Code of Conduct for Business Partnersof the Jenoptik Group
Business Partner includes sales partners, suppliers and other contractors
Corporate responsibility is a fundamental element ofJenoptik’s commercial success.

1.

Compliance with laws and regulations

The Business Partner warrants that it complies with all
relevant national and international laws in and inconnection with the provision of services for Jenoptik,
and that it takes steps to keep itself regularly informedof any changes to these laws.

In addition to upholding high legal and ethicalstandards when dealing with its own employees,
business partners, and other company stakeholders,
this also includes sustainable management to promote
the company’s social responsibility.

This applies, in particular, to the laws of the country inwhich services are provided and in which the supplierand (if not the same) any end customer has itsregistered office.

Jenoptik expects its sales partners, suppliers and othercontractors (hereinafter "Business Partners") to upholdthe same legal and ethical standards.
This Code of Conduct defines the Jenoptik Group’s
requirements for its Business Partners with regard tocompliance with national and international laws,regulations, and standards.

Jenoptik recognizes that there are differences incultures and legal requirements and, at the same time,expects that regardless of the location of the Business
Partner or the contracting Jenoptik company, allbusiness activities will be managed and structured insuch a way that they comply with the requirements ofthis Code of Conduct for Business Partners.

It applies to all Business Partners of JENOPTIK AG and
its affiliated companies (as defined by Article 15 of theStock Corporation Act (AktG)) (hereinafter “Jenoptik”).
The Business Partner shall undertake to comply withthe following principles.

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Code of Conduct for Business Partners

2.

Observance and guarantee of human rights

3.

The Business Partner warrants that it complies withinternationally recognized human rights standards anddoes not tolerate any infringement of these standards
by third parties.

Prohibition of corruption and bribery

The Business Partner does not tolerate bribery,corruption, or other corrupt conduct. In and inconnection with the provision of services for Jenoptik,
it complies with all relevant national and internationalanti-corruption legislation (e.g. UK Bribery Act, ForeignCorrupt Practices Act).

This applies in particular to the laws on the preventionof forced labor of the country in which the services areprovided and in which the provider (if not the same) or
the end customer is based.

The Business Partner warrants that it has not and will
not provide any unlawful benefits, either directly orindirectly, to managers, employees, or representatives ofJenoptik. The Business Partner further warrants that it
does not offer, promise, or grant unlawful payments,
donations, gifts, or other assets to public officials, otherprivate or public decision-makers, or other business
partners, either directly or indirectly, and does not seek
to exercise any unlawful influence on their decisionmaking.

2.1. Prohibition of forced and child labor
The Business Partner does not tolerate any form offorced labor, slavery, human trafficking, or otherexploitation of employees, or any form of child labor.

2.2. Prohibition of discrimination and unequal
treatment

The Business Partner will also neither demand, accept,
nor tolerate the promise of any unlawful benefits fromthird parties.

The Business Partner does not accept any form of
discrimination, unfavorable, or unequal treatment, forexample based on race, ethnic or national origin, skincolor, gender, religion or belief, political affiliation,
disability, age, marital status, sexual identity, or otherpersonal traits. It respects the privacy and personal
rights of its employees.

4.

Avoidance of conflicts of interest

The Business Partner warrants that it has no personal,
business, or legal conflicts of interest in and inconnection with business decisions regarding Jenoptik.
It will also undertake to provide immediate notificationof potential conflicts of interest (including those of its
employees and agents), in particular those relating topersonal relationships with Jenoptik employees orbusiness partners.

2.3. Assurance of fair working conditions and hours
The Business Partner ensures fair working conditions
and complies with all applicable health and safety
regulations. In particular, it warrants that it complies
with all statutory regulations relating to working hours.

5.

2.4. Assurance of fair pay
The Business Partner ensures fair pay for its personnel.
It warrants that it complies with all statutory minimum
wage provisions applicable in its provision of services
for Jenoptik, including relevant documentation
including ordinances, guidelines and any local
specifications as well as the relevant documentation
and retention obligations.

Fair conduct in the marketplace and faircompetitive practices

Jenoptik expects its Business Partner to engage inmarket and competitive practices that are fair, ethically
responsible, and law-abiding.

5.1. Prohibition of antitrust practices
The Business Partner warrants that it refrains fromantitrust and anticompetitive agreements in and inconnection with the provision of services for Jenoptik,
this to include impermissible price, territorial, marketsharing, and collusive bidding agreements, and that itcomplies with the regulations of the relevant antitrustlaws.

2.5. Respect for freedom of association and right toorganize
The Business Partner warrants that it respects its
employees’ freedom of association and right toorganize in accordance with the relevant laws andprovisions.

2Code of Conduct for Business Partners

5.2. Protection of information

6.2. Assurance of product safety and compliancewith requirements relating to the handling ofsubstances, mixtures, and articles as well as
hazardous waste

The Business Partner ensures the protection ofconfidential information that becomes known to it in
the process of providing services for Jenoptik, as wellas other trade and business secrets, and complies withthe relevant laws relating to the protection of
intellectual property. Confidential information anddocuments may only be used for the purposes agreed
in the respective business relationship and may not bepassed on or otherwise made accessible to thirdparties without authorization.

