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Policy Statement

STATEMENT ON RESPECTFOR HUMAN RIGHTS

Version 1.1
Date of effectiveness December 4, 2023
Governance Framework
Schaeffler Gruppe

Policy category: Compliance, Legal, Risk & Corporate Security
Responsible member of the Executive Board: Chief Executive
Officer
Policy Owner: Group Chief Compliance Officer

STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

Table of contents

1

Foreword by the Board of Directors

3

2

Our Commitment to the Respect for Human Rights

3

2.1

Our values and self-commitment3

2.2

Our expectations

3

3

Relevant Human Rights topics and potentially affected groups ofpeople4

3.1

Priority Human Rights Topics in our own Business Area4

3.2

Priority Human Rights topics in our Supply Chains

4

3.3

Potentially affected groups of people

5

4

Our approach to the implementation of Human Rights andenvironment-related due diligence obligations

5

5

Risk Management and Responsibilities

5

6

Risk Analyses

6

7

Prevention

68

Remediation

7

9

Grievance Mechanism

810

Effectiveness Control

811Documenting and Reporting

8

12

About this Policy Statement

9

Glossary

9

Contact

10

Approval

10

Change History

10

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

1
Foreword by the
Board of Directors

Schaeffler1 is a globally operating family business with a strong value base.
Integrity, fairness, and mutual respect when doing business have always been
Schaeffler's top priority and an integral part of our DNA.
For Schaeffler's board of directors, respect for human rights is a fundamental
element of responsible corporate governance. Schaeffler pursues the goal ofadequately meeting human rights and environment related due diligenceobligations and respecting the rights of affected parties. This includes, precluding
and minimizing human rights and environment related risks or preventing,stopping, or repairing the violation of human rights or environment-related
obligations. By creating suitable structures, we want to implement ourrequirements into our own business area and our value chains. To fulfil our
responsibilities and to achieve our goals, we have developed this Human Rights
Statement that particularly complements our Corporate Code of Conduct as wellas our Supplier Code of Conduct. We align our actions with the holistic andstrategic approach to the respect for human rights outlined below.
This Human Rights Statement is key part of Schaeffler's Human Rights Strategy. It
is up to all of us to put the measures of this policy statement, which we haveanchored in our Human Rights Strategy, into practice.
Many thanks for your support!

2
Our Commitment
to the Respect for
Human Rights

2.1 Our values and self-commitment
We are convinced that social responsibility is the basis for long-term
entrepreneurial success. We commit ourselves to respecting human rights along
our value chain and to working towards the implementation of these rights in our
global supply chains.
We commit ourselves to respecting, in particular the following international
standards:••••

United Nations’ international code of human rights
UN Guiding Principles on Business and Human Rights
Internationally recognized standards of the eight core conventions of theInternational Labor Organization (ILO) and
10 Principles of the UN Global Compact.

We commit ourselves to perceiving our responsibility, preventing and identifying
negative impacts of our business activities on human rights as well as stoppingand minimizing them, where possible.
2.2 Our expectations
We expect our employees to respect human rights in their daily work and when
dealing with affected parties. In the same way, we address these expectations toour business partners and therefore expect them to also commit to establishingsuitable due diligence processes and to pass on these expectations to their own
business partners.

1 “Schaeffler” or “Schaeffler Group” means

Schaeffler AG and all companies in which
Schaeffler AG directly or indirectly holds amajority interest. This Human Rights Statement
will be issued by the Board of Directors of
Schaeffler AG as group parent company as well
as by Schaeffler Technologies AG & Co. KG and
Schaeffler Automotive Bühl GmbH & Co. KG,
as controlled group companies.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

3
Relevant Human Rights
topics and potentiallyaffected groups of people

By means of our worldwide risk analyses, we identify human rights andenvironment related risks or violations2 that may arise from our business activitiesor those of our business partners.
We see risks primarily, to varying regional and local extents, in the following
areas:
3.1 Priority Human Rights Topics in our own Business Area
With over 84,000 employees working in more than 100 countries and in a wide
variety of cultural contexts and conditions, we are aware of our special
responsibility towards our employees. Each and every one of us bears great
responsibility when it comes to respecting human rights and protecting theenvironment. In our human rights risk analysis, which we conducted at all our
locations, the following risks were prioritized by individual locations:
Human Rights Topics

