Rules of ProcedureofJoyson Safety Systems
For Complaints Proceedings pursuant to § 8 (2) of the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz)

I.

Doing Business With Integrity

1.

About Joyson Safety Systems

Joyson Safety Systems is a global leader in mobility safety. We are responsible for designing andmanuf acturing some of the world’s most advanced mobility safety components, systems and technology.
Joyson Safety Systems employs about 43,000 employees at 62 locations in 25 countries generating
annual sales exceeding USD 5 billion.
2.

Our Commitment to Ethics and Integrity

At Joyson Safety Systems, we are committed to ethics and integrity in everything we do. Our businessconduct and the conduct of those acting on our behalf must at all times conform to applicable laws andregulations, our internal policies and procedures, as well as ethical business principles. We recognize
our environmental and societal responsibilities, including our responsibility to respect human rights andrelated environmental standards. For us, respecting human rights and related environmental standards
is key to long-term economic success and is considered an integral part of how we do business.
3.

Our Reporting Policy

We believe that these goals are best achieved in an environment that promotes open communication,including open and candid discussion of concerns about compliance with applicable laws andregulations as well as Joyson Safety Systems’ company policies and procedures. Open dialogue anda healthy reporting mechanism helps to identify risks and potential compliance concerns at an earlystage and in doing so protect the company, our employees, and other affected stakeholders. Everyone
at Joyson Saf ety Systems is responsible f or creating and maintaining a work environment thatencourages asking questions or reporting about any legal, regulatory, or business conduct issue. Whenconcerns are reported, we take swift action to evaluate the report and investigate any indication ofcompliance violations. We encourage and expect that employees and business partners will timely
report any actual or suspected violations of applicable laws or regulations or company policies, including
without limitation violations of human rights and related environmental standards, where Joyson Safety
Systems or any of its representatives or any of our suppliers are believed to be involved. To this end, it
is Joyson Safety Systems’ policy to provide an ef fective process f or all employees , business partners
and other third parties to express concerns or report any such actual or potential violations.
We prohibit all f orms of retaliation against people who report concerns in good faith. Where a reporter
identifies themselves, every reasonable effort will be made to keep their identity strictly confidential ona “need-to-know” basis within the company.

II.

Complaint Procedure

1.

Our Reporting System

Joyson Saf ety Systems operates a company-wide, publicly available and generally accessible
complaint and reporting system.
Any actual or potential violation of law or regulations, our Code of Ethics and Business Conduct (the“Code”), our Supplier Code of Conduct (the “Supplier Code”) or other company policies andprocedures, including those related to human rights and related environmental standards, can bereported through internal and publicly available grievance channels described in our Code and ourSupplier Code, including but not limited to the Joyson Safety Systems Compliance Hotline (see below
under Section II.2). Reports can be filed by employees, business partners and any other third parties.
Concerns may be raised anonymously wherever permitted by local law. All reports will be treatedequally whether submitted anonymously or not, and whether received f rom employees, business
partners or third parties (to the extent legally permitted ).
2.

The Joyson Safety Systems Compliance Hotline

Complaints and reports can be submitted through the Joyson Safety Systems Compliance Hotline (the“JSS Compliance Hotline”). The JSS Compliance Hotline is a service run by an independent thirdparty provider of corporate compliance services and is available in many different languages 24 hours
a day, seven days a week.
The JSS Compliance Hotline can be contacted by phone or internet (f or more inf ormation go tohttps://jss-speakup.com). If contacted by phone, trained specialists f rom the independent third -party
provider of corporate compliance services will answer the call, document the concerns, and forward anelectronic case report to our Compliance Department for review. Reports submitted through the webintake of the JSS Compliance Hotline will be directly f orwarded to our Compliance Department forreview.
Reporters may also contact Joyson Saf ety Systems directly and talk to any of our ComplianceDepartment team members or local Compliance Representatives. They can also contact our LegalDepartment, company managers, the Human Resources Department, or the Chief Compliance Officer.
3.