The supplier undertakes to ensure that all goods andservices it supplies comply with the quality or safety
standards specified by the relevant laws and regulations and will demonstrate this at Jenoptik’s request.
The supplier further undertakes, if applicable, to ensure
careful and responsible handling of substances,mixtures, and articles in and in connection with theprovision of services for Jenoptik in accordance withthe relevant national and international requirements.

The Business Partner also undertakes to comply withthe applicable national and international dataprotection laws.

In particular, the supplier warrants that, if applicable, it
complies with all relevant registration and information
obligations and the restrictions of the REACH Regulation (EC) 1907/2006 for substances and mixtures andprovides a material safety data sheet for substancesand mixtures used. It further undertakes to comply withthe restrictions on the use of certain hazardous
substances in accordance with the RoHS Directive
2011/65/EU in the current valid version.

5.3. Compliance with foreign trade law provisions
If applicable within the scope of providing services for
Jenoptik, the Business Partner warrants that it complies
with all relevant national and international foreign trade
law and customs provisions, such as the relevant laws
on importing and exporting goods, services,technologies, software, and information, and on
embargoes and other sanctions. In particular, it
undertakes to comply with all relevant provisions ofnational and international customs and foreign tradelaw, and provide in good time and in writing all papers,
documents, data, and information required forcompliance of the relevant customs and foreign tradelaws on export, import, and re-export (e.g. officialpermits to be obtained or existing obligations toregister).

6.

The supplier undertakes to comply with the following
environmental agreements in connection with themanufacture of the goods it supplies:- Minamata conventions on mercury;- Basel Convention on the Control ofTransboundary Movements of Hazardous Wastes
and Their Disposal;- Stockholm Agreement on Persistent Organic
Pollutants.

Commitment to the environment

7.

6.1. Protection of the environment and resources

Responsible use of conflict minerals

The supplier must ensure that “conflict minerals” (tin,tantalum, tungsten, and gold) and their derivatives areonly used in supplies to Jenoptik in compliance withthe relevant statutory regulations. It must ensure this,in particular, by means of sufficient transparency andreviews of the supply chain (e.g. OECD due diligence
proof of execution) and demonstrate it to Jenoptik
upon request.

The Business Partner warrants that it complies with all
relevant national and international environmental
protection regulations in and in connection with theprovision of services for Jenoptik and is committed to
the responsible use and procurement of naturalresources. In particular, it ensures the establishment ofan appropriate environmental management system.

3Code of Conduct for Business Partners

8.

In the event of a serious infringement of the principlesof this Code of Conduct for which the Business Partneris responsible, Jenoptik is authorized to demand thereturn of any commissions or discounts granted thathave been used for undue activities. The Business
Partner grants Jenoptik the right and declares its
consent for Jenoptik, should it have reasonablegrounds to believe that the Business Partner has
committed a serious infringement of the above
assurances and obligations, and following priornotification provided within a reasonable period oftime, to inspect the files and documents of the Business
Partner that are directly associated with its services forJenoptik through an auditor and/or lawyer who isbound by professional secrecy. The Business Partner isauthorized and obliged to participate in this audit.

Communication of the principles in this Code of
Conduct to third parties

The Business Partner undertakes to communicate toand bind its employees, legal representatives, agents,and other third parties involved in and in connection
with the provision of services of Jenoptik to theprinciples set out above.
At Jenoptik’s request, it will demonstrate this to Jenoptik
in the event that reasonable grounds to do so exist.

9.

Consequences of infringements

The Business Partner is obliged to notify Jenoptik
without delay if it suspects an infringement of theobligations set out in this Code of Conduct inconnection with the provision of services for Jenoptik
and to support Jenoptik in resolving any such cases. Anysuspicions can be communicated to its contact atJenoptik or employees in Corporate Compliance & Risk
Management. The Business Partner also gives its
employees the opportunity to report infringements inconfidence. In the event of serious infringements of thisCode of Conduct, Jenoptik is authorized, in particular,
to immediately end all contractual relations with thecontracting party and terminate them without notice.
In all cases, the Business Partner is obliged to remedy
any infringements without delay.

All Business Partners of Jenoptik have the opportunity
to confidentially report misconduct and violations of
this Code of Conduct for Business, e.g. potential
violations of human rights or environmental violationsin their own company or at their own sales partners,
suppliers or other contractors, via Jenoptik's
confidential whistleblowing system(https://jenoptik.integrityline.com).

10. Final provisions
This Code of Conduct is subject to the laws in effect at
the registered office of the Jenoptik company
responsible for concluding the contract.

Jenoptik reserves the express right to claim damages
from the Business Partner in the event of an
infringement of this Code of Conduct for which theBusiness Partner is responsible. The Business Partner
exempts Jenoptik from all claims made by third parties
based on infringements of this Code of Conduct for
which the Business Partner is responsible in theprovision of services for Jenoptik.

Dr. Stefan Traeger
Chairman of the Executive Board

Last updated: May 2023

Dr. Prisca Havranek-Kosicek
Chief Financial Officer

Dr. Ralf Kuschnereit
Member of the Executive Board

Contact
JENOPTIK AG · Compliance & Risk Management
Carl-Zeiss-Strasse 1 · 07743 Jena · Germany
P +49 3641 65-2235 · risk-compliance@jenoptik.com

The content of this publication adresses all genders equally. For better readability, the masculine forms are used normally.

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