Reason for Prioritization

Discrimination3
Increased abstract country
risks, taking into account theexisting preventive measuresthat minimize the occurrenceof violations

Freedom of Association3

Deployment of Security Forces

3.2 Priority Human Rights Topics in our Supply ChainsWe recognize that due to our business activities, human rights risks in the
countries and industries of our direct suppliers cannot generally be ruled out. The
following human rights topics are, depending on the respective product group themost essential on an abstract level:
Human Rights Topics
Health and Safety at Work

Freedom of Association3

Reason for Prioritization
General risks due to complex
supply chains considering
existing preventive measures

The majority of Schaeffler's direct suppliers are highly industrialized. The work
may involve handling hazardous materials, operating heavy machinery and otherpotentially dangerous tasks. Furthermore, the disadvantage of trade union
members or the country-specific suppression of strikes are the focus of our
preventive and remedial measures along the supply chain.

2 Within the meaning of the Act on Corporate Due

Diligence Obligations for the Prevention of Human
Rights Violations in Supply Chains.
3 These terms are explained in the glossary of thisHuman Rights Statement.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
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3.3 Potentially affected groups of people
In our efforts to respect human rights, the focus is on the following groups ofpeople:Our employees at national
and international locations

Employees of our companies
in the direct and indirect
value chain

Other right holders suchas local communities andindigenous people

We recognize that within these groups of people there are in turn marginalizedgroups and rightsholders who are particularly exposed to discrimination due totheir special position in society and in its structures and whose rights are
therefore particularly worthy of protection.

4
Our approach to theimplementation of
Human Rights andenvironment-related due
diligence obligations

For us, respect for human rights is an ongoing commitment which we
continuously develop into a holistic Human Rights Compliance Management
System, depending on changing contextual conditions, type of business activity
and the enterprise’s size and structure. Therefore, we have anchored humanrights-related due diligence processes as an integral part of our organization andin the relationships with our business partners to ensure respect for human rights.
Regarding environmental risks, Schaeffler relies on existing and provenmanagement processes. In this respect, we have therefore not identified any risks
that should be prioritized according to the logic underlying this holistic humanrights risk analysis.

5
Risk Management andResponsibilities

In the context of our Human Rights Compliance Management System, we at
Schaeffler have defined clear responsibilities for the awareness of and adherence
to our human rights and environment-related due diligence processes.4
The Board of Directors takes responsibility for the respect for human rights in theown business area as well as in the value chain. It determines respective
responsibilities within the organization.
The responsibility for the operational implementation of human rights andenvironment-related due diligence obligations, especially the anchoring of thehuman rights strategy in the departments and processes, lies with the respective
nominated department. Responsibility for monitoring risk management has also
been defined.5 To ensure that we can always make informed strategic andoperational decisions, we rely on regular and ad hoc internal reporting on the
results of our risk analysis relevant to human rights as well as information fromour grievance mechanisms and information on the effectiveness of our remedial
and preventive measures.

4 For the future it is aimed at a certification for the

Human Rights Management System according to
IDW PS 980.
5 The Compliance Function is entrusted with thehigher-level management of the due diligenceprocesses and their monitoring. The department
Purchasing Sustainability is responsible for the risk
management in the supplier network. The
department Environment Health & Safety takes
the responsibility for the due diligence processes
in its own business area. Further departments are
involved in the operational implementation of thehuman rights strategy and the corresponding
activities.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

6
Risk Analyses

Within the scope of our due diligence obligations, we focus on topics that havebeen considered as potential risks. By utilizing criteria, such as the expected
severity of a violation and its probability of occurrence, we prioritize them. We
systematically identify and assess the relevant human rights topics and potentiallyaffected groups of people with the help of branch and country risks and with awell-established Human Rights Compliance Management System. The mentioned
risk analyses are performed once a year as well as on an ad hoc6 basis.
As part of the risk analyses, regarding our own business area, we examine thehuman rights-related topics considered significant at our locations. Concrete
human rights-related risks are identified per determined marginalized group with
the involvement of responsible and appropriately qualified employees, theregional risk assessors. The results of the risk analysis lead to a measure plan thatis tested for status of implementation and effectiveness in regular intervals.
For our supply chain, we have systematically expanded our corporate risk andsupplier management with processes and measures for the respect of humanrights. Thereby, we determine the individual risk position of the direct supplier.
Here we take all suppliers into account who have had turnover with Schaeffler inthe past 24 months. We identify risks per procurement or service category andregard the measures and processes for the respect of human rights that the
supplier has already implemented.
In the event that we gain substantiated knowledge of a potential incident
involving indirect business partners, we additionally conduct corresponding
ad hoc risk analyses.

