#BusinessPartnersCodeOfConduct

CODE OF CONDUCTFOR BUSINESS PARTNERS
OF THE GROB GROUP

#BusinessPartnersCodeOfConduct_2#BusinessPartnersCodeOfConduct

CODE OF CONDUCTFOR BUSINESS PARTNERS
OF THE GROB GROUP

5. WHAT CONDUCT DO WE EXPECT FROM OUR BUSINESSPARTNERS WITH REGARD TO THE ENVIRONMENT?
5.1 International agreements on environmental protection and environmental responsibility
5.2 Reduction of energy consumption and greenhouse gas emissions

1. PREAMBLE

5.3 Economic use of resources and support for recycling
5.4 Biodiversity, wildlife protection and resource-saving land usage
5.5 No environmental consequences harmful to human health

2. SCOPE OF APPLICATION
3. WHAT COMPREHENSIVE MEASURES, PROCESSES AND
REGULATIONS DO WE EXPECT FROM OUR BUSINESS PARTNERS?

5.6 Environmental management system

6. WHAT ARE OUR EXPECTATIONS FOR THE BUSINESSINTEGRITY OF OUR BUSINESS PARTNERS?

3.1 The Code of Conduct and compliance with the law

6.1 Prohibition against corruption

3.2 The Code of Conduct for Business Partners

6.2 Prohibition against money laundering

3.3 Sustainability management

6.3 Prevention of conflicts of interest

3.4 Whistleblower system

6.4 Compliance with import and export provisions and sanctions
6.5 Compliance with statutory and generally accepted ethical standards for free and fair market competition
6.6 Protection of intellectual property and trade secrets

4. WHAT CONDUCT TOWARD EMPLOYEES AND FELLOW HUMAN
BEINGS DO WE EXPECT FROM OUR BUSINESS PARTNERS?
4.1 Prohibition against child labor and the protection of young workers

6.7 Data protection and information security
6.8 Use of artificial intelligence
6.9 Financial responsibility, proper accounting, and disclosure of information

4.2 Prohibition against modern slavery, human trafficking and corporal punishment
4.3 Indigenous peoples
4.4 Occupational health and safety
4.5 Appropriate compensation and observance of statutory working hours

7. HOW DO WE APPLY THE CODE OF CONDUCTFOR BUSINESS PARTNERS?

4.6 Diversity, inclusion and non-discrimination

7.1 The Code of Conduct for Business Partners as an elementary part of an agreement

4.7 No unethical recruitment

7.2 What monitoring instruments can GROB employ?

4.8 Security personnel employment

7.3 What happens in the event of violations by our business partners?

4.9 No support for armed groups

7.4 What happens in the event of violations in our business partners' supply chains?

4.10 Prohibition against unlawful forced eviction

7.5 Reporting misconduct

4.11 Conflict minerals
4.12 Freedom of association and collective bargaining
4.13 Interactions with defenders of human rights

8. CONTACT PARTNERS

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1. PREAMBLE
Dear business partners,
our guiding values – innovation, quality, efficiency and responsibility – are not just buzzwords for us, but
the benchmark for our past and future actions. They are the foundation of all our business activities anddescribe how we want to work with others. Compliance with applicable law in all its business activities
is a matter of course for GROB in this sense. Additionally, we expect our business partners to live up to
their social, ecological and economic responsibilities and to align their business processes accordingly.
This also implies that our business partners monitor and actively promote these basic principles at all
locations and in all activities. GROB relies on close cooperation with its business partners for this. Against
this background, this Code of Conduct for Business Partners ("CoC4BP") forms the basis for trustworthy
cooperation between GROB-WERKE GmbH & Co. KG, including all other production sites belonging to
the GROB Group, as well as service companies abroad ("GROB" or "GROB Group") and its business partners. In our CoC4BP, we not only communicate the GROB Group's foundation of values to our business
partners, which we had already set out in writing in 2018 in the form of a compliance guideline and havedeveloped over the years into an internal Group Code of Conduct ("CoC"), but also the requirements forthe implementation of sustainability standards in international supply chains. We see sustainability as bothrespect for human rights and environmental protections, as well as ethically and legally impeccable business practices and the responsible acquisition of raw materials. In particular, we look to the ten principlesof the UN Global Compact, the UN Guiding Principles on Business and Human Rights, the core labor standards of the International Labor Organization (ILO) and the OECD Guidelines for Multinational Enterprises.
These internationally recognized frameworks provide companies with a framework for action that enables
them to operate sustainably and incorporate human rights concerns into their business activities to therequired extent. If the following sustainability requirements go beyond the requirements of the applicablelaw, these must also be observed. The order of the following provisions has nothing to do with theirimportance. This Code of Conduct for Business Partners is supplemented by the declaration of principles
on the GROB Group's human rights strategy. In it, we refer to the requirements of the Supply Chain Due
Diligence Act, which has been in force in Germany since January 1, 2023, and specifically document ourcommitment to respecting internationally recognized human and environmental rights, our expectationsof our employees and suppliers based on this, and the processes we have established to implement ourhuman rights and environmental due diligence obligations. Like our CoC4BP, this declaration of principles
is also freely accessible on the GROB website https://www.grobgroup.com/unternehmen/compliance/.

