Policy Statement on Human Rights andEnvironmental Due Diligence Obligations 1 ofams-OSRAM International GmbH – Regensburg

1In accordance with the German Act on Corporate Due Diligence Obligations for thePrevention of Human Rights Violations in Supply Chains (Supply Chain Due Diligence Act,
Lieferkettensorgfaltspflichtengesetz – LkSG).

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Commitment to Respect for Human Rights and the Protection of theEnvironment
As a leading global high-tech company operating in the field of opto semiconductors and beinga part of the ams OSRAM Group, ams-OSRAM International GmbH is aware of its responsibility
within the global value chain.
We hereby undertake to prevent, mitigate and, where necessary, remedy any negative
impacts on human rights and the environment that might arise in the context of our businessactivities, business relationships, supply chain or through our products. At the same time, we
aim to strengthen positive effects.
We respect and support the human rights recognized by the international community andprotect the environment wherever we operate. Furthermore, we expect the same from ouremployees, suppliers, and business partners worldwide. This includes complying with thefollowing international standards and frameworks which are also enshrined in our Code ofConduct for Employees, Code of Conduct for Suppliers, Human Rights Policy, as well as in ourEHS Policy:

22.1

United Nations (UN) Universal Declaration on Human Rights and other internationalagreements
International Labor Organization (ILO) Declaration on Fundamental Principles and Rights
at Work
Tripartite Declaration of Principles of the International Labor Organization (ILO)
Concerning Multinational Enterprises and Social Policy (“MNE Declaration”)
Guidelines of the Organization for Economic Co-operation and Development (OECD) forMultinational Enterprises
Principles of the United Nations Global Compact (UNGC)
Responsible Business Alliance (RBA) Code of Conduct

Fulfilling our Human Rights and Environmental Due Diligence Obligations
Governance and Lead Functions
At ams-OSRAM International GmbH, the Management Board is responsible for theimplementation of, and compliance with, the principles and procedures set out in this Policy
Statement on Human Rights and Environmental Due Diligence Obligations.
To continuously fulfill these due diligence obligations, ams-OSRAM International GmbH closelycooperates with various corporate and specialist departments of the ams OSRAM Group. The
corporate Human Resources (HR) Department and the corporate Environmental Protection,
Health and Safety (EHS) Department are responsible for coordinating the relevant due
diligence activities at our own locations, including subsidiaries (e.g., ams-OSRAM InternationalGmbH). The corporate Procurement Department is responsible for ensuring that our due
diligence obligations are complied with by the Group’s entire supply chain (including thesupply chain of ams-OSRAM International GmbH). The corporate Compliance Department is
responsible for the whistleblowing system “Tell ams OSRAM”, which is one of the mainreporting channels of our complaint management system. Corporate Audit is responsible forreview the compliance with, and the effectiveness and efficiency of our Supply Chain Due

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Policy Statement of ams-OSRAM International GmbH in accordance with the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz, LkSG)
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Diligence Risk Management System. The Legal Department provides legal advice to allfunctions.
The ams OSRAM Management Board has appointed the Head of Audit, Compliance & Risk
Management as its corporate Human Rights Officer. The Human Rights Officer is responsiblefor monitoring compliance with due diligence obligations, including the Supply Chain Due
Diligence Risk Management System of ams-OSRAM International GmbH. The Human Rights
Officer is supported by the local human rights coordinator at ams-OSRAM International GmbH.

2.2

Risk management under the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz, LkSG)
We have established a risk management system that aims to identify, report, assess andprioritize potential human rights risks and violations as well as environmental impacts within
our value chain, and to define and implement appropriate preventive and remedial measures.

2.2.1

Risk analysis and assessment
The corporate specialist departments of the ams OSRAM Group (HR, EHS and Procurement)
are responsible for subjecting our entire value chain to human rights and environmental risk
analyses. These analyses are both performed on an annual basis and ad-hoc, especially if wehave substantiated knowledge indicating that human rights or environmental due diligenceobligations may have been violated. To this end, we rely on the risk and hot spot analyses
specifically conducted for ams-OSRAM International GmbH, as well as on a structured risk
assessment process. Based on the risk analyses conducted, the following risk areas have been
identified within both our own operations and our supply chain, and addressed with priority2:
 Working conditions
 Discrimination
 Environmental protection, occupational health and safety Child and forced labor, human trafficking (in the supply chain only)
The results of the risk analyses and risk assessments are documented; they are reported to the
Human Rights Officer of the ams OSRAM Group and the Management Board of ams-OSRAM
International GmbH. These results provide the basis for developing effective prevention
measures in close cooperation with the corporate and local specialist departments
responsible. Significant risks are also addressed by the Enterprise Risk Management of the ams
OSRAM Group and thus reported to the Group’s Management Board.

