Policy Statement on Human Rights andEnvironmental Due Diligence Obligations1 ofOSRAM GmbH – Munich

1 In accordance with the German Act on Corporate Due Diligence Obligations for the Prevention of Human Rights

Violations in Supply Chains (Supply Chain Due Diligence Act - SCDDA, Lieferkettensorgfaltspflichtengesetz – LkSG).

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Commitment to Respect for Human Rights and the Protection of theEnvironment
As a leading international company in the lighting industry and being a part of the ams OSRAM
Group, OSRAM 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 business activities,business relationships, supply chain or through our products. At the same time, we aim tostrengthen positive effects.
We respect and support the human rights recognized by the international community and protect
the environment wherever we operate. Furthermore, we expect the same from our employees,
suppliers, and business partners worldwide. This includes complying with the followinginternational standards and frameworks which are also enshrined in our Code of Conduct forEmployees, Code of Conduct for Suppliers, Human Rights Policy, as well as in our EHS Policy:• United Nations (UN) Universal Declaration on Human Rights and other internationalagreements• International Labor Organization (ILO) Declaration on Fundamental Principles and Rights atWork• 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) for
Multinational Enterprises• Principles of the United Nations Global Compact (UNGC)• Responsible Business Alliance (RBA) Code of Conduct

2Fulfilling our Human Rights and Environmental Due Diligence Obligations

2.1 Governance and Lead Functions
At OSRAM GmbH, the Management is responsible for the implementation of, and compliancewith, the principles and procedures set out in this Policy Statement on Human Rights andEnvironmental Due Diligence Obligations.
To continuously fulfill these due diligence obligations, OSRAM GmbH closely cooperates withvarious corporate and specialist departments of the ams OSRAM Group. The corporate HumanResources (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 (including OSRAM GmbH). The corporate Procurement
Department is responsible for ensuring that our due diligence obligations are complied with by
the Group’s entire supply chain (including the supply chain of OSRAM GmbH). The corporate
Compliance Department is responsible for the whistleblowing system “Tell ams OSRAM”, which
is one of the main reporting channels of our complaints management system. Corporate Audit isresponsible for review the compliance with, and the effectiveness and efficiency of our Supply
Chain Due Diligence Risk Management System. The Legal Department provides legal advice to allfunctions.
The Management Board of the ams OSRAM Group has appointed the Head of Audit, Compliance& Risk Management as the Group 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 OSRAM GmbH. The Human Rights Officer is supported bythe local human rights coordinator at OSRAM GmbH.
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Policy Statement of OSRAM GmbH pursuant the German Supply Chain Due Diligence Act22.2 Risk management under the German(Lieferkettensorgfaltspflichtengesetz, LkSG)

SupplyChainDueDiligenceAct

We have established a risk management system that aims to identify, report, assess and prioritize
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) areresponsible 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 we havesubstantiated knowledge indicating that human rights or environmental due diligence obligations
may have been violated. To this end, we rely on the risk and hot spot analyses specificallyconducted for OSRAM GmbH, as well as on a structured risk assessment process. Based on thecore area of our business activities, we focus on the following risk areas, both in our own business
operations and in our supply chain:• 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 theGroup Human Rights Officer and the Management of OSRAM GmbH. These results provide thebasis for developing effective prevention measures in close cooperation with the corporate andlocal specialist departments responsible. Significant risks are also incorporated into the Groupwide Enterprise Risk Management 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 OSRAM GmbH 2 . They form a mandatory action framework for all employees andbusiness 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 diligenceobligations:• ams OSRAM Code of Conduct for Employees• ams OSRAM Code of Conduct for Suppliers• ams OSRAM Human Rights Policy• 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 OSRAM GmbH. To fulfill ourresponsibility within the scope of human rights due diligence obligations and prevent any
offenses, we have implemented the following measures for our own employees and locations, aswell as for our suppliers:• We inform and train employees on human rights (including working conditions), health andsafety at work, as well as environmental protection.
2 In addition, OSRAM GmbH has concluded local employer/works council agreements for its own location whichrefer 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 OSRAM GmbH pursuant the German Supply Chain Due Diligence Act3•••

We conduct in-house surveys, analyses, audits, and certifications (or have them conductedby third parties).
We develop and implement strategies and measures for handling identified external andinternal risk 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 part ofour supplier selection, qualification, monitoring, and development process. We perform riskbased audits, also as part of industry initiatives.

2.2.3 Complaints procedure
OSRAM GmbH has established various reporting channels which can be used by employees andthird parties to report human rights and environmental risks and violations at any time. This
allows us to identify negative developments and grievances at an early stage. We have a groupwide reporting system called “Tell ams OSRAM”, which is accessible to all employees of 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 andon our company Intranet can also be used for this purpose. In addition, employees can contact
the Human Rights Officer, the local human rights coordinator, the responsible HR department, orthe respective line manager.
We also consider whistleblowing systems of industry initiatives of which ams OSRAM is a member
in order to identify potential weaknesses at an early stage.
All relevant reports submitted via the various channels are documented and processed inaccordance with our internal complaints procedure. See also Rules of procedure on thecomplaints 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 which measures arenecessary and appropriate for eliminating it. These can include e.g. disciplinary measures against
employees. If a supplier has committed a substantial violation of our Code of Conduct for
Suppliers, 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 andresults of remedial measures are reported to the Management of OSRAM GmbH and to the GroupManagement Board both on a regular basis and ad-hoc. They are published once a year within
the scope of the supply chain due diligence reporting.

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 with theLkSG. The Group Human Rights Officer reports to the Management of OSRAM GmbH on supply
chain due diligence compliance at least once per year. In addition, Corporate Audit continuously
assesses compliance with, and the effectiveness and efficiency of the Supply Chain Due Diligence
Risk Management System throughout the ams OSRAM Group.

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Policy Statement of OSRAM GmbH pursuant the German Supply Chain Due Diligence Act4

2.3 External/ 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. Furthermore, we report on these topics in the annual sustainability reportingof 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 OSRAM GmbH as acompany. We are aware that the implementation of human rights due diligence obligations in ourown business area as well as in our supply and value chains is a constantly evolving process. We
take on this challenge and regularly check our strategic approaches and measures with the goalof continuous improvement. Within the scope of supply chain due diligence and sustainability
reporting, we regularly inform on measures implemented and strategic developments in atransparent manner.

The Management of OSRAM GmbH

Rainer Barthel(Chairman)

Babette Fröhlich

Munich, 12.12.2023

Veröffentlich von der OSRAM GmbH
Marcel-Breuer-Straße 480807 München
Deutschland
Telefon: +49 89 6213-0
Fax: +49 89 6213-2020
E-Mail: humanrights@ams-osram.com
Internet: https://ams-osram.com

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Policy Statement of OSRAM GmbH pursuant the German Supply Chain Due Diligence Act5