Codeofconduct

We firmly believe that sustainable and ethical practices generate long-term value for all membersof society. They not only ensure the longevity ofbusinesses but also inspire innovative solutions
that drive progress. Our success is derived fromoperating within a clear value system, adhering tobest-practice principles and standards, and closely
monitoring key environmental, social, and governance indicators.

Dear Colleagues,

LEM Code of Conduct serves as a fundamental
document guiding our responsibilities to society.
It aligns with the principles of the United NationsGlobal Compact (UNGC), global environmental standards, and our core corporate values.

In times of change and uncertainty, it is particularly
important that we are finding a broad consensus on
our values and the way wewant to do business. The
Code of Conduct has been
established at LEM a longtime ago, however, it wastime to revisit, update, andre-enforce it.

Ethics lie at the heart of our corporate culture, and it
is our expectation that all employees and business
partners uphold the standards outlined in our Codeof Conduct, regardless of their location, cultural
background, or position within the company. Should
any employee have doubts about their conduct, orthat of their colleagues or business partners, they
are encouraged to reach out to their manager, theHuman Resources Department, the Legal Department, or the Risk, Control, and Audit Department
for guidance.

I am pleased to introduce the new LEM Code ofConduct, which represents our commitment toupholding the principles of good corporate governance. At LEM, we understand the importance of
responsibly addressing the needs and interestsof our stakeholders, including shareholders, employees, customers, and the wider public. By adhering to robust corporate governance practices, we
can further strengthen trust in our company.

I know I can count on each of you to uphold ourshared values and drive our company forward.

What truly sets us apart is our way of working. LEM
thrives on the expertise, talent, and leadership ofour dedicated teams, who tirelessly strive to deliver the best solutions for our customers. We are
fully aware that our collaborative approach with all
stakeholders distinguishes us from our competitorsand positions us to achieve our ambitious businessobjectives.

Sincerely,Frank Rehfeld
CEOCOMPLIANCE WITH
LAWS AND INTERNAL RULES:
LEM is committed to operating its activities in accordance with the laws and regulations of the countries in which LEM operates and expects its business
partners to do the same. We comply with applicable
export and import restrictions, public authorization
requirements, as well as governing customs and tax
regulations. We do not tolerate violations of any applicable law of the countries in which LEM operates
or violations of this Code of Conduct or any otherinternal rule, guideline, or policy.
BRIBERY AND ANTI-CORRUPTION:
We are committed to making business free from bribery or corruption and expect the same from ourbusiness partners. We do not accept, offer, promise, or authorize any payment or gift or renderingof services with the intent to obtain or retain any
business or improper advantage, or to influence thepolicy or decision of any government, government
official or private organization. Where local laws allow for gifts of nominal or symbolic value, entertainment, or social invitations (depending on local customs), appropriate disclosure should be reported tothe management to maintain good business ethics.
Entertainment is only permissible if the hosting
company representative is also present during theevent.
RESPECT AND FAIRNESS:
When dealing with customers, we act in accordance with fair business, marketing and advertising
practices and take all reasonable steps to ensure
the quality and the reliability of our products. We
demonstrate respect, fairness and honesty with ourcustomers and business partners, and we expect
them to behave in the same way when dealing withus. We select our business partners based on faircriteria such as price, quality, contractual terms, aswell as business integrity.