7
Prevention

We derive suitable measures from the conducted risk analyses as well as frompublicly available reports, the grievance mechanism, or audits. With the help of
these measures, affected groups of people shall be protected and adverse humanrights and environment-related impacts and risks shall be avoided, stopped, or
minimized. Especially by taking the following preventive standard measures, weensure the respect for human rights in the own business area and our supply chain:
Due to our Corporate Code of Conduct and associated trainings, we raise thenecessary awareness of respecting the human rights at our locations. This is
supported by internal guidelines such as the Human Rights Compliance Policy(rollout in 2024) as well as a Sustainable Procurement Policy.7
Through our Supplier Code of Conduct, our suppliers accept our ethical and legal
principles. In this context, they confirm that they pass over these requirements intheir value chain, and they agree with the implementation of risk-oriented
preventive measure. We provide all suppliers with training courses free of charge
on human rights-related due diligence obligations. At identified high-risk suppliers,
we conduct structured audits according to the standard of the Responsible Supply
Chain Initiative, in order to derive further, individual measures.

6 We conduct risk analyses in the supply chain and in

the own business area on an ad hoc basis e.g., in
the case of changed country risks, reported
information from the grievance mechanism andpublic reports from authorities and nongovernmental organizations. The same applies tothe introduction of new products, projects, or new
business fields.
7 Within the scope of the risk assessment of our

suppliers, we pursue a zero-tolerance limit. Thatmeans, maintaining a business relationship withidentified high-risk suppliers requires a special
permit or a risk elimination.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

We also take into account, findings from sectoral dialogues or those from our daily
business activities when deriving measures, insofar as they relate to human rights.8
Moreover, we have developed individual measures for the prioritized humanrights topics which we exemplarily list below:•
Freedom of Association9••

Alignment of employer practices with the
ILO-Core Labour Standards, as well as
creation of transparency on local laws andon actual working hours•

Diversity & Inclusion Strategy to promoteequality among our employees
Target ratios for the proportion of female
employees in top management

Health and Safety at Work,particularly Working Hours9

Discrimination9••
Prohibition of Forced Laborand Child Labour9

Cooperation with the respective employee
representative bodies
Individual communication measures at thelocations, with regard to the guarantee of
freedom of association•

Standard agreement of our Supplier Codeof Conduct
Participation of external security personnel
in Supplier Code of Conduct trainings

As part of our self-commitment, we additionally take the following measures.
These are listed below as examples:

•
•
•
•
•
•
•

8
Remediation

Policy against Human Trafficking with therein defined, granular measures
Collectively agreed remuneration regulations or comparable
remuneration systems
Transparency on actual local demand for reasonable maintenance
Various internal guidelines e.g., on Human Resources andEnvironment, Health & Safety (in draft process)Environment, Health & Safety Policy
Conflict Minerals Policy and Critical Raw Materials Policy
Material Compliance Management System

In the event that we, as an enterprise, have directly caused the violation ofhuman rights in the own domestic business area, we will work toward theredesign of our activities or processes, to remedy the violation. In exceptional
cases, we analyze the extent to which a pause in business activities can end theviolation or the concrete risk.
After investigating as per our grievance mechanism, we sanction employee
behavior that is not aligned with human rights. In the case that our businessactivities contribute to actual human rights violations or that we are indirectly
associated with the violations, we will try for an appropriate remediation and aprompt reparation by the responsible authorities. Regarding our business
partners, we reserve reasonable reaction options, from requesting an immediate
violation remediation, to taking legal actions or ultimately terminating thebusiness relationship. In any case, we work towards the reparation of theviolation.

