DOING THE RIGHT THING.

Code of Conduct for the ZEISS Groupzeiss.com/compliance2 | ZEISS Code of Conduct

Not only what we do, but also the “how” is of great
importance – for each of us and the reputation of ourcompany. We do the right thing! #teamZEISSContent | 3

Content
4 Foreword
6 About the ZEISS Code of Conduct

01

02

03

The right behavior:
Our principles

The right behavior
in business activities

The right way tohandle information

The right behavior
in the workplace

The right behavior
in case of doubt

10 Fair behavior

16 Competition and antitrust law

24 Data privacy

12 Environmental and climate
protection, energy efficiency,
sustainability

18 Avoiding conflicts of interest,
secondary activities

26 Protection of trade secrets,
and information security

30 Occupational healthand safety

35 Reporting Complianceviolations
36 Internal contact points

19 Fighting corruption

27 Ban on insider trading

32		Handling company
property

13 Product safety and quality

20 Adherence to export controls
and customs regulations
21 Correct bookkeeping andaccounting, anti-money laundering

0405

38 Special responsibilities
of supervisors

4 | ZEISS Code of Conduct

Internalize and live ourCode of Conduct.
We set a good example!
Management Boardof the ZEISS Group

Andreas Pecher

Dr. Markus Weber

Stefan Müller

Dr. Karl Lamprecht

Susan-Stefanie Breitkopf

Sven Hermann

Dr. Jochen Peter

Foreword | 5

Dear employees,
Dear business partners,

We thank you for
deciding to do theright thing every day

ZEISS is a company dedicated to delivering optimum performance andmeeting the highest demands, not only with our technology, but also in
our Compliance with the “rules” of good and fair behavior in competition
and when dealing with dealing with one another. As a Management
Board team, we attach great importance to a corporate culture in which
we treat our employees, customers, and business partners with honestyin our dealings and courtesy and respect in our cooperation.
It is our firm conviction that sustainable economic success is inextricably
linked to Compliance with laws and internal rules. The ZEISS Code of
Conduct creates a common understanding of what “doing the rightthing” means to us. It is our guideline for responsible business conduct.
In most cases, we at ZEISS already make the right decisions intuitively.
Every now and then, however, we may find ourselves in situations where
the “right decision“ cannot be completely clearly distinguished from a“wrong decision”. Inadvertently or even deliberately taking the wrong
path can have far-reaching negative consequences for our company andfor you personally, result in high fines and cause lasting damage to thereputation of ZEISS. ­­Therefore, an important appeal to you: Use the ZEISS Code of Conduct
and, if in doubt, better ask once too often than not often enough! If you
have any questions about Compliance-related topics, you can contact
your supervisor or our Compliance organization in confidence.
We all at ZEISS must always act responsibly, with no exceptions, andmust adhere to mandatory legal and operational requirements.
As a Management Board team, we thank you for deciding to do theright thing every day.
Management Board of the ZEISS Group
Dr. Karl Lamprecht | Susan-Stefanie Breitkopf | Sven Hermann
Stefan Müller | Andreas Pecher | Dr. Jochen Peter | Dr. Markus Weber6 | ZEISS Code of Conduct

About the ZEISS Code of Conduct

Everyone at ZEISS
must know the rules
and act accordingly

Our Code of Conduct applies to all employees andsupervisors at ZEISS. Supervisors have an importantrole model function in this: they set a good example
and promote our Compliance culture.
Everyone at ZEISS must comply with laws and internal
rules. We also encourage our business partners tomake sustained efforts to comply with applicablelaws and regulations, including, for example, dataprotection, human and environmental rights, and ourapproach to energy-efficient behavior.

Employees can findpractical examples of
topics from the ZEISS Codeof Conduct here.

The Code of Conduct does not intend to explicitly
reference all legal regulations which apply to ourbusiness conduct. Instead, it explicitly addresses thosesubject areas which are essential for the sustained
success of ZEISS. Accordingly, all employees are
expected to comply with laws and internal rules evenin those cases that are not explicitly listed in this Codeof Conduct.

