CODE OF CONDUCT
Mai 2024

CODE OF CONDUCT
June 2024

ILLIES Group Code of Conduct1

1 Welcome / Introduction............................................32 Our guiding principles .............................................4
3 Integrity and Reliability ............................................53.1

Integrity towards customers .................................................................................53.2

Integrity towards the company: avoiding conflicts of interest. ..........................53.3

Integrity towards business partners and third parties:
Avoiding abuse of insider information ................................................................63.4

Integrity towards to our business partners:
acknowledgement of the code of conduct ...........................................................63.5

Integrity towards employees .................................................................................64 Fairness and Competition .......................................75 Transparency ............................................................86 Business Practice ....................................................87 Implementation and Communication ...................10

1 ILLIES includes theC. Illies & Co. (GmbH & CO.) KG as well as all associated and subsidiary companies

21Welcome / Introduction“It takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you'll do things differently.”
Warren Buffett

Dear employees, dear business partners,

The success of ILLIES as a worldwide operating trading company is based on the confidence
and trust of its business partner.
Therefore ILLIES is constantly working on a process to ensure the sustainable external reliability of its employees.
Due to a number of prominent cases, the subject “Compliance”2 is very much on the corporate
agenda, and has received significant public attention. Companies have had to suffer significant
damages, both financially and in terms of reputation. Many companies have reacted by implementing processes, introducing tighter controls and communication processes.
ILLIES appreciates this as a positive development. We feel it is wrong to dismiss Complianceas a short-term trend. Rather, we want to continue taking precautions to avoid that such incidents could happen in our company.

Next to the Group Executive Board, you, our employees, have a corresponding responsibility
towards the company group ILLIES as you are close to our business partners, and can put thenecessary measures into action.

In this Code of Conduct you will be made aware of potential conflict situations and risks in yourdaily working life, and requested to act integer.

This Code of Conduct will be brought to the attention of all employees, and is to be considered
as a guideline for appropriate working processes within the ILLIES group.

2 General term for all measures relating to guaranteeing adherence to laws, regulations and other external or internal guidelines.

3This Code of Conduct summarizes existing tools, and provides a framework for the Compliance activities within the ILLIES group. In various areas it is complemented by already existing
directives. Apart from this, our employees are requested to inform and involve their direct superior regarding possibly compliance-related decisions in their daily business practice.
We are asking you to consider these rules as an aid to act according to existing laws andregulations and by doing so to contribute towards the on-going success of the ILLIES Group.

C. Michael Illies

Stephan Hirschfeld

Max Illies

Kristopher Rodenbusch

2Jan RundshagenFrank König

Steffen Trabert

Christoph Peters

Our guiding principles

Our strengths are the engagement, reliability and competence of our employees. We aim
to meet the expectations of our customers and continually strive for the highest level ofachievement. Integrity and sustainability mean much more to us than short-term success.
We are always conscious of our responsibilities towards business partners, employees, andother stakeholders. Our goal is the creation of added value at any time.
In order to reach this goal, we promote innovative technologies and offer a comprehensive
range of services.
As a worldwide operating trading company, ILLIES relies on the trust of all our business
partners and customers to be successful. Our integrity and international reputation as a reliable partner ensure our success and credibility. We therefore expect every employee andbusiness partner of the ILLIES Group to respect national and international laws and regulations.
ILLIES will not tolerate any exceptions under any circumstance and will react to any misconduct with disciplinary actions up to and including dismissal.
In order to avoid any contravention against these guiding principles, ILLIES will support you byoffering respective trainings. These training will ensure that you are able to recognize potential conflicts of interest in time, and to react correctly.
We also expect that you, our colleagues, will report any contravention of the regulations in thisCode of Conduct to your direct superior or the local management.
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Integrity and Reliability

Integrity and reliability are central elements of the success of the ILLIES Group. The ILLIESGroup has grown successfully for more than 160 years because we act in the interest of ourprincipals and customers to meet their expectations. Another important reason for this successstory is the continuous engagement of our employees within the ILLIES Group and the relianceon the loyalty and respect of our business partners. Engagement and reliability towards ourprincipals, customers, business partners, i.e.: our local partners, logistics companies and between the Illies Group Companies all ensure our credibility and our long-term success.