Processing Received Reports

Our Compliance Department is responsible f or processing all complaints and other reports received,regardless of how they were submitted. The Compliance Department reports directly to the ChiefCompliance Of ficer, who reports to the Board of Directors of t he company. Employees of theCompliance Department are subject to a duty of confidentiality, are impartial, and have the necessary
expertise to prof essionally handle complaints and reports.
Within seven days of receipt of a complaint or other report, the reporter will receive an acknowledgementof receipt f rom Joyson Saf ety Systems.
Joyson Safety Systems takes all complaints and other reports seriously. The Compliance Department
reviews each report to clarify whether there is suf ficient inf ormation to process the matter. If needed,
the Compliance Department will reach out to the reporter and other relevant individuals to discuss thef acts and/or request additional inf ormation.
Thereaf ter, the Compliance Department will determine the appropriate next steps, including: (i) whethera f ormal investigation shall be conducted, (ii) if there is need f or other f unctions to be involved in theinvestigation and/or notified of the issue, (iii) if regulatory bodies (authorities) must be inf ormed, (iv)

whether less f ormal measures by relevant functions or departments may suffice, (v) if any preventive
action may need to be implemented while the investigation is conducted, or (vi) whether the case canbe closed without f urther investigation required (e.g., in case of obviously unsubstantiated or frivolous
complaints).
If an internal investigation is conducted by the Compliance Department, the Compliance Department
will develop an investigation plan, conduct the investigation (including, e.g., reviewing relevant
documents and other data and interviewing witnesses and involved persons), and document the resultsof the investigation. The results of the investigation will be summarized in an investigation report. The
results of the investigation will be communicated to relevant stakeholders. Results may include
recommendations f or disciplinary action or other remedial measures, such implementation of newcontrols, policies and procedures, and trainings .
To the extent feasible and legally permissible, Joyson Safety Systems we will inform the reporter in due
course of the measures taken.
4.

Our Investigative Principles

All investigations shall be conducted in accordance with the f ollowing investigative principles :••••••5.

Confidentiality: Maintaining confidentiality is critical to the integrity of our investigations. The
identity of the reporter, the f act that an investigation is underway or is being considered, thesubject matter of it, the process followed, the materials or information gathered, and the resultsof the investigation shall in general be treated confidentially and shared only on a need-to-knowbasis.
Professionalism: All investigations will be conducted in a professional manner. The essence ofprof essionalism is that our investigators act with integrity, f airness, and diligence.
Competence: The quality of an investigation depends largely on the competency of theinvestigator, and f or this reason, only qualif ied personnel shall be assigned to conduct
investigations.
Impartiality: Investigations must be conducted impartially. Impartiality means that everyone getsa f air chance, and that all subjects are investigated in the same manner, with the sameprof essional, objective and impartial treatment. Individuals will not be assigned to conduct orparticipate in investigations if they have a personal interest in the result, may be called upon as
an interviewee or to provide information, or have a close personal or working relationship withthe subject of the investigation.
Objectivity: Investigations must be objective, i.e., f ree of personal opinion and bias. All
inf ormation shall be reviewed and analyzed using the same standards, and the f indings in an
investigation must be based upon f acts.
Timeliness: Investigations need to be carried out promptly. Investigators shall make reasonableef f orts to commence and conclude investigations in a prompt and reasonable timeframe,depending upon the nature of the allegations being investigated, the scope of the investigation,and other f actors bearing on the scope of the investigation.
Our Non-Retaliation Policy

Joyson Safety Systems strictly prohibits and does not tolerate any f orm of retaliation against anyone
who in good faith makes a complaint or report, provides information, or otherwise assists Joyson Safety
Systems in an internal investigation regarding any conduct that the reporter reasonably believes to bein violation of the law or regulations, the Code, the Supplier Code or other company policies orprocedures, including without limitation any violations of human rights or environmental standards byJoyson Saf ety Systems or its suppliers.

Persons should immediately contact the Compliance Department or the JSS Compliance Hotline (go tojss-speakup.com) if they suspect that they or someone else has been retaliated against f or making agood faith complaint, raising a concern, providing information or otherwise assisting in an investigation.
6.

Periodic Review and Evaluation

The ef f ectiveness of the compliance procedure is reviewed at least once a year and, when needed, onan ad hoc basis.
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