FAIR COMPETITION AND ANTI-TRUST:
We compete fairly, openly, and independently toprotect our customers and shareholders. We refrain from entering or carrying out anti-competitive
agreements related to: prices fixing, collusive tenders (rigged bids) output restrictions or allocationof markets, customers, suppliers, or territories. We
do not use third parties (including consultants,third-party sales representatives, or industry associations) to assist in or facilitate improper dealings
with competitors.
ENVIRONMENT AND SUSTAINABILITY:
We are committed to contributing to economic,environmental, and social progress with a view toachieving sustainable development. LEM continually seeks to improve corporate environmental performance, at the level of the enterprise and of its
supply chain. We exercise due diligence in relation
to minerals and metals from conflict-affected andhigh-risk areas and in relation to child labor. We expect our business partners to take measures to limit
the environmental impact of their operations, and tomanage resources responsibly.
RESPONSIBLE BUSINESS CONDUCT:
We promote awareness and compliance by ouremployees of the company policies through appropriate communication and training programs.
We carry out risk-based due diligence, throughour enterprise risk management systems, to identify, prevent and mitigate actual and potential adverse impacts on matters covered by this Code ofConduct and account for how these impacts areaddressed. Furthermore, we expect our business
partners, including suppliers and sub-contractors, to apply principles of a responsible businessconduct compatible with this Code of Conduct.
DATA PROTECTION:
We use lawful means to access, collect, use, share,transfer or store the personal information, and use
it solely for legitimate business purposes. Do notcollect, use, access or share personal information
except as necessary for your job and the jobs of
those with whom you share information. We takereasonable measures to ensure the security of data(including personal data) that we process and toprevent unauthorized access.

TRANSPARENCY ANDINVESTOR RELATIONS:The LEM group is listed on the SIX Swiss Stock Exchange. Consequently, we ensure that timely andaccurate information is disclosed on all material
matters regarding the activities, structure, financial situation, performance, ownership, and governance of the company, with due regard of business
confidentiality and regulatory obligations. Sharing
information about LEM’s financial, social or environmental performance, or any other information via apublic statement, through mass media or press inquiries is reserved for the Chairman of the Board,
the Chief Executive Officer, the Chief Financial Officer and certain employees only after approval byappropriate management in accordance with internal policies. Any breach of these rules and regulations can damage our reputation and destroy thetrust and confidence in LEM.

RECORDS / ACCOUNTING PRACTICES:
We apply high quality standards for accounting, financial as well as non-financial information, including environmental and social reporting, where theyexist.
INSIDER TRADING:
Using material non-public information for personal
financial gain, or sharing it with others for their financial gain, is prohibited and potentially illegal. Youshould never use or disclose material non-public
information prior to its official public release. “Material non-public information” about LEM means any
information that a reasonable shareholder would
consider important in making a decision to buy orsell stock, such as yet-to-be-announced financial
or company performance information, mergers oracquisitions, supplier or customer relationships, orchanges in senior executive management.

CONFLICT OF INTEREST:
A conflict of interest occurs when an individual’s
personal interests – family, friendships, financial, or
social factors – may influence his or her judgment,decisions, or actions in the workplace. A conflict ofinterest can create a situation where an employee
acts in his/her own interests instead of the interestsof LEM. You should disclose promptly any personal
interest that might be in conflict with the interestsof LEM or create the appearance of a conflict of interest. We don’t give preferential treatment to any
business partner for private reasons.
COMMUNICATION AND SOCIAL MEDIA:
We use social media responsibly and carefully in a
respectful manner without offensive or demeaning
language. We refrain from using social media during
work hours, except for business purposes. Sincewe are listed on the SIX Swiss Stock Exchange, wedo not disclose confidential information, including
financial, business information, or any intellectualproperty, through social media. We respect competitors, customers or other stakeholders and do notbring LEM into disrepute.
COMPANY ASSETS:
We commit to using LEM’s resources and assets toserve LEM’s best interests and not for external orpersonal interests. If a limited personal use is authorized by LEM, it is only occasionally with minimal
interference with our job, no harm to LEM’s assets
and in accordance with LEM policies. We use theseresources in a responsible way and protect themagainst loss, theft, or misuse.

INTELLECTUAL PROPERTYAND BUSINESS INFORMATION:
We use LEM’s intellectual property and informationin the company’s best interests. All employees havea duty to secure and protect information and intellectual property, and to maintain confidentiality by
only sharing information when appropriate. We arecommitted to protecting information entrusted to us
by our customers and partners and we respect theirintellectual property.