3.1

Integrity towards customers

We are a service provider. Principals and customers of all kind determine the nature and scopeof the services they expect from us. A good business relation with them is the foundation forour success. Therefore we expect you to behave correctly and with respect towards ourbusiness partners.
The trust of our customers in our reliability is of decisive importance for the success of theILLIES Group. We must therefore refrain from any activity which could adversely affectour principals’ and clients’ trust in us. Integrity and sustainability are of much greater importance to us than short-term success. This basic principle has been part of the ILLIES culture
for more than 160 years and will continue to be.

3.2

Integrity towards the company: avoiding conflicts of interest.

ILLIES is aware of your contribution to our success and will support you in your personal andprofessional development. You are expected to always act in the best interest of the company.
This means, in particular, that business decisions are made exclusively in the best interestof the ILLIES Group. Any situation has to be avoided which could lead to conflicts between
the ILLIES Group’s interests and your own personal or financial interest.
Any risk of conflict arising within a business transaction, i.e.: your personal interests are affected, must be reported to your direct superior.

53.3

Integrity towards business partners and third parties: Avoiding abuse of insider
information

You are working with confidential data and support important technology projects, during which
you are exposed to sensitive information about technologies, services or strategies of our business partners and customers. ILLIES expects that you will preserve the confidentiality ofthis information towards uninvolved third parties and do not use this information for personal benefit, or for the benefit of close related persons.3
Confidential paperwork, drawings, models etc., must be protected and kept secured.

3.4Integrity towards our business partners: acknowledgement of the code of conduct

As a condition for a business relationship we expect from our business partners i.e.: localagents, principals or customers, the acknowledgement of this code of conduct and theimplementation of its guidelines.
In particular, we expect our business partners to adhere to the following principles:•Respect the human rights of all employees.

•Reject corruption and improper influence•

Adhere to laws against child labour•

Obey Health and Safety laws in favour of the employees.

•Obey laws and regulations to combat money laundering and the financing of terrorism.

3.5•

Implementation of the regulations of this Code of Conduct within the supply chain.

•Obey all legal requirements and payment of all required taxes and duties.

Integrity towards employees

3 This obligation continues to apply after the end of any employment relationship6This Code of Conduct applies equally to all employees and the Group Executive Board of theILLIES Group. Members of the management team must distinguish themselves through exemplary personal behaviour, reliability, engagement and expertise.
As a worldwide operating trading company we consider ourselves to be open-minded andmulti-faceted. We value the personality of every single employee, and therefore we promote
open communication between staff and superiors. We expect our employees to accept suggestions and constructive criticism, and to regard this as a contribution to the personal development and the development of the ILLIES Group. In addition, we would like to encourage you
to address conflict openly and honestly, in order to find mutually sustainable solutions.
The reputation of ILLLIES doesn’t just depend on our services, but also, in particular, how wework with our business partners, customers and principals. Therefore ILLIES expects that employees handle all internal and external contacts correctly and with appropriate respect.
No employee will suffer discrimination within the ILLIES group. Any contravention of thiswill have disciplinary consequences, as no form of sexual harassment, or other assault or disadvantage due to the misuse of a superior position (power harassment) ethnic origin, gender,
sexual orientation, religion, culture, age or physical disability etc. will be tolerated.
Of course, ILLIES observes the laws against child labour, and respects any other universal
human rights laws.