Mindelheim, May 1, 2024

Wolfram Weber
Vice Chairman of theBoard & CFO

Christian Grob
Chairman of theSupervisory Board

Florian Grob

GROB attaches great importance to diversity and equality. To improve readability,
we have not used the different language forms for male, female, and diverse (m / f / d).

German Wankmiller
Chairman of theBoard & CEO

Christian Müller
Member of theBoard & CSO

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2. SCOPE OF APPLICATION
The term "business partners" refers to all business
partners of the GROB Group, in particular our suppliers,
service providers, sales representatives, authorized
dealers and consultants, but also our customers andinvestors as well as the media, society, non-governmentalorganizations ("NGOs") and politics. In this context,
the term "employees" always includes all employees,
including management, executives and other persons
who work for or on behalf of our business partners.
The CoC4BP and its requirements apply directly between
GROB and its business partners. However, we expect
our business partners' commitment to ensuring thatthe values and sustainability standards addressed by
our CoC4BP even beyond this business relationship,including all legal requirements, are complied with bytheir business partners and along their own supply
chain in an appropriate and comparable manner.
This CoC4BP replaces the GROB Supplier Sustainability
Standards previously applicable to our business
partners. The CoC4BP applies in its current version available at https://www.grobgroup.com/unternehmen/compliance/. GROB reserves the right to amend the
CoC4BP from time to time. We will inform our business
partners separately of any significant changes.

3. WHAT COMPREHENSIVEMEASURES, PROCESSES AND
REGULATIONS DO WE EXPECT
FROM OUR BUSINESSPARTNERS?

3.1 THE CODE OF CONDUCT ANDCOMPLIANCE WITH THE LAW
An internal Group Code of Conduct is a valuable
tool for establishing fundamental and necessary
rules for conduct in the company and creating avalue-oriented corporate culture. It is the foundationfor ensuring that employees are aware of humanrights, ethical and ecological standards as well as
mandatory legal requirements, and can operate
within these guidelines in their day-to-day work.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You are aware of and comply with both generally binding legislation and the legislation relevant to yourindustry. This also means that you respect the local laws, values and ethical concepts of your respective
location. You are responsible for ensuring that your employees are aware of the key values of your company
and the relevant legal framework, and that they act accordingly. We welcome the implementation of aninternal Code of Conduct with sufficient language coverage appropriate to the size of the company.

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3.2 THE CODE OF CONDUCTFOR BUSINESS PARTNERS
We are certain that long-term entrepreneurial successcannot be achieved without the trust of our own employees, but also not without that of a large number of external
stakeholders such as customers, suppliers, authorities andthe public in our company and our products. Acting withintegrity and responsibility, and mutual respect are just as
important as excellent and future-oriented technologies.

For this reason, we rely on a clear and binding Code of
Conduct in all our business activities that expresses ourvalues. We expect the same things from our business partners that we set out internally in our Code of Conduct,and communicate our expectations in this regard with our
CoC4BP. In particular, we expect our suppliers and subcontractors to share our values and to commit to shaping
their business relationships and supply chains responsibly.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You are familiar with the legal standards for the consideration of human rights and environmental standards
in international supply chains, in particular the UN Guiding Principles on Business and Human Rights andthe contents of the UN Global Compact, as well as with the national and international laws relevant toyou and your business activities, such as those relating to the prevention of corruption, competition andsanctions law and product safety. Based on all these frameworks and binding regulations, you define yourexpectations and requirements for your own business partners, which you usually set out in writing in a
Code of Conduct for Business Partners. We recommend that our business partners use this document tocommunicate clear expectations in the areas of business integrity, human rights and the environment.

