Principles for submitting reports, processing reports and protecting
persons making a report(“Principles of reporting”)
1. Principles➢ Sustainable business success at home and abroad is only possible with strict
compliance with the respective legal system. We demand full compliance withapplicable laws, human rights and environmental and social standards from all
employees, the entire management team and all our business partners.
➢ We take reports indicating a violation of legal and/or company regulations very
seriously.
➢ Reporting violations of legal and/or company regulations not only helps to uncoverpossible current violations, but also to prevent future violations and thus avert
damage to WITTENSTEIN.
➢ We provide various reporting channels, both personal and anonymous.
➢ We do not discriminate against anyone who reports violations to the best of theirknowledge and belief.
➢ For details, please refer to our Code of Conduct.

2. Reporting➢ Who?
o Any person who has become aware of a potential violation of legal and/or
company regulations can submit a corresponding report.
o Any person means that both employees and external parties can report apotential violation. External parties may be employees of business partners, forexample, but also completely uninvolved third parties.
➢ What?
o Potential violations of legal and/or company regulations can be reported.
o A suspicion of a potential violation is sufficient for a report.
o Examples of potential violations:▪ Violations of cartel and competition law▪ Matters relating to bribery and corruption▪ Human rights violations▪ Environmental violations▪ Violations relating to money laundering or terrorist financing▪ Violations of product safety and conformity requirements▪ Violations of quality and safety standardso Violations by our business partners in connection with their activities for
WITTENSTEIN, e.g. violations of our Supplier Code of Conduct can also bereported.

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Page 1 of 3➢ How?
o WITTENSTEIN - Reporting System
This reporting system can be used to submit reports 24/7 worldwide in various
languages.
Secure communication with compliance organization is ensured by means of amailbox.
When creating a report, please follow the instructions in the system, which will
guide you through the process step by step.
Persons submitting reports can do so anonymously or can give their name.
o In person
By prior appointment via compliance@wittenstein.deo By phone
Reports can be submitted in German or English on +49 7931 493 18520 during
normal business hours.
In addition, reports can be submitted via our Compliance Officer in the respectivecountry.
o By email
compliance@wittenstein.deo By mailWITTENSTEIN SE, Compliance Officer, Walter-Wittenstein-Straße 1, 97999
Igersheim, Germanyo Anonymously
Anonymous reports can be submitted via the WITTENSTEIN - Reporting System.
Reports can be submitted 24/7 worldwide in various languages, provided this ispermitted by national law.
3. Processing of reports➢ Receipt of a report is confirmed in the reporting channel selected by the person
making the report. The respective time periods are observed, which may vary fromcountry to country. In Germany, confirmation of receipt of a report is issued after
seven days at the latest.
➢ Receipt of a report is documented.
➢ As part of the processing of a report, the validity of the report received is checked inconsultation with the relevant specialist departments. If necessary, questions areasked to the person making the report. Furthermore, depending on the individualcase, appropriate measures are defined and implemented to remedy the reported
violation and to prevent similar cases from occurring in the future.
➢ As long as a violation has not been proven, the presumption of innocence applies.
Incriminating and exonerating facts are equally included in the investigation.
➢ The person making the report will receive a response regarding the current
processing status as well as regarding measures already taken and measures still to
be taken within the legally prescribed period in the various countries, provided that
this does not affect internal inquiries or investigations and provided that this does notaffect the rights of the persons who are the subject of a report or who are named in areport. In Germany, the deadline for a response is three months.

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Page 2 of 3➢ If a violation of legal and/or company regulations is ascertained, this violation will beremedied immediately. Measures will be taken to prevent such violations in the future.

4. Protection of persons making a report➢ Persons who report any violations of legal and/or company regulations to the best of
their knowledge and belief shall not suffer any disadvantages as a result of theirreport.
➢ If the person making a report is put at a disadvantage, this is a violation of the Codeof Conduct of the WITTENSTEIN group and, where applicable, against applicable law
and may be subject of a separate report.
➢ However, a deliberately false report, e.g. in order to unjustifiably arouse suspicion
about colleagues, can lead to negative consequences for the person making thereport.
➢ The information provided by the person making the report will always be treatedconfidentially. The “need to know” principle is observed when processing reports.
However, statutory or official notification obligations must be complied with whenprocessing reports.
➢ Personal data is protected. Details can be found in the Privacy Statement of ourReporting System.

5. External reporting offices
Persons making a report can also contact external reporting offices that are available forthis purpose in the respective country.
In Germany, these include:ooo

External Reporting Office of the German Federal Office of JusticeExternal Reporting Office of the German Federal Cartel Office
Reporting Office of the German Federal Financial Supervisory Authority

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