HUMAN RIGHTS:
We support the principles contained within the Universal Declaration of Human Rights, the UN Guiding
Principles on Business and Human Rights, the International Labor Organization (ILO) Conventions, theprinciples of the UN Global Compact and other similar laws and principles. We respect human rights,
and we seek ways to prevent or mitigate adverse
human rights impacts that are directly linked to ourbusiness operations, products and services. We expect our suppliers, contractors, and other business
partners to do the same in those areas where humanrights issues are at stake, such as working hours andconditions, freedom of association, discriminationand equality, child labor, fair wages, compulsory orforced labor and modern slavery.

HEALTH & SAFETY:
We are committed to providing safe and healthy
working conditions to our employees, co-workers
and other contractors and we expect our business
partners to apply the same principles. We takemeasures to ensure health and safety in operations and we commit to protecting our employees
and colleagues against harassment and any kind of
sexual, physical, psychological abuse or threats inthe workplace. Employees must work in a condition
fit to perform their duties, free from any substancethat could impair their judgment or interfere with effective and responsible professional performance.
DISCRIMINATION:
We follow the applicable employment and laborlaws where we do business, including wages andworking hours, immigration, collective bargaining,anti-discrimination, and similar employment rules.
We are guided by the principle of equal opportunity
and treatment in employment. We treat individuals
equally and fairly based on the principle of non-discrimination, with respect and dignity, regardlessof religion, race, age gender, nationality, politicalopinion, sexual orientation, physical challenges, orother characteristics.
EDUCATION AND TRAINING:
We aim at being an attractive working environmentthat opens up opportunities for development andthat encourages new ways of thinking, personal
growth, and continuous learning.
CHILD LABOR:
We adhere to the legal minimum age requirements
in all countries where we operate, and we upholdthe effective abolition of child labor in accordancewith the principles set forth in the ILO conventions.

FORCED LABOR:
We uphold the elimination of all forms of forced orcompulsory labor. We only employ individuals who
are working of their own free will. Any individual isfree to terminate employment with LEM in accordance with the applicable notice requirements andregulation.
RIGHT TO ORGANIZATION:
We respect the right for the employees to join, orform a labor union without fear of reprisal, intimidation or harassment. Accordingly, LEM respects theright to be represented by trade unions and other
employee organizations.
PRIVACY:
We process personal data of our employees and business partners in accordance with applicable laws
and expect our suppliers and business partners todo the same. Our activities at work are not private innature, consequently we may access records andnetworks for monitoring purposes as permitted byapplicable laws.

SPEAK UP:
If you know or suspect a violation of this Code ofConduct or any LEM policy, it is your responsibility
to promptly report it. Usually, your manager is thebest person to address such a concern. Alternatively, you may address concerns to the Human resources Department, the Legal Department or theRisk, Control and Audit Department. Any concern
raised in good faith shall be taken seriously. If you
feel uncomfortable sharing a concern with yourmanagement, we have set up a speak-up processdescribed on MyLEM Legal or on lem.com in thecompliance section.

COMPLIANCE AND DISCIPLINARY MEASURES:
The managers shall ensure that employees under
their supervision understand and comply with thisCode of Conduct and internal policies. Any violationof this Code of Conduct or other internal policies
will be subject to appropriate disciplinary action,
which may include termination of employment.
NO RETALIATION:
We refrain from discriminatory or disciplinary action, adverse employment or career consequences
against persons who make bona fide reports to themanagement, the competent public authorities orto the speak-up hotline, on practices that contravene the law, this Code of Conduct, or our policies.
However, any breach of this Code of Conduct may
lead to disciplinary action and contract termination.
INVESTIGATION:
The Risk, Control and Audit Department is responsible for overseeing internal investigations into
suspected misconduct under this Code and related
policies. You must not interfere in internal investigations or engage in your own fact finding, but you
must cooperate with the Risk, Control and Audit Department. Any investigation and corrective action,
as applicable, will be conducted and enforced incompliance with local laws.

CONTACT:
If you have any questions regarding the Code ofConduct or about compliance, you may contact theHuman Resources Department, the Legal Department or the Risk, Control and Audit Department.