3.3 SUSTAINABILITYMANAGEMENTAs an internationally active company, we take responsibility
in making our business practices as sustainable as possible.
Over several generations, we have implemented sustainability
by never focusing solely on maintaining and expanding
economic success, but by also always taking the effects of ourown actions on our employees, on the environment, and on

society into account. Appointing sustainability managers orcomparable persons and establishing appropriate sustainability
management, as well as developing the awareness of employees, particularly in the form of training on the various aspectsof sustainability is crucial to ensure that the constantly growing
human rights, ethical and environmental concerns are properly
taken into account in the business practices of our partners.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You establish a comprehensive sustainability management system that enables you totake sustainability considerations into account in all business decisions. We welcome
the appointment of a sustainability manager or a comparable responsible person
who is in charge of establishing and implementing a sustainability strategy.

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3.4 WHISTLEBLOWER SYSTEM
Setting up a whistleblower system (and - if legally
relevant for you - a complaints procedure within themeaning of the German Supply Chain Due DiligenceAct) allows individuals to report human rights andenvironmental risks, and violations of human rightsrelated or environmental obligations. The same applies topotential violations of business ethics such as corruption,competition law or accounting. Only those aware ofpotential weaknesses in their organization are able
to independently remedy any occurring misconductand optimize processes for the future. With this inmind, it is important to provide every whistleblower
the opportunity to address their concerns as easily as
possible. The protection of whistleblowers is of paramountimportance. A whistleblower must not be disadvantaged
or penalized for information provided in good faith.

	Internet (reports can also be submitted anonymously
here on request): https://sicher-melden.de/whistle/#/mainpage/icm53606/grob_werke_gmbh_co_kg

	E-mail: compliance@grobgroup.com
	
Postal address: Compliance, GROB-WERKE GmbH &Co. KG, Industriestraße 4, 87719 Mindelheim, GermanyT elephone: Dr. Korbinian Feller, +49 (8261) 996-1903;
Dr. Monika Glogger, +49 (8261) 996-1904

We at GROB have also set up a whistleblower system
to facilitate reporting misconduct. This provides a safe
way for all parties involved to express concerns or report(potential) misconduct. GROB takes care to consistently
follow up on all reports received and to take appropriate
action. We would like to encourage every potential
whistleblower to use our whistleblower system.
The GROB whistleblower system can beaccessed in the following manners:

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You are familiar with all relevant legal requirements for the implementation of whistleblower systems
for your company and consistently implement the resulting obligations. You communicate yourwhistleblowing system and the GROB whistleblowing system to your employees and along yoursupply chain. You guarantee easy access to your system, for example via a barrier-free online solution
and sufficient language coverage that reflects your company's business activities. Even if there is nolegal obligation for your company to set up a whistleblowing system, you are committed to a cultureof openly addressing faults within your organization and make your employees aware of existing
whistleblowing systems of your business partners, in particular the GROB whistleblowing system.

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4. WHAT CONDUCT TOWARD
EMPLOYEES AND FELLOWHUMAN BEINGS DO WE EXPECT
FROM OUR BUSINESSPARTNERS?
GROB is committed to fully respecting and promoting human rights in accordance with internationally recognized
standards. We expect this not only of ourselves, but also of our business partners. We therefore ask our business
partners to join us in this commitment and to incorporate internationally recognized human rights principles intheir business practices. We expect our business partners to be familiar with the relevant national and international
regulations on the protection of human rights and to be aware of the resulting obligations for companies.

4.2 PROHIBITION AGAINSTMODERN SLAVERY,
4.1 PROHIBITION AGAINSTHUMAN TRAFFICKING AND

CHILD LABOR AND

CORPORAL PUNISHMENT

THE PROTECTION OF
YOUNG WORKERS
We reject child labor in any form. Thisapplies to both our own activities and to the­supply chain of our business partners.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You are required to implement the legal provisions for the protection of young workers and the minimum age
for employees in accordance with the standards of the International Labor Organization (ILO) in your company
and to ensure that the working conditions promote the health, safety and development of young people.

We condemn modern slavery, debt bondage, humantrafficking and any form of corporal punishment. The
dignity and privacy of employees must be respected. This
also applies to practices that interfere with the privacy of
individuals and the right to sexual self-determination.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You ensure for your company, but also for your supply chain, that no form of forced labor, bonded
labor, slavery or human trafficking is associated with your activities. We expect you to implement
appropriate policies and measures to ensure that these principles are adhered to in your company
and that a respectful and safe working environment is guaranteed. In the event of infringements
and documented violations, you will respond with a clear response and, if necessary, sanctions.

