Policy statement on the human rights strategy ofORAFOL Europe GmbHThe responsibility for the implementation of this human rights policy statement is controlled by thechairman & CEO of the ORAFOL Group, the members of the ORAFOL management group, and themanagement of the company departments. This ensures that every part of our company is clear on its
own responsibility for the respect and everyday implementation of human rights.
As a chemicals and plastics processing business, we are able to strengthen our human rights
protections in many different ways. We are also, however, aware of the potential risks to human rights
and environmental standards that our business can involve.
The principles of the ORAFOL human rights strategy as stated here apply to our own business activities
and to all employees of the ORAFOL GROUP.
Furthermore, we also expect our suppliers and other business partners to commit to the principles
recorded here and to implement suitable processes for respecting human rights. This also includes
providing information on their compliance with the specified principles when requested to do so.

……………………………………………………………
Dr. Holger Loclair
Chairman & Chief Executive Officer

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Introduction
MISSION STATEMENT and VALUES of the ORAFOL GroupWe strive every day to pursue our vision with a strong focus on research and development, and withinvestments in the future and in national and international production capacities. As a family-owned
business, we make considered decisions quickly, are passionate about developing new and bespoke
solutions for our customers, and always place equal value on outstanding service(punctuality/reliability), stable customer relationships, transparency and trust. Our engineeringexpertise “made in Germany” and our roots in Brandenburg give us the strength and power toassertively shape industries as a global player and market leader.

COMMITTED TO PROVIDING PEAK TECHNOLOGICAL PERFORMANCE
ORAFOL is a technology-driven business. Our research and development is of high quality, applicationoriented, and designed to secure our economic future, as developments are brought up to industry
standards very quickly. The topic of high technology is also demonstrated by the skills and experienceof the ORAFOL management team. Every contact at this level is informed by technological expertiseand gives our customers a feeling of trust and closeness. High technology also represents ourinnovative capability and successful ideas management. Our German engineering shines from
Oranienburg to the entire world. However, global markets offer the potential for growth, but they also
provide space for more competition. Both factors require a high level of agility from ORAFOL. Our will
to be the market leader in the industry and further expand our global market position drives us tocreate global standards and synergies in the value chain and simultaneously remain close to the local
needs of our markets. The principle of “customized solution selling” strengthens our position as ahigh-tech company with our customers in an individual fashion. At the same time, it sustainably
secures the growth potential of our company by permanently optimizing the depth of addedvalue. Our autarkic production ensures even greater independence from external suppliers and service
providers and allows ORAFOL to adapt more quickly to market and customer needs.

PREMIUM QUALITY
ORAFOL stands for premium quality. Our production sites, in which we are constantly investing, areglobal leaders with regard to machines and process management – in terms of both modernity andefficiency. Customer satisfaction is the highest priority. Our highest goal is to fulfill the needs andpreferences of our customers and to accompany them into the future. Our customer relationships arepartnerships at eye level: We want to offer our customers positive experiences that go beyond theactual product. For this reason, reliability, punctuality, and speedy reaction are the values of ourpremium service concept. We are not satisfied with the way things are. We are always improving allareas of the business – profits are continuously reinvested. Premium means always being a stepahead. Our quality standard creates trust in all areas: with customers and employees. In an
increasingly changing world, our commitment to premium quality represents a stable and trustfulvalue for the future.
Declaration of principle on the human rights strategy of the ORAFOL Group(as per LkSG § 6.2)

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Our company management is shaped by the personalities of the people at ORAFOL. We areapproachable, responsive, and interact at eye level with customers, suppliers, and employees.
As a family-owned company we strive in all our activities for a high level of freedom to make decisions
and to act. We enjoy the privilege of making decisions quickly and courageously, developing leading
product solutions from high technology, and making flexible use of our capacities. This gives us asignificant competitive advantage that benefits our customers. Our service is personal, engaging, andreliable.
As an independent family-owned business we are obligated only to ourselves and our high standards.
Our financial independence enables us to reinvest our profits directly in new projects andgroundbreaking technologies.
Our ambition, constant curiosity, and visions motivate us to challenge ourselves constantly.
Management’s commitment to personal values is what makes ORAFOL special – it is an anchor for all
our reference groups.