This Code of Conduct fully complies with therequirements of the “Responsible Business Alliance
Code of Conduct“ (RBA). In addition, ZEISS supports
the “UN Guiding Principles on Business and Human
Rights” (UNGP) in Business and the rights set out in the“International Bill of Human Rights”. The “core labour
standards of the International Labour Organization”(ILO) are also of particular importance to ZEISS.
When in doubt, ask for advice and point out­possible Compliance violations
Laws and internal policies can be complex, are subject
to change and often vary from country to country.
For this reason, the Compliance organization at ZEISS
offers a global network of contact persons who provide
comprehensive advice and information.
All employees are requested to report violations of laws
and internal rules. This also applies if violations havebeen committed by business partners in connection
with their activities for ZEISS.
Consequences of non-compliance with the Code of
Conduct
Our Code of Conduct forms the basis of our actions
and is non-negotiable. Violations of the law andinternal policies can lead to significant damage forthe company (e.g., in the form of fines or through lossof reputation) and may result in criminal or labor law
consequences for affected employees.

About the ZEISS Code of Conduct | 7

We behave fairly,
respectfully, andcommunicate
transparently.
We are not ­alone and canseek advice
at any time.

DOING
THE RIGHT
THING.

For us, doing the right thing means that
all employees at ZEISS are responsible foraligning their actions with applicable laws
and internal rules.

We address
misconduct
openly andreport ­violations­immediately.

We are law-abiding
and adhere to theCode of Conduct
without exceptions.

We support eachother in doing theright thing.

8 | ZEISS Code of Conduct

The right behavior:

Our principles

In this chapter:»

Fair behavior»

Environmental and climate protection,energy efficiency, sustainability»

Product safety and quality

The right behavior: Our principles | 9

I am proud to be part of #teamZEISS. There are manyreasons for this – it is particularly important to me that
we treat each other with respect and fairness.
Treating colleagues as well as customers, suppliers
and other business partners in an unbiased, polite
and appreciative manner must be the linchpin of ourcorporate culture.
Lazgin Sis
Representative for persons with disabilities,
Carl Zeiss AG (Oberkochen, Germany)10 | ZEISS Code of Conduct

Fair behavior

We promote fair working
conditions and expect
reliable and respectful
behavior from our employees
and business partners

Our employees and business partners (customers, sales partners,
and suppliers) are the focus of our activities. Respective relationships
shall be marked by mutual appreciation and reliability.
We expect honesty in our actions as well as courtesy, respect, andfairness in our dealings with each other.
We offer fair working conditions and comply with the statutory
provisions for the protection of employees as well as collective
or company agreements and contractually stipulated regulations ­­(e.g., on remuneration, working hours, free choice of employment
and freedom of association).

We respecthuman rights

We reject any form of child or forced labor, slavery or human trafficking
and we support an appropriate living minimum wage. Humane­­­
treatment in the workplace is a foundational principle of ZEISS.

We create anappreciative
corporate culture

We prohibit any kind of discrimination in our organization basedon ethnic or social origin, nationality, skin color, gender or gender
identity, sexual orientation, marital status, age, religion, world view,political, social or trade union affiliation or other characteristics
protected by law. In addition, we do not tolerate any behavior that
qualifies as harassment or bullying.

This is what we expect from you:

The aspiration of ZEISS:» Conduct yourself in a courteous,respectful, and fair manner wheninteracting with each other.

» We stand up for fair working
conditions and human rights,
in our company and among ­­ourbusiness partners.

» Do not discriminate against
anyone for any reason.
» When possible, speak directlywith people who may not be­aware of the impact of theiractions.

» We respect human rights by,among other things, neither­committing nor contributing
to slavery or other forms of­oppression, forced labor or
human trafficking.

» Respect cultural differences.
» Make and communicate decisions
transparently and comprehensibly.