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4.3 INDIGENOUS PEOPLES
We recognize the rights of indigenous peoples
and respect their cultural identity, land rights
and opportunities for participation. Our business
partners are required to consider and protect therights of local communities in their activities.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You will comply with the UN Declaration on the Rights of Indigenous Peoples (UNDRIP) if
and to the extent that your business activities affect the interests of local communities. We
expect you to exercise particular caution when planning new production sites, for example,
if these could be built in a region where indigenous peoples are known to live.

4.4 OCCUPATIONALHEALTH AND SAFETY
Ensuring a safe and healthy working environment for the
benefit of all employees is fundamental to sustainablebusiness management. Basic working conditions,
including access to clean sanitary facilities and adequate
break rooms, must be ensured. The dignity and privacyof employees must be respected. Occupational healthand safety and fire safety measures must be implemented
effectively. Evacuation plans and training are mandatory
to ensure the safety of all employees in the event of an
emergency. Occupational health and safety measures
must not be associated with costs for employees.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
As an employer, we expect you to actively promote a safe and healthy working environment
for your employees, at the least within the framework of applicable national regulations,and to encourage continuous development to improve working conditions. In particular, youtake suitable protective measures for your employees to avoid exposure to chemical, physicalor biological substances. Furthermore, you ensure that your employees receive all necessary
instructions so that they can carry out the tasks assigned to them safely and correctly.
We recommend that our business partners set up an occupational health and safety management
system, including certification if necessary (e.g., in accordance with ISO 45001). For companies
with more than 1,000 employees, we usually require appropriate certification. In any case,
GROB will give preference to suppliers who actively operate an occupational health and safety
management system, thereby expressing their commitment to occupational health and safety.

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4.5 APPROPRIATE COMPENSATION AND OBSERVANCE OF
STATUTORY WORKING HOURS

of equal opportunities. This includes ensuring thatwages are always paid directly, in full and on time.
Working hours must comply with legal requirements
and must not be excessive. Employees have theright to appropriate rest periods and time off.

The payment of fair, living wages is of central importancefor the creation of stable labor relations and the promotion

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
In your role as an employer, you undertake to pay fair and appropriate wages, at least at the levelstipulated by local law (minimum wage) and to comply with statutory provisions on working hours andrest periods. At locations where there is no statutory minimum wage, you must at least comply with thestandards of the International Labor Organization (ILO). You also promote compliance with international
standards on working hours and wages along your supply chain, especially with your suppliers.

4.6 DIVERSITY, INCLUSION
AND NON-DISCRIMINATION
We are committed to diversity and condemn any form of
discrimination, be it on the basis of national or ethnic origin,skin color, social background, marital status, health status,
disability, sexual orientation, age, gender, political opinion,

religion or ideology. For us, unequal treatment in thiscontext also includes, in particular, the payment of unequal
remuneration for work of equal value. We always strive topromote the strategic value of diversity and work to ensurethat our workforce reflects the diversity of our global society.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
In your role as an employer, you are committed to taking active measures to promote diversity,
equality and inclusion within your workforce and to prevent discriminatory behavior and bullying
among employees. This includes implementing awareness-raising programs, training and corporate
culture initiatives to create a diverse and inclusive working environment. Secondly, you ensure thatyour employees are not discriminated against or otherwise disadvantaged on the basis of nationalor ethnic origin, skin color, age, gender, sexual orientation, disability, religion, political affiliation,
trade union membership, origin or marital status, both in the context of recruitment procedures
and applications and in everyday working life in connection with promotions, other benefits,
access to training, work assignments, wages, social benefits, termination or retirement. Finally, ­­we
also encourage you to committedly support these standards within your own supply chain.

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4.7 NO UNETHICALRECRUITMENT

as, for example, practices such as the publicationof false and unobjective job advertisements that
deliberately falsify the requirements and conditionsof the job with the intent to deceive job seekers.

We reject any form of unethical recruitment,
including misleading practices and exploitation ofjob seekers. Unethical recruitment is understood

4.9 NO SUPPORT FOR
ARMED GROUPS

groups, whether in the form of financial means,resources or other assistance. This includes any
actions that could contribute to the promotion ofviolence, conflict or human rights violations.

Beyond the appropriate deployment of security
forces to protect the company premises, we reject
any form of direct or indirect support for armed

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?

In your role as an employer, you adhere to ethical standards when recruiting labor.
You ensure that potential employees are not misled about the nature and scopeof the work and that no fees are charged for taking up employment.

You do not provide direct or indirect support to armed groups, organized crime or terrorist
organizations. You clearly reject any cooperation with parties that violate human rights standards.

