CODE OF CONDUCT
February 15, 2023

www.landbell-group.com

Through its core environmental business, the Landbell Group strives to have a positive impact on
the world we live in. This includes our work towards a more Circular Economy, our firm position in
support of the human rights and social rights of workers, our dedication to protect theenvironment, and a strong commitment to good and sound business practices and relations. Within
its sustainability initiative, Landbell gives a central place into business practices and strategies toidentify, measure and address its impact. Through its network and actions, Landbell Group
promotes international standards set by United Nations texts such as UN Guiding Principles on
Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work and theUN Universal Declaration of Human Rights,the International Covenant on Economic, Social andCultural Rights, the International Covenant on Civil and Political Rights, or the UN Rio Declaration onEnvironment and Development, 1992. It also promotes the step by step development of bestpractices and endeavours to lead the way for its stakeholders.

PURPOSEThis code of conduct (“the Code”) contains the rules that are decisive for us in our dealings
with our stakeholders, such as colleagues, authorities, customers or suppliers and thebroader public. It sets out minimum standards that are binding guidelines for all
employees to follow in our everyday work, including senior management teams aroundthe world whose duty is to set a good example. The Code of Conduct increases mutual
understanding and ultimately helps us to be successful on global markets.
The Code also encourages you, as our business partners, to go beyond legal compliancein order to push forward sustainable responsibility as well as business ethics. Landbell
Group may therefore require evidence of, or run controls over, actions you took inpursuing these objectives. Support or questions regarding implementation of the Codemay be raised at anytime at sustainability@landbellgroup.com. If you delegate any of thework you do for us, we also require your next tier suppliers to acknowledge andimplement the Code.
Commitments from the Code may not, in any way be interpreted in a manner that is notcompliant with any applicable law. When the provisions of the Code are stricter than legal
obligations, the Code shall take precedence.

LABOUR PRACTISESThe term “employee” refers to all full-time and part-time employees, managers, senior
managers and members of the Executive Board. Landbell Group is committed to the wellbeing of its employees and of the employees of its business partners, and requires that
all are treated with dignity and respect, with special attention given to those who mostneed it, as for example migrant workers. Harsh or inhumane treatment including mental
or physical violence, sexual harassment or abuse or verbal abuse, of employee as well as
the threat of any such treatment shall be absolutely prohibited. Disciplinary, judiciary
and/or criminal procedures for any breach will be enforced.

2 © Copyright LANDBELL GROUP 2023

Modern Slavery.
Landbell Group employs its employees under fair wages and working conditions. No
employee of any company working directly or indirectly for Landbell Group shall ever use
any involuntary or exploitative prison labor, slavery or trafficking of persons. No threat,force, coercion or penalties may be tolerated nor any restrictions on workers’ freedom ofmovement in and out of the facility. A direct written labour agreement shall be offered
and all its conditions maintained thoughout the employment duration. Payment shall bemade directly to the employees and never to third party agencies or agents, which do nothold a relevant permit from the authorities. At no time should workers be denied accessto their personal identification documents or work permits, if temporarily (and for lawfulreasons) held by the company. No worker shall have to pay for their employment.

Child Labour.
No one below the age of 15 should be made to work, under any circumstances. The only
exception might be students following an internship program, holiday work orapprentices. Moreover, such students/interns/apprentices shall not perform work that is
likely to jeopardize their health or safety, including physically demanding jobs, night shifts
and overtime.

Working Hours.
With respect to employees’ health, working hours are not to exceed the maximum set by
local law. Furthermore, a working week should not be more than 50 hours, except inemergency or unusual situations. Workers shall be allowed at least one day off every
seven days.

Wages and Benefits.
Employees’ wages shall comply with all applicable wage laws, including those relating tominimum wages, overtime compensation and legally mandated benefits. Deductions
from wages as a disciplinary measure shall not be permitted.

Freedom of Association.
The rights of all workers to form and join trade unions of their own choosing, to engage
in peaceful assembly, to go on strike, shall always be respected, as well as the right ofemployees to refrain from such activities.