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Commitment to due diligence on human rights at ORAFOLORAFOL commits to the compliance with and monitoring of its due diligence on human rights in linewith international standards. We always obey the law. Where local laws and international humanrights are not aligned, we will act according to the higher standard. This applies in particular to the banon child and forced labor, the ban on all forms of slavery and discrimination, and the strengthening of
the right to organize. We also commit to complying with occupational health and safety, to paying fairwages, and to the ban on environmental pollution, eviction, and the use of security forces if theirdeployment involves the risk that human rights will be ignored or restricted.
At the product level, we endorse in particular: The Stockholm Convention(Stockholm Convention on Persistent Organic Pollutants; http://www.pops.int/), The Minamata Convention(https://minamataconvention.org/en/documents/minamata-convention-mercury-text-andannexes) and The Basel Convention(The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes andtheir Disposal; http://www.basel.int/) as well as the regulations and national laws derived
therefrom.
Furthermore, we also endorse the international agreements listed below:
 Universal Declaration of Human Rights from the United Nations (UN AEMR)
 International Covenant on Civil and Political Rights (UN ICCPR)
 International Covenant on Economic, Social and Cultural Rights (UN ICESCR) Declaration on Fundamental Principles and Rights at Work (ILO) Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy(MNE Declaration) The Ten Principles of the UN Global Compact
 UN Guiding Principles on Business and Human Rights
 OECD Guidelines for Multinational Enterprises
 Responsible Care® Global Charter of the International Council of Chemical Associations

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Embedding of the human rights strategy at ORAFOL
1. Risk analysis and priority risks
A comprehensive and continuous risk analysis provides a basis for appropriate prevention and remedy
measures for the ORAFOL GROUP. The risk analysis provides transparency on the potential negativeimpacts on people and the environment that can result from our business activities, products andservices as well as from the associated business relationships. In order to draw up a risk analysis, wehave developed and implemented a process that incorporates the identification, assessment, andprioritization of risks to human rights and the environment, both in our own business area and for ourdirect suppliers. In addition, we have adjusted our existing procurement practices, such as the onboarding of new suppliers, according to human rights and environmental criteria in line with theGerman Supply Chain Act (Lieferkettensorgfaltspflichtengesetz). Should the ORAFOL GROUP obtain
substantiated knowledge that indirect suppliers are violating human rights or environmental
standards, event-driven risk analyses will be performed. The Compliance Manager ensures that theresults of the risk analyses are reported to the relevant decision-makers in management and in thepurchasing department.
During the first stage, the analysis of locations in our own field of business rests on an abstract risk
analysis, which examines the risks at both national and industry level. Based on this initial analysis, thelocations are instructed to analyze the concrete risks for their area of business. The identified actual
risks are subsequently discussed with the responsible persons at the respective locations. If necessary,
further information is obtained and suitable measures for prevention and remedy are defined. This
process ensures that no violations of human rights or environmental regulations take place in our own
area of business, or that any such violations are rectified promptly.
In the case of our immediate suppliers, the ORAFOL GROUP identifies and assesses risks continuously
and systematically at least once a year in a graded process. All active direct suppliers are sorted intorisk categories on the basis of national and industry risks as part of an abstract risk analysis. During thesecond stage, suppliers who are assigned a higher risk in the abstract risk analysis are examined moreclosely in a concrete risk analysis. These suppliers are requested to provide information on potential
violations of human rights or environmental standards in the past. They are also required to provide aspecific voluntary disclosure containing additional information that is relevant to the risk. Based on theinsights from these concrete supplier-specific risk analyses, suitable prevention and remedy measures
are developed if necessary.
Details from the complaints procedure that affect our own business area, or the supply chain areprocessed and considered in the relevant risk analysis. In addition, event-driven risk analyses are
performed if a significantly changed or extended risk situation is to be expected due to theintroduction of new products, projects, or business areas.
In its own field of business, the ORAFOL GROUP has identified the following areas with potential risks:environmental protection; guarantee of freedom of association and right to organize; responsible useof security forces; and compliance with occupational safety and occupational health risks.
In the case of our immediate suppliers, we have identified the following relevant risks on the basis of
our existing risk analysis: environmental protection; critical use of security forces; freedom ofassociation and right to organize; violation of occupational safety; and occupational health risks.