4.8 SECURITY PERSONNELEMPLOYMENT

with internationally recognized human rights
standards. We reject any form of intimidation,
including the inappropriate use of force or torture.

The hiring and deployment of security personnel toprotect company premises must be in accordance

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
As part of your business activities, you ensure that security forces, in particular factory security,
are aware of and respect human rights standards. You ensure that the employees andpersons responsible do not use disproportionate force, even in extreme situations, and that
discrimination is prevented. We welcome the provision of needs-based training courses.

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4.10 PROHIBITION AGAINSTUNLAWFUL FORCED EVICTION
We respect the ban on unlawful forced evictions and theseizure of land, forests and waters in connection withthe acquisition, development or other use of land, forests
and waters.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You undertake to not carry out, support or tolerate any unlawfulforced evictions as part of your business activities.

4.11 CONFLICT MINERALSAs part of our business activities, it is important to us
that all minerals and raw materials, including tungsten,tantalum, gold, silver, tin, cobalt, rare earths and ores
such as coltan, do not originate from civil war or conflictregions and are not extracted in an exploitative manner.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You are familiar with the internationally recognized standards of the OECD Guidelines for Responsible
Supply Chains of Mineral Companies from Conflict-Affected or High-Risk Areas. You take all thenecessary steps to ensure that your supply chains are free of conflict minerals. At our request, youare prepared to provide appropriate certificates of origin for the minerals and raw materials used.

4.12 FREEDOM OF ASSOCIATION

4.13 INTERACTIONS WITH

AND COLLECTIVE BARGAINING

DEFENDERS OF HUMAN RIGHTS

Freedom of association and the right of employees tostrike are fully respected. This also means that no measures
are taken to actively prevent the formation of trade unions
and employee representatives. The formation, joining
and membership of a trade union must also not be used
as a reason for unjustified discrimination or retaliation.
Instead, fair collective bargaining must be made possible.

We firmly reject any form of threat, intimidation or
discrimination against people who actively campaign forthe observance of human rights (human rights activists).

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You respect the freedom of association and the right to strike of your employees andare committed to an environment of fair collective bargaining and social dialogue.
In the event of national legal restrictions on these rights, you endeavor to findalternative, legally permissible opportunities for participation and involvement.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You ensure that people who campaign for human rights at your company's production sites,or criticize the situation in your company are not threatened or discriminated against. You
do not permit employees to act "on their own initiative" in suppressing critical voices inorder to prevent damage to their company's reputation or the exposure of grievances. You
ensure that people who wish to exercise their right to express their opinions have access toyour whistleblowing channels and can use them free from the threat of retaliation.

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5. WHAT CONDUCT DO WE
EXPECT FROM OUR BUSINESSPARTNERS WITH REGARD TO
THE ENVIRONMENT?
In addition to our clear commitment to respecting human rights, our commitment to sustainablebusiness practices also includes treating nature and its resources with respect. This understanding
characterizes not only our own actions, but also our cooperation with our business partners.

5.1 INTERNATIONAL AGREEMENTS ON ENVIRONMENTAL

Convention (mercury) and the Stockholm Convention(POPs Convention) in order to ensure the highest
standards in environmental and human rights issues.

PROTECTION AND ENVIRONMENTAL RESPONSIBILITY
As part of our environmental responsibility, we
not only rely on self-regulation, but also demandcompliance with all relevant national environmental
legislation and international regulations such as theBasel Convention on the Transboundary Movement ofHazardous Wastes and their Disposal, the Minamata

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You are obligated to ensure that your company's activities comply with national andinternational legal requirements relating to the environment and sustainability. The
precautionary principle is taken into account in your actions. This also includes checking
your supply chains in an appropriate manner to ensure that your suppliers comply with theserequirements and take appropriate measures to counteract potential or actual violations.

5.2 REDUCTION OF ENERGYCONSUMPTION AND
GREENHOUSE GAS EMISSIONS

these endeavors. With responsible energy consumption
and the continuous promotion of the development of­energy-efficient products and production processes, we
set not only economic standards, but also ecological ones.

We not only work on reducing the greenhouse gases
we emit ourselves, but also expect our business partners to make an appropriate contribution in the context
of this global challenge. Concrete measures to reducegreenhouse gases must be an integral part of ourshared commitment to a future worth living. Energy
savings, the expansion of renewable energies and measures to increase energy efficiency are cornerstones of

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We are in favor of including climate targets in our business strategy, which ideally should include a concept
for achieving climate neutrality in accordance with the Paris Climate Agreement, at least by 2050. In
addition to the reporting of climate-relevant key figures in accordance with legal requirements, we focus
on continuous improvement of the respective data basis with our business partners and communicationof information on total energy consumption and CO2 emissions at the product level. In this manner, youmake a valuable contribution to ensuring that GROB can also continuously improve its key CO2 figures.

