous, and documented, including any sub­sequent changes and additions. This also applies to arrange­ments such as bonus payments and cost subsidies for adver­
tising and sales promotion. We comply strictly with the internal
regulations concerning the use of dual control and the segrega­tion of executive and monitoring functions. We select suppliers
solely on competitive merit, after comparing the price, quality,
performance, and suitability of the product or service offered.

Corruption
We do not tolerate corruption in any form. Corrupt behaviorof associates or business partners is liable to prosecution. It
distorts competition, results in financial loss, and harms thecompany’s reputation.

What are the consequences of corruption?*
Corruption results in higher costs for companies,
limiting the funds available for investment, growth,and innovation. It leads to dependency and prevents
sustainable business relationships. Products become
more expensive, and economies grow more slowly
and fail to achieve their full potential. Corruption does
everyone a disservice.
* Based on Transparency International

When it comes to giving gratuities to public officials or peo­
ple in similar positions, we apply extreme restrictions. We
wish to avoid even the appearance of an attempt to gain
influence. We ourselves do not accept gratuities from public
officials. We neither offer nor grant public officials benefits
for carrying out or expediting official acts. We abide by thisregardless of whether we are legally entitled to the official
act, or the public official behaves in a manner that violates
their official duties.

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“Our conduct isbased on fairness
and integrity.”

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Who is considered a public official?
Public officials are above all individuals performing
sovereign tasks. Examples may include civil
servants, judges, employees of official agencies,
professors at public universities, and employees oftesting institutes that perform sovereign tasks.
Employees of publicly owned entities that areorganized under private law and perform public
functions (for instance, public utilities) may also be
considered public officials in certain jurisdictions.

In the course of business, and especially in our dealings
with customers and suppliers, we also refrain from any formof corruption or other unfair attempt to influence businessdecisions. This applies in particular to agreements concern­
ing the brokering, award, delivery, settlement, and payment
of orders. We do not agree to any payments where it can beassumed that they are intended to serve entirely or partiallyas bribes. We oblige agents or other intermediaries that weengage to procure orders or permits neither to pay or toaccept bribes, nor to grant any undue benefits. For viola­tions, our contracts provide for the right to terminate with­out notice.
When it comes to accepting and giving gifts and other gratu­
ities, including invitations, we apply extreme restrictions.
If we allow ourselves to be unfairly influenced by public offi­
cials, customers, suppliers, or other third parties, or our­selves attempt to unfairly influence such individuals, we will
be subject to disciplinary action – regardless of the conse­
quences under criminal law. We report any attempts by pub­lic officials, suppliers, customers, or other third parties to
unfairly influence our decisions to the executive manage­
ment responsible and the compliance officer.

As a Bosch associate, am I allowed to invite
customers to dinner?
We are allowed to invite customers to dinner if it
is related to business and the expense remains
within reasonable limits. For example, a dinner isbusiness-related if it follows a workshop or productpresentation and business or professional subjects
are discussed. A dinner is reasonable if its costdoes not exceed what is customary in the respective
region. If there is any uncertainty, we contact ourcompliance officer.

Personnel rotation in sensitive areas
In sensitive areas such as purchasing and sales, we make pro­vision for regular job rotation as a matter of principle. In manycases, this also serves our further professional development.
Donations
Robert Bosch Stiftung is involved in the fields of interna­
tional relations, healthcare, education, science, and culture.
It is both an operating foundation that pursues its objectives
with its own programs and a grant provider that enables
third parties to develop and implement their projects. By
contrast, operating units of the Bosch Group express theircommitment to civic society by making cash and non-cash
donations to educational, scientific, cultural, and social
causes. The rules governing the award of such donations are
established exclusively by the board of management ofRobert Bosch GmbH or the executive management of theoperating units. When making such donations, we are not
motivated by self-interest, and make a clear distinction
between such donations and sponsoring.

In the case of violations, we take appropriate action, suchas an order embargo or termination of contract.