Non-Discrimination.
In hiring or in employment practices, Landbell Group and its business partners shall neverengage in or tolerate, either in hiring, or in employment practices, discrimination orharassment based on race, color, age, gender, sexual orientation, gender identity andexpression, ethnicity or national origin, disability, pregnancy, religion, political affiliation,
union membership, or any other distinctive moral or physical characteristics.

3 © Copyright LANDBELL GROUP 2023

Concern Raising and whistleblowing
Landbell Group and its business partners ensure employees are able to openly shareconcerns with management regarding working conditions and management practices
through fair and effective grievance processes. Besides, Landbell Group encourages
whistleblowers to speak up and shall guarantee them safety and well-being. Breaches ofprinciples laid down in this Code as well as to any legal or regulatory obligation may bereported through secure whitsleblowing system employees are informed about without
fear of discrimination, reprisal, intimidation, or harassment.

HEALTH AND SAFETY
While circular economy related business is not risk free, it is the responsibility ofemployers to ensure employees’ safety at work and prevent work-related injury andillness. A safe and healthy work environment enhances the quality of services that wedeliver and the well-being of employees. All employee shall be provided with appropriate
workplace health and safety information and training in a language they can understand.

Occupational Safety.
Landbell Group and its business partners avoid or reduce as much as feasible exposure to
health and safety hazards (chemical, electrical, fire, vehicles, fall, etc.) by implementing athorough identification, assessment and mitigation process, which is reviewed regularly.
Where hazards cannot be adequately controlled employees are to be provided withappropriate protective equipment and information. Employee exposure to the hazards ofmachinery or physically demanding tasks, including manual material handling and heavyor repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks
is to be avoided as much as possible. If it is not avoidable, such task shall be identified,evaluated, and controlled to ensure acceptable and minimum health related risks.

Occupational Injury and Illness.
Procedures and systems are to be in place to prevent, manage, track and report
occupational injury and illness, including provisions to encourage worker reporting,classify and record injury and illness cases, provide necessary medical treatment,
investigate cases and implement corrective actions to eliminate their causes, andfacilitate the return of workers to work. Employee exposure to chemical, biological, andphysical agents shall be especially identified, evaluated, and controlled.

Emergency Preparedness.
Potential emergency situations and events are to be identified and assessed, and theirimpact minimized by implementing emergency plans and response and evacuation
procedures, trainings and drills. Emergency drills must be executed at least annually or as
required by local law, whichever is more frequent.

4 © Copyright LANDBELL GROUP 2023

ENVIRONMENT
Landbell Group recognizes the need for all to participate in the preservation of ourenvironment. Minimizing adverse impacts of our activities on the environment andnatural resources is a necessity. It acknowledges that environmental responsibility is anintegral part of delivering circular economy related services, and gives particular attention
to transparence of waste routes and processing. In case of doubt, the precautionary
principle will be followed.

Environmental Permits and Reporting.
Landbell Group requires all business partners to hold all environmental permits as
required by law (e.g. discharge monitoring), approvals, and registrations, to maintainthem, and to abide by all of their provisions, including the reporting of performance andevents to the relevant authorities.

Pollution Prevention and Resource Reduction.
Emissions and discharges of pollutants to water, air, soil, or as waste are to be minimized,
or eliminated, at the source, or by adapting practices or equipment or by other means.
The use of natural resources, including water, energy, fossil fuels, minerals, and virginforest products, is to be reduced as much as possible, and improvement is to be measured
annually.

Hazardous Substances.
Chemicals and other materials posing a hazard to humans or the environment are to beidentified, labeled, and managed to ensure their safe handling, movement, storage, use,recycling or reuse, and disposal. Wherever possible, their use shall be replaced byenvironmentally sound equivalent products.

ETHICS
For Landbell Group, ethical business also covers relations of companies between eachother, with their stakeholders, society, and national or regional authorities. As acompliance company, we regularly gain deep insights into the economic foundations ofother companies. To establish and maintain a high level of business reliability and trust
the highest standards of ethics shall be adhered to. Information and training on theprocesses to implement and reach these standards should be provided to employees in alanguage that they understand and appropriate for their level of responsibility within theorganisation.