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5.3 ECONOMIC USE OFRESOURCES AND SUPPORTFOR RECYCLING

our responsible use of these vital elements and make anessential contribution to sustainable resource management.
In addition to economic use, we also focus on clear
recycling measures and preventing or reducing waste.

The economic use of water and other natural resources
such as air and soil is a primary goal of our environmental
efforts. By using these resources efficiently, we demonstrate

5.4 BIODIVERSITY, WILDLIFEPROTECTION AND RESOURCESAVING LAND USAGE
The preservation of biodiversity and the support for animal
welfare are just as important to us as environmentallyfriendly land use and a deforestation-free supply chain.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?

We expect our business partners to have individualized company guidelines that explicitly
address the responsible use of resources and are aimed at reducing the impact on water, airand soil quality to the absolute minimum. We also value a transparent strategy for reducing
resource consumption, which includes recycling as well as other sustainable practices and isgeared towards taking environmental concerns into account. This includes, among other things,
the continuous development of environmentally friendly packaging for your products.

For you as a business partner, this means that in your business activities, for example
when selecting or expanding production sites within the framework of the applicable law,
you take into account possible effects on local biodiversity and animal welfare as well as
resource-conserving land use, and that you avoid deforestation wherever possible.

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5.5 NO ENVIRONMENTALCONSEQUENCES HARMFULTO HUMAN HEALTH

not cause any harmful soil changes, water pollution, air
pollution, noise emissions or excessive water consumptionthat could lead to a significant impairment of the natural
basis for food and drinking water or human health.

In this context, we also take sustainable corporate
management to mean that operational activities must

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
For you as a business partner, this means that, with the help of targeted measures and established processes,
you prevent impairment of the natural basis for food and drinking water and prevent health risks to people.

5.6 ENVIRONMENTAL
MANAGEMENT SYSTEMManagement systems help with compliance withthe diverse and constantly updated regulatory
requirements in the field of environmental law.
Certifications in accordance with international standards
and norms ensure transparency and reliability.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We expect our business partners to align their existing processes in this area on the basis of the
globally recognized ISO 14001 (environmental management) and ISO 50001 (energy management)
standards as well as corresponding industry standards, and to continuously work on improving theirperformance in this area. For companies with more than 1,000 employees, we usually require appropriate
certification. In any case, GROB will give preference to suppliers who actively operate appropriate
management systems, thereby demonstrating their commitment to environmental protection.

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6. WHAT ARE OUREXPECTATIONS FOR THE
BUSINESS INTEGRITY OF
OUR BUSINESS PARTNERS?
The cornerstones of our business relationships are based on the highest ethical standards, setting our clear
stance against any form of dishonesty and illegal practices. A comprehensive understanding of and strict
compliance with all relevant laws and regulations are essential for us. Compliance is not just a legal obligation,
but a central component of our corporate responsibility, and everyone has a contribution to make.

6.1 PROHIBITION AGAINSTCORRUPTION
There is no place for any form of corruption in ourbusiness relationships. Bribery, undue advantage
or other corrupt behavior is unacceptable and iscontrary to our core values as well as a number ofnational and international regulations and laws.
Our clear stance is not just a legal obligation,
but a cornerstone of our corporate culture.

6.2 PROHIBITION AGAINSTMONEY LAUNDERINGWe also pursue a zero-tolerance policy withregard to money laundering and the financing
of terrorism. Implementing control mechanisms
is essential to ensure that business practices
are not used to conceal illegal activities.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
You undertake to take a strict stance against all forms of corruption, for example by incorporating clear
guidelines on corruption prevention in your own Code of Conduct and corresponding internal processes, e.g.,
for onboarding business partners before entering into business relationships. We expect our business partners
to carry out regular risk analyses that help to identify potential weaknesses and take appropriate measures toprevent cases of corruption. We also presume that employees of our business partners receive an appropriate
level of training to be able to detect relevant corruption risks and to be able to make legally sound decisions.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We require that you review your customer relationships with regard to money laundering risks inaccordance with current standards. This includes implementing effective approval processes to ensurethat financial transactions are appropriately monitored and suspicious activities are detected promptly.