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This risk situation is partly caused by the fact that the majority of suppliers relevant to the ORAFOLGROUP are members of the chemical industry. This industry is fraught with risk, mainly because ofhigh demand for raw materials from countries that tend to have high risks to human rights andenvironmental protection, and because of the character of the business (including handling of
hazardous materials).

2. Implementation of appropriate measures
In order to live up to our self-imposed commitment to human rights, we are implementing
appropriate diligence processes. We use these to identify and mitigate risks and effects. We will adjust
our declaration of principle accordingly over time.
Furthermore, we will incorporate the results of our risk analyses into the relevant business processes,
and in particular into our supplier management system. Where risks exist we implement suitable
preventive measures.
Regardless of the as-yet incomplete concrete risk analyses, we have already implemented measures toprevent potential human rights violations:




Measures for the health and safety of our own employees:
The health and safety of our employees are of the highest priority for us. By implementing
consistently high standards at all our locations, we are working continuously to create a safeand healthy working environment.
Supplier selection and assessment:
When selecting and assessing our suppliers, we consider human rights criteria andselected/specific environmental criteria, and we execute appropriate inspection measures,among them supplier audits.
Voluntary disclosures
We perform our supplier monitoring by means of digital software tools such as Sphera(riskmethods) and IntegrityNext (INX)
Training:
We conduct training for the relevant business areas, including on the topics of IT andoccupational health and safety.
Product safety measures are performed continuously as part of our quality assurance.

When violations are identified, we collaborate with the affected department, subsidiary, or supplier todevelop measures that will avoid the situation where human rights and/or the environment are at risk.
In cases where our business activities cause or contribute to actual human rights violations,
we commit to the implementation of effective remedy measures.
For the ORAFOL GROUP, the teaching of knowledge to improve working conditions in the supply chain
is an essential and sustainable key to avoiding human rights risks. For this reason, we collaborate withinitiatives and associations in order to bundle our forces with actors from business, politics, and civilsociety. We evaluate our established measures in terms of their effectiveness in order to improve
continuously in this field as well.

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3. Whistleblower system
In spite of our great care regarding human rights, we are aware that violations can occur. We
therefore believe it is essential to establish complaint mechanisms, partly as indicators for recording
the risks, and partly as a way of exposing actual violations where they occur and initiating
countermeasures. In the context of our membership in associations, we are already working on finding
industry solutions that allow greater access to complaints procedures.
Our whistleblower system is an additional way for all people involved with the ORAFOL GROUP –whether they are employees, business partners, suppliers, residents, or customers – to reportcompliance violations.
A complaint or tip can be submitted as follows at any time, in line with data and whistleblower
protection, and – if required – anonymously:
1. Online via the digital whistleblower portal on our website athttps://orafol.integrityline.app/(an anonymous tip & voice message is also possible)
2. In writing by posting a letter in one of the blue report boxes (this can also be done
anonymously; however, there will be no feedback from ORAFOL in this case)
3. Via email to compliance@orafol.deDeclaration of principle on the human rights strategy of the ORAFOL Group(as per LkSG § 6.2)

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4. Governance structure
We are currently developing a governance structure that will distribute our responsibilities for theoperational implementation of our human rights strategy. We will adjust our declaration of principle
accordingly.
In order to enforce our aim of recognizing and respecting human rights, we have defined andpublished two directives for the whole Group. These are continuously checked and expanded wherenecessary:Our Code of Conduct provides all employees of the ORAFOL GROUP with a guideline forresponsible action.

Our Supplier Code of Conduct for service providers and suppliers contains all ourrequirements for our business partners in the field of procuring raw materials, trade goods,and services. These binding requirements include social standards, environmental protection
rules, occupational health and safety, and company management.

Effectiveness check

The world and our market environment are constantly changing. For this reason, we continuously
check our risk assessment and measures. We also subject our processes, this declaration of principle,
and our communications to regular review, and adjust them to changing conditions if necessary. We
are, for example, continuously working to make our reporting on risks and measures even moretransparent.

Internal documentation and external reporting

We report annually on our human rights diligence process at group level in the ORAFOL GROUP
Annual Report. Further information on focal points and risks or measures for specific business fields
are published by the individual group companies.

Responsibility
The management of the ORAFOL GROUP is responsible for the implementation of, and compliancewith, this declaration.

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