Policy Statement on the Implementation of the German Supply Chain Due
Diligence Act (“Grundsatzerklärung”, § 6 (2) LkSG)
Sustainability is a central entrepreneurial guiding principle of Heraeus and has long been
incorporated into the principles of the entrepreneurial and social actions of Heraeus. In theHeraeus vision statement for 2025, Heraeus has outlined its ambition to further strengthen
the role of ESG in corporate decisions.
Protection of Human Rights in Supply Chains
The various business segments of the Heraeus Group pursue the goal of aligning their value
chains with due regard to the protection of human rights. In doing so, the Heraeus Group
follows in particular the OECD Due Diligence Guidance for Responsible Supply Chains ofMinerals from Conflict-Affected and High-Risk Areas and the requirements of the German
Supply Chain Due Diligence Act [“Act” or “LkSG”].
For this purpose, irrespective of the Act, all new suppliers, in particular in the areas of preciousmetals trading and recycling of precious metal-containing materials, have been expected tofulfill the requirements of the Heraeus Supplier Code of Conduct for many years now.
Suppliers in the business areas of precious metals trading and recycling of precious metalcontaining materials have been carefully selected and monitored for many years already. TheHeraeus Group procures conflict minerals only from sources that have been certified by anindependent body as safe sources of supply for conflict minerals.
The principles for the selection and monitoring of suppliers, especially suppliers of precious
metal-containing materials or conflict minerals, are laid down in the Heraeus Supply Chain
Due Diligence Policy, which is part of this Statement by reference.
Protection of Human Rights at Heraeus
Since 2007, the Heraeus Code of Conduct has served as a central framework for the diversified
business activities of Heraeus. The Heraeus Code of Conduct is declared binding on allemployees of Heraeus worldwide. Since 2018, the Heraeus Code of Conduct has been
supplemented by the Heraeus Human Rights Policy. In this policy, Heraeus commits to respect
and observe universally recognized human rights. The Heraeus Human Rights Policy is part ofthis Statement by reference.
The Heraeus Human Rights Policy has been implemented through the Heraeus Human Rights
Management System, which was established to ensure that the Heraeus Human Rights Policy
is implemented in practice in the business segments of the Heraeus Group.
Implementation of the German Supply Chain Due Diligence Act
The Heraeus Group (for the purpose of this Policy Statement, Heraeus Group means all
Heraeus legal entities falling within the scope of the Act, which will be herein referred to as“relevant Heraeus company/companies”) has been working on the implementation of the Act
Page 1 von 4since 2021, and essential requirements of this Act are already being fulfilled as a result of thereview and assessment procedures introduced in the past.
Supplier Risk Assessment
Where not already in place, a process for risk analysis and the assessment of suppliers will be
set up, which includes a requirement for a risk-appropriate review by the relevant Heraeus
companies of their suppliers for the risks addressed by the Act. The risk analysis is based on
the evaluation of country and industry risks. For the risk analysis, the relevant Heraeus
companies may also use information which they have requested from their suppliers,
researched themselves or obtained from external sources (commercial KYC and ESG dataproviders).
The focus of the human rights due diligence processes is placed in particular on the following
human rights risks that have been identified by a (preliminary) risk analysis as material risks
for the Heraeus Group:---Risks arising in connection with the purchase of precious metals and with thetreatment of precious metal-containing materials, in particular as a result of unsafe
and unfair working conditions (in particular minimum salary and working hours), soil
degradation, air or water pollution and the use of mercury;
Risks arising in connection with the purchase of chemicals in countries with a risk of
unsafe working conditions or soil degradation or air or water pollution;
Risks arising in connection with the purchase of raw materials from countries with arisk of unsafe working conditions or soil degradation or air or water pollution;
Risks arising in connection with the purchase of materials or products by the relevant
Heraeus companies from suppliers in the awareness that the respective suppliers
might purchase raw materials from countries with a risk of unsafe working conditions,soil degradation or air or water pollution;
Risks arising in connection with the engagement of construction companies by therelevant Heraeus companies in the awareness that the respective construction
companies might use subcontractors with unfair and unsafe working conditions;Risks arising in connection with cleaning services due to unfair working conditions;Risks arising in connection with the disposal of waste as a result of unsafe working
conditions, soil degradation or air or water pollution.