More information:» ZEISS group policy statement on respecting
and promoting human rights

The right behavior: Our principles | 11

12 | ZEISS Code of Conduct

Environmental and climate protection,energy efficiency, sustainability
We are committed to environmental and climate
protection and the economical use of resources

Compliance with high environmental standards
was already a corporate objective in the statutesof the Carl Zeiss Foundation. The careful use ofresources (including energy and water), continuous
improvement of environmental performance andongoing improvement of energy efficiency are central
factors in our business activities.
What is important to us and how do we implement it:
In our business activities, we strive for CO₂ neutrality(Scope 1 and 2 emissions*). Our approach: avoid,
reduce, and offset.
Careful handling of the environment, economical useof resources, regulated recycling and disposal are
important components of our corporate philosophy– this claim also applies to our business activities
and our products.
These principles play an important role throughout
the entire product life cycle – e.g., in development,

production, packaging, shipping, use by customers,
recycling and disposal.
In addition, we also take environmental issues,energy efficiency and water consumption into accountwhen planning building facilities and products.
Maximum efficiency in the use of resources, taking
into account economic feasibility, and Compliancewith applicable relevant laws and regulations areimportant to us.
We want to avoid or minimize negative impacts on theenvironment as well as on the reputation of ZEISS.
More information:» Company policies about environmental protection» Company policies about energy management* Scope 1 emissions: CO2 emissions from direct combustion of fossil fuels (e.g.,gas, heating oil). Scope 2 emissions: CO2 emissions from indirect energy purchases(e.g., electricity, district heating) which in turn are generated from the direct
combustion of fossil fuels (e.g., gas, heating oil, coal).

This is what we expect from you:

The aspiration of ZEISS:» Use resources (water, materials,­electricity, etc.) economically andcarefully.

» We create sustainable products andvalue chains.

» Recycle and dispose of waste inaccordance with regulations and in­­an environmentally sound manner.
» Implement environmental protectionand energy efficiency measures
relevant to your work area while
maintaining cost effectiveness.
» Report potential environmental risks
to internal contact persons to prevent
environmental damage.
» Immediately notify internal contact
persons if environmental damage has
occurred.
» Inform our suppliers thatenvironmental protection and energy
efficiency are part of our selectionand evaluation criteria.

» We introduce closed water cycles as
far as technically possible.
» We minimize environmental impacts
on water bodies.
» We support the procurement of energy
from renewable sources and theuse of energy-efficient equipment,
products, and services.
» We operate an environmental and­energy management system and­continue to develop it.
» We ensure the availability of the­necessary resources and data toachieve the defined environmental­
and energy targets.
» We comply with the relevant laws
and regulations on the environment,
climate, energy, and sustainability.

The right behavior: Our principles | 13

Product safety and quality

This is what we expect from you:
» Be guided by the rules relevant to your job.
» Help ensure that our products, solutions, and services deliver
optimal performance and meet the highest standards.

We are fully committed
to the safety, quality,
and optimal performanceof our products

Our products, solutions and services must be safe and meet the required­quality and performance to deliver effective, reliable, accurate, and optimal
results according to their intended use.
We support the success of our customers and business partners throughinnovation, reliability and user-friendliness and promote sustainable business
relationships and solutions.
Product safety begins in the initial development phase, accompanies the­procurement and production process, and is an essential aspect of the­installation of our products at customer sites and during service.
A large number of legal requirements for the development, production,­approval and sale of our products serve to ensure product safety. ZEISS
products must not endanger the safety and health of consumers or users ­under any circumstances and must comply with the applicable regulatory
requirements and quality specifications.
We are committed to complying with the requirements and maintainingthe­­­effectiveness of our quality management system. This is how we avoid­defective products that can harm not only the company (e.g., reputation), butmore importantly users, patients, consumers, or others.

The aspiration of ZEISS:» We comply with the applicable standards, regulations, andcustomer requirements and ensure these are incorporated ininternal specifications.
» We implement business-specific quality management systems,
maintain them, and continuously improve them where possible.
» We define relevant quality targets and review them regularly.
» We inform our customers and stakeholders and take corrective
action when we become aware of hazards posed by our
products (e.g., through market observation or consideration ofregulatory reporting on product safety).

More information:» Corporate Management Manual

14 | ZEISS Code of Conduct

In this chapter:»

Competition and antitrust law»

Avoiding conflicts of interest,
secondary activities»

Fighting corruption»

Adherence to export controls
and customs regulations»

Correct bookkeeping and accounting,anti-money laundering

The right behavior inbusiness activities

The right behavior in business activities | 15

My team and I ensure transparency – wealways inform our customers and business
partners openly and honestly about the price,performance, and quality of our products,
among other things.
By advertising correctly, ZEISS will remain atrustworthy business partner in the future.