8 For the future, we plan to involve right holders(such as employees and/or local communities)
as well as human rights experts actively andsystematically in regular exchanges, to further
develop our strategy to promote the humanrights.
9 These terms are explained in the glossary of thisHuman Rights Statement.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

9
Grievance Mechanism

An appropriate and effective grievance management allows to effectively prevent,and remedy adverse human rights-related impacts caused by our company andour business activities. Both employees and those affected persons outside thecompany have the opportunity to submit information about potential humanrights violations through the Schaeffler Group's global whistleblower system. We
provide an electronic reporting system in 20 different languages. However,reports can be submitted in all languages and through various channels.
We follow up on all reports submitted and plausible suspicions of potential
human rights violations in accordance with a reporting and investigation processthat is defined in the guideline Whistleblowing System. The confidentiality ofreports and the anonymity of whistleblowers will be respected.

10Effectiveness Control

We review the effectiveness of our measures and processes, including ourgrievance mechanism, regularly and on an ad hoc basis with the help ofeffectiveness criteria that are predefined for individual cases. In the course of themeasure and process design for addressing prioritized human rights topics orconfirmed incidents, we in advance regularly define the objectives which are to beachieved by use of the measures and processes. To review the effectiveness, andwith that the actual achievement of the predefined objectives, we specify key
performance indicators. We ensure the effectiveness control by gathering
information on the definition of key performance indicators and by involving
relevant stakeholders. In the event that measures, or processes turn out to beineffective, we adjust them and adapt the effectiveness logic, where necessary.

11
Documenting andReportingIn our annual Sustainability Report, we inform the public about our human rights
and environment-related due diligence processes and their effectiveness.
Specifically on the topics of forced labour and modern forms of slavery in our
supply chains and in our own business area, we publicize the Schaeffler Modern
Slavery Statement once a year.
Furthermore, as of the financial year 2023, we annually report to the German
Federal Office for Economic Affairs and Export Control. This is based on thecontinuous internal documentation of the fulfilment of our due diligenceobligations.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

12
About thisHuman Rights Statement

We have developed this Human Rights Statement in dialogue with the competentdepartments at Schaeffler, external experts and with the Schaeffler Economic
Committee. The approval of this Human Rights Statement is made by the Board of
Directors. We will review the statement, in accordance with the principles ofcontinuous improvement and further development, annually as well as on an ad
hoc basis and initiate an update if we observe changed human rights-related
situations.
It is not possible to deduce any individual or third-party rights from this policy
statement. The Human Rights Statement has no retroactive effect and enteredinitially into force on June 26,2023. Version 1.1 of this Human Rights Statement isvalid with effect from December 4, 2023.

GlossaryIn the Human Rights Statement, certain established terms were utilized. These are
to be understood as follows:
Working hours: Existence of a human rights-related risk due to a lack of measures
to prevent excessive physical and mental fatigue. An inappropriate workorganization in terms of working hours and rest breaks is exemplarily cited as acause.
Discrimination: Discrimination in employment on the grounds of national andethnic origin, social origin, health status, disability, sexual orientation, age,gender, political opinion, religion and belief or other categories.
Freedom of Association: Right to form and join a trade union as well as guarantee
for trade unions to freely operate which includes e.g., a right to strike and theright to collective bargaining.

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STATEMENT ON RESPECT FOR HUMAN RIGHTS / Version 1.1 / Date of effectiveness December 4, 2023
A downloaded or printed version of this document is not subject to the updating service.

Contact

With regard to the respect for human rights, Schaeffler has set up diverse
contact options. The following channels are available for all affected groupsof people.

For content-related questions as wellas comments on the Human Rights
Statement:

By e-mailhumanrights@schaeffler.com

By postSchaeffler AG
Compliance & Corporate Security
Industriestraße 1–3
91074 Herzogenaurach
Germany

Personal

Group Chief Compliance Officer
Compliance & Corporate Security
Industriestraße 1–3
91074 Herzogenaurach
Germany
compliance@schaeffler.com

For information on violations of the
Schaeffler Human Rights Statement:

Electronic Whistle-BlowingSystemwww.bkms-system.net/schaeffler

By e-mailinvestigations@schaeffler.com

Schaeffler employees can also report the information to all colleagues of theCompliance-Organization and their supervisors.

Approval

Change History

Policy Owner

Group Chief Compliance Officer

ApproverExecutive Board

Version1.1

Approval date

December 4, 2023

Publishing date

December 15, 2023

Date of effectiveness

December 4, 2023

Changes

Minor changes:
Alignment of the commitment to respecthuman rights with the Schaeffler Code of
Conduct
Updates based on the results of the 2023
risk analysis
Minor linguistic amendments

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