As part of its efforts to respect human rights, the Heraeus Group focuses on the following
groups of persons, as their human rights are potentially threatened by its business activities
along the global supply chain:-Employees of mining companies
Employees of chemical sector companies in countries with higher human rights risks
or environmental risks
Employees of construction companies or companies offering cleaning or waste
disposal services, in particular in countries with higher human rights risks orenvironmental risks
Neighbors of mines or chemical plants
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Based on the risk analysis, the relevant Heraeus companies are required to take appropriate
measures if deemed necessary. Depending on the risk identified, such measures can range
from obtaining confirmations of compliance with the Heraeus Supplier Code of Conduct, totransmitting and evaluating questionnaires, collecting external data, committing the supplierto certain measures, and to on-site supplier audits. Or the relevant Heraeus companies may
even decide not to enter into a business relationship or to terminate an existing business
relationship with certain suppliers. The sample purchase contracts as well as the Supplier Codeof Conduct provide that the suppliers of the relevant Heraeus companies are to commit theirsub-suppliers in a risk-appropriate manner to also comply with the human rights andenvironmental standards laid down in the Heraeus Supplier Code of Conduct.
Risk Assessment in Heraeus’ own area of operations (“eigener Geschäftsbereich“)
In the implementation of the Act, the Heraeus Group expands its own processes andstructures for its own area of operations (“Eigener Geschäftsbereich”). In doing so, theHeraeus Group can build on its existing Compliance Management System to ensure theprotection of human rights and the relevant environmental aspects addressed by the Act. The
expansion of the existing Heraeus Compliance Management System and the implementationof the risk analysis are coordinated in close cooperation between the Responsibility Office,Corporate Human Resources and Corporate EHS.
Based on risk assessment carried out in the past, Heraeus Holding is not aware of any material
human rights risks or environmental risks for employees of the Heraeus Group. Regarding
human rights risks, the relevant Heraeus companies have been and will be required to conduct
an annual human rights risk assessment. For the assessment and mitigation of environmental
risks mentioned under § 2(3) LkSG, in particular risks related to the manufacturing andhandling of chemical substances, the Heraeus Group has established a global framework for
an EHS management system. This framework also provides for countermeasures to be taken
where required.
Implementation of other elements of the Act and Responsibilities
Human rights training courses are part of the compliance training seminars. Employees of theprocurement department have been and will be invited to specific human rights training
courses on human rights risk in the supply chain. The relevant Heraeus companies are required
to report the results of the risk assessment and the implementation of preventive andremedial measures to their top management or their supervisory board. The processes for theimplementation of the Act will be reviewed at least annually by a human rights expert group.
The Heraeus Group already has a Compliance Hotline (“grievance mechanism”) which isavailable to employees and third parties and which will be further improved and expanded in
the course of the implementation of the Act.
The responsibility for the operational implementation of the Act, in particular for the risk
assessment and any adequate measures taken based on such risk assessment, lies with themanaging director of the relevant Heraeus company, who may delegate the responsibility forthe risk assessment to the procurement department (suppliers and supply chain) or thehuman resources department (Heraeus’ own area of operations) which are supported in thePage 3 von 4implementation of the Act by the Global Procurement Department (suppliers and supplychain) or the Global HR department (Heraeus’ own area of operations), respectively, and by
the Responsibility Office (Heraeus Business Solutions GmbH). The Responsibility Officeconsolidates the reports of the relevant Heraeus companies and supports the relevant
Heraeus companies in the reporting on the LkSG. The Responsibility Office is also responsiblefor establishing the grievance mechanism, receiving incoming complaints and supporting therelevant Heraeus companies in taking adequate measures based on the complaints.
The Heraeus Group will report on an ongoing basis on the implementation of the Act, both in
the policy statement required by the Act and in annual reports.

Jan Rinnert
CEO and Chairman of the Board of Managing
Directors of Heraeus Holding GmbH

Hergen Haas
Group General Counsel
Heraeus Holding GmbHPage 4 von 4