Adela Chen
Marketing Communication Supervisor,
Carl Zeiss (Shanghai) Co., Ltd; China

16 | ZEISS Code of Conduct

Competition and antitrust law

This is what we expect from you:» Refrain from any collusion or exchange of information
with competitors on competition-determining factors(e.g., price, conditions, production quantities, sales
territory, customer allocation).

We respect the principles and rulesof fair competition and do nottolerate anti-competitive behavior

Regulations protecting fair competition are an essential component to thefree market economy. To this end, there are laws worldwide that prohibit
actions such as:» Collusion and exchange of information between
competitors on prices, territory allocation, productquantities or other parameters relevant to competition» Price fixing by sales partners» Do not attempt to influence the pricing or other termsand ­conditions of sale of our distributors – either by
threatening disadvantages or by promising benefits.
» Do not interfere with bidding processes, e.g., do notmatch bids with competitors and do not ask bidding
entities to provide you with non-public information.
» Do not exploit dominant positions (e.g., by boycotting
deliveries).
» Do not make untrue or misleading advertising claims.

» Abuse of a dominant position
We avoid giving any appearanceof concerted behavior
We conduct legallycompliant marketing

The examples of prohibited activities listed here include informal discussions,informal understandings or coordinated conduct, as all of these are measures
restricting competition.
It is prohibited to gain competitive advantages through unfair marketing
activities. Advertising statements about products and services must be
truthful, accurate and not misleading.

More information:» Company policies on conduct in competition

The right behavior in business activities | 17

18 | ZEISS Code of Conduct

Avoiding conflicts of interest,
secondary activities

This is what we expect from you:
» Disclose any potential or actual conflicts of interest to
your manager or Human Resources.
» Hand over decisions where you may have a conflict ofinterest to your supervisor or colleagues.

We make our decisions exclusively
based on objective criteria anddo not allow ourselves to be
influenced by personal interests

In everyday business, situations may arise in which personal interests or
private relationships conflict with the interests of ZEISS. Conflicts may
arise, for example, from the employee‘s own entrepreneurial (sideline)
activities or, under certain circumstances, from those of family members
or friends.
Make such conflicts of interest transparent and leave the relevant decisions
to your supervisor or colleagues.

We communicate possible
conflicts and secondary activities
openly and transparently

ZEISS generally supports the socio-political or social commitment of its
employees. However, activities in associations, parties or other social,political or societal institutions, whether as a mandate holder or in anhonorary office, must be compatible with the fulfillment of the duties
under the employment contract.
The supervisor or Human Resources department must be informed about
any additional (entrepreneurial) sideline activities, honorary offices orsimilar activities. Approval may need to be obtained for them.

» Do not cause related parties (e.g., family members,
partners, friends) to perform activities for you that you
may not perform yourself due to a conflict of interest.
» Inform your supervisor and obtain approval from the
Human Resources Department before you begin any
outside employment (e.g., work for another company,
own entrepreneurial activity).
» Inform your supervisor before accepting an honorary
position (e.g., as a juror, on the local council or as an
exercise instructor).

More information:» Company policies for dealing with conflicts of interest

The right behavior in business activities | 19

Fighting corruption

This is what we expect from you:
» Don‘t make business decisions based on whether you receive a
personal benefit.

We do not tolerate
corrupt behavior by
our employees orbusiness partners

We do not bribe
and we do nottake bribes

We strive to be successful within the framework of fair competition. In doing so, we convince throughprice, performance, and the quality of our products and services and not because business partners
are influenced by corrupt actions. That would harm competition and is therefore prohibited.
Corrupt behavior means abusing one‘s decision-making authority in a professional environment forone‘s own private benefit or for the benefit of a third party, e.g., by demanding, accepting, offering,or granting personal benefits or benefits to third parties in return for the award of a contract.
Both the person who grants or holds out the prospect of such an advantage and the person who­demands or receives it may be liable to prosecution. Such an advantage is any kind of benefit suchas monetary payments (e.g., donations), non-cash benefits (e.g., vouchers, invitations, inadmissible
discounts) or gifts in kind but can also be services or favors (e.g., internship for daughter).

