Policy StatementofJoyson Safety Systems
on the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz)

I.

Building a Sustainable Mobility Safety Future

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 Respecting Human Rights and Related Environmental Standards

At Joyson Safety Systems, we are committed to building a more sustainable mobility safety future. We
recognize our environmental and societal responsibilities, including our responsibility to respect humanrights and related 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 dobusiness. To this end, we align our business activities with the f ollowing international standards onresponsible business conduct:
•••••
3.

United Nations (“UN”) International Bill of Rights;
UN Guiding Principles on Business and Human Rights ;International Labor Organization (“ILO”) Declaration on Fundamental Principles and Rights atWork, ILO Tripartite Declaration of Principles Concerning Multinational Enterprises and Social
Policy (MNE Declaration) and ILO Convention 169;
Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational
Enterprises; andTen Principles of the UN Global Compact.
Acting on our Commitment

Our Code of Ethics and Business Conduct (the “Code”), which is supplemented by our Human Rightsand Working Conditions Policy, reiterates our commitment and requires all of our employees globallyto uphold and respect human rights and related environmental standards whenever and wherever wedo business.
Joyson Safety Systems chooses to conduct business with suppliers who share our core values andsense of corporate social responsibility. As set forth in our Supplier Code of Conduct (“Supplier Code”),
we expect and require all of our suppliers to comply with applicable laws and regulations, to respecthuman rights and related environmental standards, and do business ethically. We also require our direct
suppliers to communicate the content of our Supplier Code to their suppliers and to ensure theircompliance with its requirements.
In f urtherance thereof, we have incorporated human rights and environment related due diligence andreporting requirements into Joyson Safety Systems’ existing management systems, including thoserelating to risk management, occupational health and safety, retention of employees and contractors,
environmental protection, supply chain management, and f acility management. Our well-establishedcompliance management system provides protected reporting and complaint channels and procedures
f or the response to any identified potential or actual human rights and related environmental risks orimpacts, as well as a risk management process also covering human rights and related environmentalrisks.
4.

About this Policy Statement

This Policy Statement on the German Supply Chain Due Diligence Act (“SCDDA”) describes our actions
to respect human rights and related environmental standards within our business operations and along
our supply chain. The terminology used in this Policy Statement is intended to align with the definedterms used within the SCDDA.

II.

Implementation of our Human Rights and Environmental Strategy

1.

Managing Risks related to Human Rights and Related Environmental Standards

As a global manufacturing company with complex global supply chains, we recognize that our suppliers
and our business partners’ operations may impact the situation of human beings and the environment
in many ways, which may give rise to human rights and environmental risks.
To identify, assess and appropriately address any such risks, at Joyson Safety Systems, we have taken
steps to understand and analyze where our operations may have a negative impact on human rights
and related environmental standards. To this end, and as required by the SCDDA, Joyson Safety
Systems conducts on an ongoing basis due diligence assessing the potential and actual impact of ourbusiness taking into account among others, the kind, scope and location of our business operations,our products (including components and raw materials used to manuf acture those products), oursupplier base as well as f indings f rom compliance and audit reports.
The assessment of human rights and environmental risks is integrated into Joyson Safety Systems’
business processes and not only covers Joyson Safety Systems’ own business operations, but also its
suppliers starting at their onboarding and continuously thereafter. The risk assessment f ollows ourstandard compliance risk assessment procedures, which govern the identification, analysis, evaluation(including prioritization) and treatment of risks. With respect to human rights and environmental risks,
we analyze whether and to what extent individuals or groups of individuals or the environment may beharmed by Joyson Safety Systems’ business operations and/or through its business relationships withsuppliers, irrespective of whether such risks have an adverse impact on Joyson Saf ety Systems.
Joyson Safety Systems uses a risk-based approach and focuses on those locations where human rights
and environmental risks are most likely to arise. We f ollow a two -step approach:a) Abstract risk analysis of those countries in which Joyson Safety Systems operates based on
publicly available data concerning human rights and environmental risks. Based on the risk
prof ile f or each country, Joyson Saf ety Systems identifies the most relevant risks that mightarise f rom its operations and supplier relationships in those countries.
b) Specific risk analysis is then undertaken, prioritizing the countries, operations and processes
having the highest risk prof ile.
Based on the results of the analysis, Joyson Safety Systems then conducts a gap analysis to determine
whether and how identif ied risks need to be mitigated.

The risk assessment will be performed annually or when necessary on an ad -hoc basis. The outcomeof the risk analysis will be communicated to the relevant management bodies of Joyson Safety Systems
and other relevant stakeholders on a regular and ad -hoc basis.
The responsible body f or establishing and monitoring human rights obligations is the Global
Sustainability Of f ice.
2.