5 © Copyright LANDBELL GROUP 2023

Gifts. Anti-Bribery.
Landbell Group expects from its employee and business partners a zero-tolerance policy
for any forms of corruption, extortion,embezzlement and any other form of active or
passive bribery which jeopardise the world of trust, democracy and honesty Landbell
Group wishes to do business in. Actual or attemps to bribe or other acts in view ofobtaining undue or improper advantage will be reported to the relevant authorities. This
prohibition covers promising, offering, authorizing, giving or accepting anything of value
which might make the receiver indebted, either directly or indirectly through a thirdparty, to influence, obtain or retain business, direct business to public officials, business
partners, employees or any other person, or otherwise gain an improper advantage.
Monitoring, record keeping, and enforcement procedures shall be implemented toensure compliance with anti-corruption laws.

Confidentiality.
The security of customer data and the confidentiality of information are of the greatest
importance and it must be ensured that at all times confidential information is protectedagainst access by third parties. Employees who have access to or control of confidential
or proprietary information must take the appropriate and prescribed security precautions
to prevent misuse and disclosure.

Transparency.
All business dealings should be transparently performed and accurately reflected in thefinancial records. Information regarding labor, health and safety, environmental
practices, business activities, structure, financial situation, and performance is to bedisclosed in accordance with applicable regulations and prevailing industry practices.
Falsification of records or misrepresentation of conditions or practices in the supply chain
are unacceptable.

Intellectual Property.
Intellectual property rights are to be respected. Transfer of technology and know-how is
to be done in a manner that protects intellectual property rights.

Privacy.
Personal data is collected, stored, processed, shared and used for lawful purposes only
within the boundaries of the applicable privacy and information security laws. Besides
legal requirements, reasonable privacy expectations of everyone we do business with,including suppliers, customers, consumers, and employees should be considered. If there
is any suspicion that data protection regulations have been infringed, all appropriate
measures shall be taken without delay.

6 © Copyright LANDBELL GROUP 2023

QUALITYCompliance.
Any kind of business with Landbell Group shall be made in full compliance with applicablelaws and customers requirements. This means that business partners are expected tomonitor legal requirements applicable to their business and to set up complianceprogrammes accordingly.

Due Diligence.
Where the support from third party suppliers is required to perform business especiallywhen managing waste, Landbell Group supports the use of adapted due diligenceprocedures to carefully select the supply chain and business partners, including vis-à-vis
rules laid down in this Code.

Awareness on this Code.
We expect you to cascade down to your employees and suppliers the rules in this Codeof Conduct in a clear and intelligible manner and in a language that they can understand.
Trainings for managers and employees shall be set-up and clear communicationorganised. The relevant executive managers and managers should ensure that allemployees are familiar with the current version of the Code of Conduct at all times.

Jan Patrick Schulz, CEOUwe Echteler, COO DACHTim Scholz, CFO

Grant Kinsman, COO
Europe – NA

Christophe Pautrat, COO
Africa Asia LATM

Martin Tobin, CCO

Ulf Halmann, CIO

Andreas Bohnhoff, CPO

Nicola Magaraggia, CFO
ERP

7 © Copyright LANDBELL GROUP 2023

LANDBELL GROUP is an international supplier of service and consulting solutions
for environmental and chemical compliance. Our aim is to reduce the complexityof extended producer responsibility legislation, as well as other product- andpackaging- related requirements for producers and distributors. In everything wedo, we seek to provide our customers with the most competitive solutions interms of service quality, compliance and cost.
At LANDBELL GROUP, we prepare our clients for the uncertainties to come. We
help them unlock the value of the circular economy and strive to be their best
partner on the journey to a more sustainable future.
© 2023 Landbell AG für Rückhol-SystemeLandbell AG für Rückhol-Systeme
Rheinstraße 4L
D-55116 Mainz
Phone: +49 61 31 23 56 52-0

8 © Copyright LANDBELL GROUP 2023