We always act withthe utmost restraint
when it comes toinvitations and gifts

Not every granting or acceptance of invitations or gifts is corruption. Socially customary benefits
that are not made with the purpose of unlawful favoritism (e.g., in connection with the awarding ofcontracts) may be permissible. But the appearance of improper influence can quickly arise. Therefore,
general restraint is required when accepting or granting invitations and gifts, especially in thecase of public officials (e.g., representatives of authorities and employees of state organizations) or
employees from the medical sector (e.g., doctors and pharmacists).

More information:
Company policies on
gifts and invitations

In many countries, invitations and gifts to these groups of people are completely prohibited.
Therefore, in these cases, no benefits of any kind are permitted. Exceptions to this may be reasonable
hospitality in connection with product presentations or training events, insofar as these have been
approved internally in advance.

» Do not attempt to influence business decisions in favor of ZEISS
by granting or promising personal benefits to decision-makers
of business partners.
» Reject bribery attempts and report them immediately to yoursupervisor or Compliance Officer.
» Be extremely cautious about invitations and gifts. Keep thebenchmark of €50 (or the equivalent value in local currency) ­as a guideline value in individual cases.
» Only accept invitations or gifts of a higher value in exceptional
cases that cannot be refused for cultural reasons. Make thisinternally transparent and make them available e.g., for social
purposes or an internal raffle.
» Only grant invitations or gifts of a higher value in justified­exceptional cases and after first checking their permissibility
under local law.
» Do not grant invitations or gifts to public officials or employeesof any government agency or the medical sector.

20 | ZEISS Code of Conduct

Adherence to export controls
and customs regulations

This is what we expect from you:

The aspiration of ZEISS:Have the staff responsible for export
control verify that

» We have policies and regulations forcontrol and monitoring processes
to ensure Compliance with export
control and customs regulations.

» restrictions or prohibitions exist(e.g., on the purchase, sale,brokering, and marketing of goods
and services, and on the transfer oftechnology).
» official approvals must be obtained
before the respective action is
performed.
We comply with all­applicable export control
and customs regulations

ZEISS is a globally active company that must comply with any­regulations restricting the free movement of goods in its worldwide
business activities.

» customs regulations must becomplied with for import andexport transactions.

» We appoint trained experts who
perform the necessary checks andhave the right to stop any activity
in case of doubts about legal
Compliance.
» We conduct IT-based screening
processes (sanctioned parties,
restricted goods, embargo
restrictions and end-use).

Various national and international laws and embargoes restrict or prohibit
the import, export or domestic trade of certain goods, technologies, orservices, as well as capital and payment transactions.
The restrictions and prohibitions may result from the nature of the goods,
the country of origin or use or due to the business partners themselves.
Every ZEISS company and its employees must comply with the relevant
customs regulations for import and export transactions.

More information:» Company policies about export control and customs

The right behavior in business activities | 21

Correct bookkeeping and accounting,anti-money laundering

This is what we expect from you:
» Comply with tax and accounting regulations.
» Do not transact business outside of standard processes.
» Ensure careful and orderly archiving of all documents
related to business transactions.
» Comply with legal retention requirements.
» Do not alter or destroy documents related to government
investigations or private litigation.

We record our financial­transactions completely and­­accurately and only work with
reputable business partners

All business transactions must be properly reflected in accounting records,
balance sheets and tax returns. This requires that all relevant facts arerecorded correctly and completely and documented and archived in a
traceable manner.

» Stop transactions immediately if there are any indicationsof money laundering or terrorist financing and report any
suspicious cases to the relevant colleagues.

Any infringement may expose the company to investigations for accounting
manipulation, document offenses, allegations of fraud, tax offenses, ormoney laundering charges.
We do not tolerate practices
that serve the purpose of money
laundering or financing terrorism

Money laundering means that the origin of illegally obtained money(e.g., from terrorism, drug trafficking, bribery, and other criminal acts) isconcealed by smuggling it into the legal economic cycle, thereby creating
the appearance of legality.
It is the declared objective of ZEISS not to be misused for money launderingor other illegal purposes or to contribute to this.

More information:» Company policies about finance and controlling22 | ZEISS Code of Conduct

The right way tohandle information

In this chapter:»

Data privacy»

Protection of trade secrets, ­and information security»

Ban on insider trading

The right way to handle information | 23

In my work, confidential handling of personal
data and Compliance with IT security standards
are essential.
Close collaboration with the Data Protection
Coordinators and regular training sessions
help my colleagues and me to implement the­requirements that must be met.