4Fairness and Competition

ILLIES is committed to fair competition and we compete for the best conditions for our business
partners. We win contracts on the basis of offering better prices, better quality, meeting
deadlines and greater reliability. We refrain from any discussions with competitors or customers which aim to restrict free competition.
As an employee of the ILLIES Group you are not allowed to have any agreements about
competitive factors, prices or restriction of competition. You are not allowed to give any information about product specifications, sales, tenders, profits, margins, costs, distribution methods, or trading terms to suppliers. In addition, you are not allowed to make any dummy tenders
or subdivide customers, markets, regions or product ranges. And you are not allowed to influence re-sell prices.
Employees of the ILLIES Group act internationally. In some regions and cultures, gifts andother favours between business partners may be treated differently as these would be treated7

in Germany. In some circumstances, this could even lead to an illegal action which must beavoided. ILLIES rejects any kind of corruption.
This means that ILLIES employees are not allowed to influence decision makers in anyway. You are not allowed to offer any individual benefits to decision makers of the public or
private sector designed to influence them in favour of our proposals.
ILLIES also obliges its business partners acting on its behalf to refrain from exerting any such
improper influence. Gifts, any kind of entertainment or other favours may only be carried out
on behalf of ILLIES within a culturally and personally appropriate framework.4
Besides, employees of the ILLIES Group are not allowed to accept any benefits which areintended to influence their decisions in favour of certain business partners.
ILLIES is proud of the achievements of innovation of its principals and business partners andis therefore committed to continuously find flexible and creative solutions for them. For thisreason employees of the ILLIES group are not allowed to take part in any kind of industrial
espionage as well as any form of illegal financing. As an employee of the ILLIES Group
you will obey all national and international laws relating to money laundering and financing ofterrorism.

5Transparency

At ILLIES, decisions and transactions are made on the basis of comprehensible informationand processes, documented in a complete and detailed manner according to relevant laws
and internal guidelines. This applies particularly to local “tipsters” and agents. ILLIES wants
all transactions to be transparent and comprehensible, especially because the public
takes a critical and detailed interest in these business practices. This will allow us to handle
any allegation of improper behaviour in an open and honest manner.
All information and data must be handled confidentially. This implies that you are only
allowed collect and process data in line with the relevant data protection regulations.
You are obliged to take technical precautions to ensure that unauthorised persons do not haveaccess to protected data.

6Business Practice

4 Please see the “Guidelines for working with “tipsters” and advisors/consultants and for gifts and entertainment”

8As a worldwide operating trading company, ILLIES acts as an intermediary between producers of innovative, high value technologies and services and the users of these technologies
and services.
In order to fulfil this role as an intermediary efficiently, ILLIES relies on local expertise. We
work closely together with local agents and “tipsters” and develop trustworthy collaboration.
“Tipsters”, agents and consultants form an important link of our added value chain. At the sametime, ILLIES is aware of the risk of abuse in this area, due to known incidents that have occurred in other companies. Therefore ILLIES has set up procedures in order to eliminate
the possibility of abuse in our company, and to minimise the risk of improper businesspractices by our local partners.
ILLIES has implemented a transparent process for dealing with “tipsters” and will continue
to further develop this. This process comprises clear, industrial standard rules for the compensation of “tipsters”, and obliges them to follow business practices with integrity.5
In addition, ILLIES is implementing comprehensible processes for working with local
agents and consultants. These processes commit our local partners to respect and follow
business practices in line with this Code of Conduct, and ensure that this obligation is documented and can be audited.6

5 Please see the “Guidelines for working with “tipsters” and advisors/consultants and for gifts and entertainment” for more infor-

mation6 lease see the “Guidelines for working with “tipsters” and advisors/consultants and for gifts and entertainment” for more infor-

mation9

7Implementation and Communication

The general guidelines in this Code of Conduct are the basic rules for your behaviour and thatof the ILLIES Group and can be regarded as framework for a self-responsible working
environment. The Code of conduct is meant to give you confidence regarding our expectations and challenges.
In order to ensure compliance and further development of the Code of Conduct, corresponding
procedures have been put in place at ILLIES. Employees will be kept up to date with the current
status of the Code (and appropriate training will be carried out).
Any contravention of the Code of Conduct must be reported to your direct superior oryour local management. Any such hints from employees will be treated confidentially.
No employee will suffer from any disadvantage by making a hint.
Customers, suppliers and other business partners can raise issues with the Group Executive
Board at any time and strictly confidentially.
The Code of Conduct will be updated at regular intervals. Employees can suggest improvements to the Code of Conduct. The Group Executive Board will regularly discuss infringements and necessary changes to the Code of Conduct.
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