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“We do not tolerate
any corruption.”

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“We are aware of
our responsibility
to the environmentand society.”

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How we develop and manufacture
What principles apply to the development of
products?
At all times, our actions are guided by the principleof legality and our “Invented for life” ethos. Legality
and the Bosch values take precedence overcustomers’ wishes. When developing and calibrating
functions, Bosch adheres to the following principles:• T he development of functions to detect test cycles
or other tests is not permitted (either on Boschplatforms or on functions or software developed by
Bosch in fulfillment of customers’ wishes).
• Across the entire program map of the product’s
normal operating conditions, calibration must be donein such a way that the contractually agreed
performance is delivered, human life is safeguarded
to the greatest possible extent, and impact on theenvironment and resources is kept to a minimum.
Optimizing products solely to satisfy test cycles is not
permitted.
These principles apply to all Bosch products(including services) in all phases of productdevelopment, and must also be observed during
product monitoring. These principles help us do
justice to our “Invented for Life” ethos. They express
the unconditional primacy of legality.

5. Standards for our products andservices
Outstanding quality is our strength. We deliver safe prod­
ucts of the highest quality and reliability. In this way, we sat­
isfy our customers’ requirements and expectations. Whendeveloping and manufacturing products and providing serv­
ices, we are guided at all times by the principle of legality
and our “Invented for life” ethos. At the very least, our prod­
ucts reflect the state of the art. If putting these require­ments into practice results in a conflict of goals, we bring thisconflict into the open. Any conflicts are resolved in accord­
ance with the principle of legality, the principles of respon­sible and fair business practice, and the other Bosch values.

6. Intellectual property of third parties
The intellectual property of third parties comprises boththe protected commercial rights (such as patents, trade­marks, registered designs) and the copyrighted items (suchas software, image rights) of third parties.
We respect the intellectual property of third parties and, as amatter of principle, may only use it if granted the right to doso. We may only use and distribute third-party know-how that
does not have protected commercial rights or copyright pro­tection if such use and distribution is not prohibited by otherstatutory regulations. If this third-party know-how was pro­vided to us under a confidentiality agreement, it may only be
used and distributed as stipulated by the provisions of that
confidentiality agreement. This particularly includes thirdparty manufacturing drawings as well as individual data,
dimensions, and tolerances obtained from third parties.
We use third-party software – including open-source softwareand firmware – only within the scope allowed by law and incompliance with the respective license conditions.

7. Occupational safety, health, fire
prevention and environmental protection
It is our duty to keep people and the environment fromharm, to minimize our impact on the environment, and touse resources sparingly. Processes, operating facilities, andoperating materials must comply with statutory and internal
occupational safety requirements, as well as with health, fire
prevention, and environmental protection regulations.

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“We speak openly aboutrisks and uncertainties.”
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How we use this code

8. Communication and training
We are informed regularly about current topics relating
to this Code of Business Conduct. We engage in regulardialog on compliance issues and address risks openly.
We regularly receive training on individual subjects.

9. Internal control system
Bosch maintains an internal control system. Within theirarea of responsibility, the executive management of
every operating unit is responsible for compliance withthe rules contained in this Code of Business Conduct aswell as with any additional company rules.
The corporate internal auditing department (C/AU),
including its local units, has an unlimited right torequest information and conduct audits, provided these
do not run contrary to statutory or company regulations.

Note:
The rules contained in this Code of BusinessConduct apply to the employment contracts
between the respective Bosch Group companies
and their associates. They are mandatory
directives. Third parties may not derive any
rights from this Code of Business Conduct.

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Information and contacts

Further information is available atwww.bosch.com/compliance andhttps://bgn.bosch.com/alias/compliance

Robert Bosch GmbH
Compliance Management (C/CM)
Postfach 10 60 50
70049 Stuttgart
Germany
Phone +49 711 811­48643
compliance.management@de.bosch.com
2023-04-01

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