Monica Jernigan
Service Delivery Specialist,
Carl Zeiss, Inc. (Dublin, USA)

Plac

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24 | ZEISS Code of Conduct

Data privacy

This is what we expect from you:» Get an overview of the extent to which you aredealing with personal data.
» Protect personal data from unauthorized access(e.g., by maintaining the required security standards
in electronic communications with third parties).

We process personal data
only within the frameworkof applicable laws andprotect this data fromunauthorized access

The more extensive electronic data processing becomes, the more important is theprotection of personal data of our customers, business partners and employees.
Such personal data may only be disclosed and processed within the framework of
the applicable laws. The framework for data privacy is provided by internationaland national regulations.
The Group-wide data privacy management system, which is operated by the
Corporate Data Protection Officer and the global data privacy team, provides
support in meeting these data privacy requirements and avoiding potential
negative effects due to inadequate protection of this data.
The locally applicable laws specify which types of data are considered sensitiveand must be given special protection accordingly.
What is personal data?
Personal data are all data that make an individual person directly or indirectly
identifiable (e.g., name, address, age, gender, but also indirect data on IP
addresses or bank details).

» Collect personal data only when necessary to performthe task and as permitted by law.
» Dispose of records containing personal data in acontrolled and secure manner.
» Require our business partners to maintain the samehigh privacy standards.
The aspiration of ZEISS:» We implement and continuously develop the dataprotection management system.

More information:» Company policies about data privacy

The right way to handle information | 25

26 | ZEISS Code of Conduct

Protection of trade secrets,
and information security
We protect­confidential datafrom unauthorizedaccessOur inventions and know-how are critically important for the long-term
success of our company. Therefore, our intellectual property and all
confidential information must be protected from third party knowledge
or unauthorized access. This also includes protection against data theft,cyber-attacks, or malware.
Intellectual property includes, for example, inventions and prototypes. ­­But trade secrets, customer or supplier data and software also deserve
appropriate protection.
A variety of measures such as multifactor authentication, anti-virus
programs, and recurring training reduce potential risks. These also include
procedures to maintain and continuously improve our security level, theadequacy of which is regularly assessed and certified by independentbodies.

We do not disclose The protection of this information is ensured through the implementation
confidential information of the Group-wide information security management system.
As such, employees may not participate in public discussions (e.g., lecture
events, Internet forums) or disclose company-relevant information in
public (e.g., on the Internet) without prior consent.

This is what we expect from you:
» Keep confidential information­pertaining to the company
private and do not share it withunauthorized individuals – thisincludes family and friends.
» Protect files and records fromunauthorized access (e.g., throughencryption).
» Always comply with the security­rules set forth by information
security.
» Apply the same security rules toinformation disclosed to us by third
parties as confidential.
» Do not share confidential
information when using social
media.

More information:» Company policies about security» Do not store company data on
private electronic devices (e.g.,
computers, tablets, smartphones).
» Do not connect private electronic
devices to the corporate network.

The aspiration of ZEISS:» We implement and continuously
develop the information security
management system.
» We maintain appropriate control
processes to ensure correct
implementation.

The right way to handle information | 27

Ban on insider tradingThis is what we expect from you:
» Do not use information that you obtain about listedcompanies (e.g., Carl Zeiss Meditec AG) in the courseof your business activities to buy or sell securities
until this information is publicly known.
» Never disclose insider information to third parties.
Third parties also include family members, partners,
friends, or other ZEISS employees who do not havethis information.

We do not use any non-publicly available information from listed companies
that we obtain in the course of our work for ZEISS to obtain financial or businessadvantages for ourselves or third parties» Do not make recommendations to third parties­about buying or selling securities if you have inside­information about those securities.

Insider trading law serves to protect investors. On one hand, it prohibits the exploitationof insider information to gain direct or indirect personal advantages when buying or
selling securities. On the other hand, the unauthorized disclosure of such information isprohibited.
Insider information is information that is not yet known to the market and the disclosureof which is likely to have a significant effect on the price of the securities concerned(e.g., information on planned corporate acquisitions, strategic agreement on cooperation
between two companies, financial results, new products, problems with products orimportant contracts).