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6.3 PREVENTION OF
CONFLICTS OF INTEREST
The prevention of conflicts of interest is anotherimportant building block for stable and resilient business
relationships. For this reason, personal relationships andprivate interests must not influence business decisions.
Potential conflict situations can arise in particular whenfinancial, personal or family relationships exist with asupplier, customer or business partner. To prevent therisk of inappropriate influence from arising in the firstplace, established processes are needed to identify,
disclose and resolve potential conflict situations, aswell as ongoing awareness efforts for employees.

6.4 COMPLIANCE WITH
IMPORT AND EXPORTPROVISIONS AND SANCTIONS
Compliance with all relevant import and export
regulations as well as national and international customs
regulations is essential for all globally active companies.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?

We expect you to address potential conflicts of interest directly when working with us, but also withother partners. We recommend that you include the topic of conflicts of interest in the Code of Conductand other company guidelines and effectively monitor compliance with these requirements.

As our business partner, you undertake to comply with all legal regulations and requirements
relating to international trade. In this context, we in particular expect of you the implementationof a thorough risk evaluation of all business relationships and orders. This includes a careful
examination prior to the conclusion of contracts, but also of ongoing business relationships,
to ensure that there are no violations of applicable import and export regulations.

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6.5 COMPLIANCE WITHSTATUTORY AND GENERALLYACCEPTED ETHICALSTANDARDS FOR FREE AND
FAIR MARKET COMPETITION
We promote fair and open competition. This includes theconsistent rejection by all market participants of practices
that can hinder, manipulate or distort competition. All rulesof competition and antitrust law must be complied with.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
As our business partner, you are committed to fair competition in all your business relationships. In
particular, this means that you will not enter into any price agreements or divide up territories with othereconomic players - be they competitors, customers or suppliers - and that you will make your decisions
without exchanging sensitive, competition-relevant information. If your company has a dominant market
position in an area, do not exploit this position in a way that violates antitrust law, for example bydiscriminating against other companies or hindering their competitive opportunities. With the help of
suitable training concepts, you create the basis for ensuring that your employees are sufficiently awareof the situations and issues of competition law relevant to them, that they know the legal framework
conditions and ethical standards in this area, and that they can also implement these in practice.

6.6 PROTECTION OF
INTELLECTUAL PROPERTY

of plagiarism in the business world. The same strict
standard of care applies to the handling of businesssecrets of business partners and third parties.

AND TRADE SECRETS

Contractual and legal provisions must be complied with.

Respect for and protection of intellectual property is
the basis of a trusting working relationship. For thisreason, there is no room for the acquisition and use

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We expect our business partners to respect the intellectual property rights of GROB andtheir other business partners, and to protect the relevant data and information fromunauthorized use. This also includes checking and ensuring that there are no infringementsof patents, copyrights, trademarks or other intellectual property rights.

#BusinessPartnersCodeOfConduct_36

6.7 DATA PROTECTION AND
INFORMATION SECURITY

of current or former employees, business partners and otherdata subjects whose personal data is collected and processedin connection with business activities, on the other hand toensure the functionality and security of business processes.

Data protection and information security are fundamental toan increasingly digitalized day-to-day business - on the one
hand to protect the right to informational self-determination

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We require that our business partners collect, process, secure and delete all personal data with the greatest
possible care in accordance with the applicable national and international regulations, in particular the
General Data Protection Regulation (GDPR), and protect it from unauthorized access. Data breaches relating
to GROB detected by our business partners must be reported to GROB immediately (datenschutz@grob.de).
We also expect our business partners to secure their IT systems against internal and external
attacks in accordance with current standards and legal requirements and to comply withboth contractual and statutory information and reporting obligations. All security-relevant
events affecting GROB must be reported to GROB immediately (security@grob.de).

6.8 USE OFARTIFICIAL INTELLIGENCE
The increased use of artificial intelligence ("AI") offers
great potential for all sectors of the economy. However,
it is also the responsibility of companies to be awareof the legal implications and possible consequences
associated with the use of AI in the business environ-ment and, building on this, to create clear framework
conditions for the legally secure, transparent andethical use of AI for their own employees, but also inthe context of their business partners, and to adapt
these to the constantly evolving circumstances.

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We call on our business partners to use suitable processes and measures to ensure that the AI
applications used comply with ethical standards and do not violate legal regulations.

6.9 FINANCIAL RESPONSIBILITY,
PROPER ACCOUNTING, ANDaccounting principles. Information is provided transparently,
accurately, on an ongoing and timely basis and communicated in accordance with applicable laws and other guidelines.