2.2.2

Preventive measures
The ams OSRAM Group has set up policies and guidelines which apply to the whole group,including ams-OSRAM International GmbH3. They form a mandatory action framework for all
employees and business partners of the ams OSRAM Group and define concrete instructions
for action, measures, and objectives, in order to comply with human rights and environmental
due diligence obligations: ams OSRAM Code of Conduct for Employees ams OSRAM Code of Conduct for Suppliers
 ams OSRAM Human Rights Policy2

As of July 2023. Please refer to our Human Rights Policy.
In addition, ams-OSRAM International GmbH has concluded local employer/works council agreements for its own
location which refer to various aspects of due diligence obligations in accordance with the German Supply Chain
Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, LkSG).
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Policy Statement of ams-OSRAM International GmbH in accordance with the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz, LkSG)
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ams OSRAM HR Policy (internal document)
ams OSRAM EHS Policy
ams OSRAM Conflict Minerals Policy

Compliance with applicable laws, as well as with the corporate policies and guidelines adopted,
is compulsory for all employees and business partners of ams-OSRAM International GmbH. To
fulfill our responsibility within the scope of human rights due diligence obligations and prevent
any offenses, we have implemented the following measures for our own employees andlocations, as well as for our suppliers: We inform and train employees on human rights (including working conditions), healthand safety at work, as well as environmental protection.
 We conduct in-house surveys, analyses, audits, and certifications (or have them conductedby third parties).
 We develop and implement strategies and measures for identified external and internalrisk areas or fields of action.
 We define concrete requirements (e.g., external certifications) for suppliers and service
providers; furthermore, we request information, for example, on human rights, child andforced labor, as well as environmental protection. These requirements are an integral partof our supplier selection, qualification, monitoring, and development process. We performrisk-based audits, also as part of industry initiatives.
2.2.3

Complaints procedure
ams-OSRAM International GmbH has established various reporting channels which can beused by employees and third parties to report human rights and environmental risks andviolations at any time. This allows us to identify negative developments and grievances at an
early stage. “Tell ams OSRAM” is our on-line reporting system; it is accessible to all employeesof the ams OSRAM Group as well as to all external stakeholders.
The e-mail contact addresses, and online contact forms provided on the ams OSRAM website
and on our company Intranet can also be used for this purpose. In addition, employees cancontact the Human Rights Officer, the local human rights coordinator, the responsible HR
department, or the respective line manager. All relevant reports submitted via the variouschannels are documented and processed in accordance with our internal complaintsprocedure. See also Rules of procedure on the complaints procedure.

2.2.4

Remedial measures
Violations of legal requirements or our corporate policies and guidelines are not tolerated andwill be consistently prosecuted. We have developed and implemented internal processes
which define how to proceed in the case of a reported or confirmed incident, and whichmeasures are necessary and appropriate for eliminating it. These can include e.g., disciplinary
measures against employees. If a supplier has committed a substantial violation of our Codeof Conduct, we reserve the right to terminate contracts after a reasonable remedy period has
elapsed unsuccessfully.
All relevant incidents are documented and processed based on the remedial measures
defined; afterwards, the successful implementation of these measures is carefully tracked.
Incidents and results of remedial measures are reported to the Management Board both on aregular basis and ad-hoc and published once a year within the scope of the supply chain due
diligence (LkSG) reporting.

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Policy Statement of ams-OSRAM International GmbH in accordance with the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz, LkSG)
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2.2.5

Monitoring the effectiveness of the risk management
The Human Rights Officer of the ams OSRAM Group is responsible for monitoring theeffectiveness of the Supply Chain Due Diligence Risk Management System in accordance withthe LkSG. The Group Human Rights Officer reports to the Management Board of ams-OSRAM
International GmbH on LkSG compliance at least once per year. In addition, Corporate Audit
continuously assesses compliance with, and the effectiveness and efficiency of the SupplyChain Due Diligence Risk Management System throughout the ams OSRAM Group.

2.3External/ internal communication and reporting
Information on human rights, health and safety at work, supply chain due diligence, andenvironmental protection is published on the website of the ams OSRAM Group. This includes
company policies, as well as codes of conduct and processes intended for both our employees
and our suppliers.
We will establish a report on compliance with our due diligence obligations in the previous
fiscal year in accordance with the provisions of the German Supply Chain Due Diligence Act(LkSG), submit this report to the German Federal Office of Economics and Export Control(Bundesamt für Wirtschaft und Ausfuhrkontrolle, BAFA) in due time, and publish it on thewebsite mentioned above. Furthermore, we report on these topics in the annual sustainability
reporting of ams-OSRAM AG.
Internal communication takes place through various channels such as our Intranet, as well as
through training activities, manuals, or instructions for action. The Group Human Rights Officer
reports to the Management Board on compliance with human rights, environmental and othersupply chain due diligence obligations, both on a regular basis and event driven. Where legallyrequired, committees such as the Works Council/ Economic Committee or the Supervisory
Board are informed or notified.

3Outlook
Respect for human rights is a major part of the social responsibility of ams-OSRAM
International GmbH as a company. We are aware that the implementation of human rights
due diligence obligations in our own business area as well as in our supply and value chains isa constantly evolving process. We take on this challenge and regularly check our strategic
approaches and measures with the goal of continuous improvement. Within the scope ofsupply chain due diligence (LkSG) and sustainability reporting, we regularly inform on
measures implemented and strategic developments in a transparent manner.

The Management Board of ams-OSRAM International GmbH

Robert Feurle(Chairman)

Julia HalaszRegensburg, 20.11.2023

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Policy Statement of ams-OSRAM International GmbH in accordance with the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz, LkSG)
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Published by ams-OSRAM International GmbH
Leibnizstr. 493055 Regensburg
Germany
Phone: +49 941 850-5
Fax: +49 941 850-1002
E-mail: humanrights@ams-osram.com
Internet: https://ams-osram.com

Version: November 2023
Policy Statement of ams-OSRAM International GmbH in accordance with the German Supply Chain Due Diligence Act(Lieferkettensorgfaltspflichtengesetz, LkSG)
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