More information:» ​​​​​​​Investor relations on TEAM ZEISS

28 | ZEISS Code of Conduct

In this chapter:

The right behavior

in the workplace»

Occupational health and safety»

Handling company property

The right behavior in the workplace | 29

At our workplaces in assembly, it is necessary for me
and my colleagues to wear protective equipment.
The meaning of this equipment is already in the
name: The protection, not only of our own health, butalso of the products that are processed at our plant.

Sabine Wanner
Individual equipment assembler,
Carl Zeiss Jena GmbH (Oberkochen, Germany)30 | ZEISS Code of Conduct

Occupational health and safety
We ensure a healthy working environment and safe workplaces
through comprehensive occupational safety measures and medicalcare, as well as ­the provision of health-promoting measures
Safety in the workplace and protecting the health of all employees is afundamental principle for ZEISS and has been described in the Carl Zeiss
Foundation statutes.
We see the healthof our employees asa key factor for the
success of ZEISS

We take n­ ecessary
measures topromote goodworking conditions

The success of a company does not only depend on modern technology
and highly efficient products, but rather - first and foremost – on thepeople behind them. The physical and also mental health of employees
are key factors for their performance and motivation and ultimately
the company’s success. ­Safe workplaces that promote good health andwellbeing are equally ­important to employers and employees.
Each ZEISS entity must take and continuously develop the measures inline with its business operations to prevent accidents and to minimize­occupational health and safety risks as well as to promote healthy working
conditions.
The workplace health management at ZEISS promotes and improves thehealth of employees through preventive and wholesome measures.
Every supervisor is responsible for the protection of their employees andmust provide them with qualifications, guidance, and instructions.

This is what we expect from you:
» Familiarize yourself with the hazards andoccupational health and safety aspects of
the workplace.

» Seek advice on health and safety issues inthe destination country well in advance ofbusiness travel.

» Adhere to health and safety regulations
and use the required personal protective
equipment.

» Inform our relevant suppliers that­occupational health and safety is part ­of our selection and evaluation criteria.

» Take advantage of the prevention andhealth promotion measures offered.

The aspiration of ZEISS:» Conduct yourself in such a prudent mannerthat potentially dangerous situations do
not arise in the first place.

» We implement and continuously ­develop
the occupational health and safety­management system.

» Act as a role model in occupational healthand safety.

» We ensure the availability of the necessary
resources to achieve the defined goals.

» Report critical situations, near misses andaccidents immediately to the responsiblesupervisor and, if necessary, other internal
contact persons, to avoid them in the future.

» We comply with the relevant laws andregulations on occupational health andsafety.

More information:» Company policies about occupational health and safety

The right behavior in the workplace | 31

32 | ZEISS Code of Conduct

Handling company property

This is what we expect from you:
» Protect all company assets and information and­communication systems from loss, damage, or misuse.
» Use the resources provided by the company ­sparingly ­­­­­­and carefully.
» Use company property for personal purposes only withsupervisor permission and in accordance with internal
policies.

We handle company property
with care and protect itfrom loss, damage, theft,
and unauthorized use

All employees are obligated to treat company property with careand for the intended purpose. The workplace and all equipment
serving employees or the company must always be kept in orderand any damage must be reported immediately to the supervisor.
Company property includes, for example, machinery, tools, officeequipment, vehicles, and all information and communication
systems.

We use company property privately
only with appropriate permission

As a general rule, company property may not be used privately,
passed on to third parties or removed from the company unlessexpress permission has been granted by the supervisor or the
responsible department in the company.

We use company funds sparingly

Financial resources must be used sparingly and appropriately,for example by always booking and settling business trips in­accordance with the relevant travel policy.

» Never use company property for unauthorized purposes(e.g., visiting illegal websites).
» Use company funds sparingly and follow applicable travel
policies when booking and accounting for business travel.
» Be wary of third parties who attempt to damage our company
property (e.g., through theft, fraud, hacking).
» Report damage to or loss of company property immediately.