Human Rights and Related Environmental Risks within Our Sphere of Influence

While we strive to prevent causing or contributing to adverse human rights and environmental impacts
in our own operations and through our business relationships, we have identified certain human rights
and related environmental risks that may be relevant to our operations and/or our supply chain:-Child labor;
Forced labor and all f orms of (modern) slavery;
Risks associated with the procurement of conf lict minerals;
Occupational saf ety and work-related health hazards;
Restrictions on f reedom of association and the right to collective bargaining;
Any f orm of discrimination;
Unf air working conditions;Risks to data protection and privacy;
Damage to health, shelter or the economic/natural resources needed for subsistence, e.g.
due to water, soil or air pollution and def orestation;
Restrictions on land rights; andCorruption and bribery.

We believe that in particular our own employees, the employees of our business partners (suppliersand customers) and individuals related to our global supply chain including, e.g., members of local
communities in which we or our suppliers operate, may be impacted.
For instance, our own operations may pose certain risks that primarily relate to the safety and health of
our employees and the environment. Protecting the health and saf ety of individuals as well as caring
f or the environment is a top priority f or us. We also recognize that we are f acing certain human rightsrisks, including maintaining international labor and social standards, especially in higher-risk countries.
Against this background, we have promulgated company policies, including our Code as well as our
Human Right and Working Conditions Policy, and implemented processes to identify and manage any
such risks appropriately.
As we work with many business partners around the globe, including direct and indirect suppliers, risks
may also exist in our supply chain. In certain high-risk countries, we recognized that risks of corrupt
practices, improper labor practices, and deforestation may exist in our supply chain. Theref ore, whenselecting suppliers, we do not only assess their ability to meet their contractual obligations and to satisfy
our and our customers’ business and technical needs and requirements. We must also equally besatisfied of their commitment to compliance with applicable laws safeguarding human rights and related
environmental standards and conducting themselves in a manner consistent with our Code and SupplierCode. We also expect our business partners to have processes in place to prevent, mitigate, and –when relevant – remediate human rights violations. We f urther conduct risk-based periodic due
diligence to identify, prevent, and where necessary remediate potential adverse human rights andrelated environmental impacts. To this end, we utilize various tools to assess supplier risk, including
self -assessment questionnaires and third-party screening platforms. Responsible for conducting thesupplier risk management is our Purchasing Department, which is overseen by the Global Sustainability
Of f ice.

3.

Remedial Action

If we become aware of actual or potential violations of our Code, the Supplier Code, the Human Rights
and Working Conditions Policy or other company policies or procedures, laws or regulations, we willtake immediate action to investigate and correct any such identif ied issues . Should we cause orcontribute to actual human rights violations through our business, we are committed to implementing
ef f ective remedial measures. Where needed, remedial action shall ensure that any non-compliant
conduct ends and recurrence is prevented. If issues are identified at suppliers of Joyson Safety Systems,
we will take necessary action to mitigate any impacts including ensuring that the relevant supplier takes,
and reports about, necessary remedial action without undue delay. If a supplier evidently fails to fulfill
any of the principles or requirements set out in the Supplier Code or ref uses to pursue and implement
measures f or improving its sustainability performance, af ter having been given a reasonable period oftime to remedy any such f ailure, Joyson Safety Systems may take appropriate action including up totermination of the supply relationship .
4.

Complaint Proceedings

We encourage and expect our employees, suppliers, and other stakeholders to report any suspected
breaches of our Code or the Supplier Code, including any suspected violations of human rights andrelated environmental standards and laws and regulations, where Joyson Safety Systems or any of its
representatives or any of our suppliers are believed to be involved. Grievances can be reported throughinternal and publicly available grievance channels described in our Code, the Supplier Code, and theCompliance Channels Reporting Policy, including but not limited to the Joyson Saf ety Systems
Compliance Hotline (go to https://jss-speakup.com). Reports can be f iled by employees, business
partners and any other third parties. Concerns may be raised anonymously wherever permitted by locallaw. Our Compliance Department is responsible f or processing these reports. Notably, any actual orpotential violations within our supply chain can be reported through these reporting channels.
We prohibit all f orms of retaliation against people who report concerns in good faith. Where a reporter
identifies themselves, every effort will be made to keep their identity strictly confidential within thecompany. We respond to complaints in a timely manner, and any report received through the reporting
channels will be reviewed, analyzed, and investigated and acted upon where appropriate.
5.

ReportingOur commitment to respect human rights and the environment is monitored by the Global Sustainability
Of f ice and overseen by the Board of Directors and the Global Sustainability Committee.
The Global Sustainability Of fice reports regularly and on a case-by-case basis to the relevant
management bodies on compliance with human rights, environmental and other obligations under ourCode, company policies and procedures as well as under applicable laws and regulations .
The annual reports of Joyson Safety Systems pursuant to § 10 SCDDA will be published on Joyson
Saf ety Systems’ global website.
6.

Periodic Review and Evaluation

The ef f ectiveness of the strategy and due diligence procedures is reviewed at least once a year and onan ad hoc basis to identify, prevent, eliminate, or mitigate any adverse human rights or environmentalimpacts. Likewise, this Policy Statement is continuously reviewed and revised as necessary.

Aschaf f enburg, 30 April 2024
Joyson Saf ety Systems Germany GmbH
The Managing Directors