DISCLOSURE OF INFORMATION
Financial responsibility is based on legally compliant and complete accounting, and continues in the transparent publicationof financial results in accordance with generally recognized

WHAT DOES THIS MEAN FOR YOU,OUR BUSINESS PARTNER?
We expect our business partners to keep complete, legally compliant and transparent accounts. Each business partner is responsible for ensuring that all financial transactions and reports comply with existing regulations and international standards.

#BusinessPartnersCodeOfConduct_40

7. HOW DO WE APPLY THE
CODE OF CONDUCT FOR
BUSINESS PARTNERS?
Transparency and fairness are core values of our business relationships. We strive to communicate clearly
and openly with our business partners to establish a partnership based on trust and understanding.

7.3 WHAT HAPPENS IN THE EVENT OF VIOLATIONSBY OUR BUSINESS PARTNERS?
We take decisive action in the event of violations of our CoC4BP. This can range from immediate corrective
measures to contract cancellation and compensation for damages incurred, depending on the severity of theviolation. Further details on this are set out in the individual contractual provisions between GROB and the business
partner or in the General Terms and Conditions. We expect our partners to work together with us to avoid possible
violations to the best of their knowledge and belief and to remedy any occurring violations immediately.

7.1 THE CODE OF CONDUCT FOR BUSINESS PARTNERS
AS AN ELEMENTARY PART OF AN AGREEMENT
This CoC4BP is an integral part of all contracts and GROB's General Terms and Conditions. Irrespectiveof this, it is the fundamental basis of any cooperation between GROB and its business partners,
regardless of whether the business relationship for GROB is on the purchasing or sales side.
The business partner accepts that compliance with the CoC4BP is an essential
prerequisite for GROB for any type of business relationship.

7.2 WHAT MONITORING INSTRUMENTS CAN GROB EMPLOY?
In order to ensure that our business partners fulfil our ethical standards, GROB reserves the right toconduct audits. These audits serve not only to ensure compliance with our CoC4BP, but the continuous
improvement of our cooperation. Further details on this are set out in the individual contractual
provisions between GROB and the business partner or in the General Terms and Conditions.

7.4 WHAT HAPPENS IN THE EVENT OF VIOLATIONSIN OUR BUSINESS PARTNERS' SUPPLY CHAINS?
GROB requires that its business partners also endeavor to comply with human rights and environmental due
diligence obligations and ethical standards within their supply chain. In the event of violations within this
supply chain, we require our direct business partners to take immediate action to remedy and rectify theirregularities. In the event of repeated or serious violations, such circumstances may also lead to a review and,in exceptional cases, to the termination of the business relationship with our direct business partner.

7.5 REPORTING MISCONDUCTWe encourage all employees, business partners and other stakeholders to report misconduct.
GROB is committed to fostering a culture of open communication where all concerns aretaken seriously. All reports are treated confidentially and investigated thoroughly.
With the belief that integrity and compliance are the cornerstones of a successful and sustainable business
relationship, we thank our business partners for their co-operation and commitment. Together, we are committed
to the highest standards and create a business environment based on trust, respect and responsibility.

#BusinessPartnersCodeOfConduct_42

8. CONTACT PERSONSSTANDARDS

If you have any questions about this document and its application, please contact the Legal & Compliance organizational unit of the GROB Group:

Korbinian.Feller@grob.de

GROB Mindelheim
Dr. Monika Glogger
Attorney (in-house attorney)
Compliance Officer
GROB-WERKE GmbH & Co. KG
Monika.Glogger@grob.de

GROB USA
Julia Benziger
Corporate Counsel
Compliance Officer
GROB Systems Inc.
JBenziger@grobsystems.com

GROB China
Helen Wang
Corporate Counsel / Compliance Officer
GROB Machine Tools (China) Co., Ltd.
Helen.Wang@grob.com.cn

GROB Brasilien
Marco Schäfer
Compliance Officer B.
GROB do Brasil S.A.
Marco.Schaefer@grob.com.br

GROB Italien
Elisa Morero
Compliance Officer
GROB Italy S.r.l.
Elisa.Morero@grobgroup.com

Dr. Korbinian Feller
General Counsel
Head of Compliance

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SYSTEMCOMPLIANCE
ORGANIZATIONDATA PROTECTION

POLICIES &PROCESSINSTRUCTIONS© GROB-WERKE GmbH & Co. KG · 05 / 2024 / EN

www.grobgroup.com

GROB-WERKE GmbH & Co. KG
Pioneers in designing and building highly innovative
production and automation systems for almost 100 years.
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