More information:» Company policies about security

The right behavior in case of doubt | 33

In this chapter:»

Reporting Compliance violations»

Internal contact points»

Special responsibilities of supervisors

The right behavior

in case of doubt

34 | ZEISS Code of Conduct

In some situations, it is not easy to know which
behavior is the right one. In these cases of doubt,
you are not alone!
Contact your supervisor and talk about the situation.
In addition, the members of the ZEISS Compliance
Organization will be happy to assist you as contact
persons for advice!
Klaus Birkle
Chief Compliance Officer,
Carl Zeiss AG (Oberkochen, Germany)

The right behavior in case of doubt | 35

Reporting Compliance violations

We seek advice from the relevant
contact points if we have any
questions and report possible
violations without delay

All employees are expected to contact their supervisor, the responsible HR or relevant
functional department, the employee representative, or the Compliance organization
if they have any doubts about their own conduct or if they receive information about
legally dubious processes in the work environment.
If employees cannot or do not wish to openly address a possible violation of laws orinternal rules to the aforementioned contact points, the whistleblower system ZEISSIntegrity Line can be used. It also allows anonymous reports and can be accessed both
via the intranet and via the ZEISS public website.

We protect good faithwhistleblowers

More information:
Compliance pageon TEAM ZEISSAll concerns raised in good faith regarding non-compliance with laws and internal policies
will be taken seriously and will be treated confidentially. The whistleblower does nothave to fear any disciplinary measures or sanctions, even if the alleged misconduct of theaccused person is not confirmed. However, deliberately false accusations (e.g., made solely
to harm others) will not be tolerated.
We respond consistently to proven Compliance violations with consistent measures, inaccordance with the principle of proportionality. For each individual case, we examine
which consequences are suitable, necessary, and appropriate.

36 | ZEISS Code of Conduct

Internal contact points

If you believe a Compliance violation
has occurred, you may also report it
as follows:
ZEISS Integrity LineThe electronic whistleblower system ZEISSIntegrity Line is available 24 hours a day.
Reports can be made in a protected area
and can also be submitted anonymously.
FAQ about the whistleblower system

Do you have a question related to a Compliance topic?
Please feel free to contact one of the following contact points:

Compliance@zeiss.com
Send an email to the ZEISS Corporate
Compliance team.
Talk to yoursupervisor.

Talk to the HR or
responsible functional
department.

Talk to the ZEISS
Compliance Organization:
Compliance Officer or
Corporate Compliance(compliance@zeiss.com)

Compliance Officer
ZEISS employees can find an overview of
the responsible Compliance Officers on the
Compliance page on TEAM ZEISS.

The right behavior in case of doubt | 37

38 | ZEISS Code of Conduct

Special responsibility of supervisors

This is what we expect from our supervisors:» Act as a role model for employees and regularly communicate
the importance of Compliance to them.
» Ensure that you and your employees know, understand, andcomply with the requirements of the Code of Conduct.
» Ensure that your employees receive the necessary instructions
and complete the Compliance trainings.
» Set goals for yourself and your employees that are consistent
with this Code of Conduct.

We expect our supervisors to embed the importance of Compliancein the company and to act as role models for employees
Each individual employee has a responsibility to do the right thing and to
abide by the rules. Executives and supervisors have a special responsibility.
By virtue of their leadership role and their associated function as rolemodels, they shape the corporate and Compliance culture.
We see the role model functionof supervisors as the key to
our Compliance culture

Our supervisors must ensure that the principles set out in this Code of
Conduct, as well as the laws and internal policies to be complied with,are known to employees, understood, and followed. A culture of trust
must be created, characterized by transparent communication and wherehonest and constructive criticism is welcomed. Individual misconduct
must be stopped and, if necessary, punished.

» Initiate corrective or disciplinary action for violations of laws
and internal policies.
» Be the point of contact for employees and support them, e.g.,
by following up on indications of misconduct.
» Encourage your employees to address potential Complianceviolations.
More information:» Leadership Principles» ZEISS Core Competency Model» Framework and Concepts for ZEISSZEISS Code of Conduct | 39

Use the ZEISS Code of Conduct as a
guideline for responsible and compliant
business conduct.
Dr. Karl Lamprecht
CEO of the ZEISS GroupEN_90_010_0018IV CZ-10/2023

Carl Zeiss AG
Corporate Compliance Office73447 Oberkochen
compliance@zeiss.com
www.zeiss.com/compliance