Corporate Guideline CO1000

Code of Conduct
The Code of Conduct (CoC) contains thefundamental principles and rules for the conduct of
all ams OSRAM employees. It defines the ethicaland legal framework within which we act. The CoC
applies to all employees worldwide, both in theirdealings with each other and in their relationships
with our external partners and the general public.

Contacts and validity
Issuer:Compliance (CO)Governance Owner:
Dietmar Prechtel (CO)Author:Danielle Campos (CO)Geographical validity:
GlobalOrganizational validity:
All organizational levels
Valid from:2023-08-01

Distribution list:
Management Team ams OSRAM
Heads of BUs
Management of Subsidiaries
Heads of Corp. Functions
Managers International

Table of Contents
Introduction

2

A.

Basic Behavioral Requirements

2

B.

Behavior which Complies with the Law
Respect for Human and Personal Rights, Mutual Respect, Honesty and Integrity
Responsibility for the Reputation of ams OSRAMManagement, Responsibility and Supervision
Treatment of Business Partners and Third Parties

2
3
3
3
4

C.

B.1 Fair Competition and Antitrust Laws
B.2 Anti-Corruption: Offering and Granting Benefits
B.3 Anti-Corruption: Demanding and Accepting Benefits
B.4 Political Contributions, Charitable Donations and Sponsoring
B.5 Government Procurement
B.6 Anti-Money Laundering
B.7 Trade Compliance
B.8 Working with Suppliers
Avoiding Conflicts of Interest

4
4
5
5
6
6
6
6
7

D.

C.1 Competing with ams OSRAM
C.2 Sideline Activities
C.3 Interests in Third-Party Companies
Handling of Company Property

7
7
7
8

E.

Handling of Information

8F.

E.1 Records and Financial Integrity
E.2 Confidentiality
E.3 Data Protection and Data Security
E.4 Insider Trading Rules
Environment and Climate

8
8
9
9
10

G. Human Rights, Working Conditions, Occupational Health and Safety

10H.

G.1 Human Rights and Working Conditions
G.2 Occupational Health and Safety
Quality and Product Safety

10
11
11

I.

Complaints and Reports

11

J.

Compliance Implementation and Monitoring

12

K.

Further Information and Contacts

12

Introduction
The Code of Conduct (CoC) contains the fundamental principles and rules for the conductof all ams OSRAM 1 employees 2. It defines the ethical and legal framework within which
we act. The Code of Conduct applies to all employees worldwide, both in their dealings
with each other and in their relationships to our external partners and the general public.
Legal provisions and international agreements on human rights, anti-corruption andsustainability form the basis for the Code of Conduct. The Code of Conduct is intended toreinforce and strengthen the awareness of the law and ethics as an integral part of ams
OSRAM’s business activities.
The Code of Conduct is an essential part of our Compliance Management System (CMS).
At ams OSRAM, we understand Compliance as the basis for all business decisions andactivities. Especially preventing corruption and other violations of fair competition is a toppriority for our company. Compliance is not a program, but the way we do business andlive integrity in our everyday business.
A.

Basic Behavioral Requirements
Behavior which Complies with the Law

Observing the law and the legal system in every country where we do business is afundamental principle for us. We comply with all internal guidelines and applicable laws
and regulations of the jurisdictions in which we operate. Violations of the law must be
avoided under all circumstances.
Violations of the law and non-compliance with the Code of Conduct and other internal
guidelines can have serious legal consequences both for our company and for theemployee involved. Irrespective of the sanctions provided by law, every employee must
1
2

The term "ams OSRAM" stands for the ams OSRAM group, i.e., ams-OSRAM AG and all affiliated companies.
The term “employee” refers to employees, managers and members of governing bodies of ams OSRAM and is
not gender-specific.

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expect disciplinary consequences in the event of a violation due to the breach of his or her
contractual duties.
Respect for Human and Personal Rights, Mutual Respect, Honesty and Integrity
We respect the human and personal rights of every individual and in particular the personaldignity and privacy of our employees, business partners and customers. We cooperatewith colleagues and business partners of different ethnic background, culture, religion,age, regardless of disability, skin color, sexual identity, world view and gender. Consistent
with our corporate principles and the labor laws of the countries in which we operate, we
do not tolerate any discrimination based on these characteristics, sexual harassment,
bullying or other personal attacks on individuals. These principles apply to both internal
cooperation and conduct towards external partners. We make decisions about those wework with – including personnel, suppliers, customers and business partners – based only
on appropriate considerations, not on the basis of inappropriate considerations such as
discrimination or coercion.
We are open, honest and stand by our responsibilities. As reliable partners, we only makepromises that we can keep. We expect our employees and business partners to act withintegrity.
Responsibility for the Reputation of ams OSRAM
The reputation of ams OSRAM is essentially shaped by the actions and behavior of eachof us. Unlawful or inappropriate behavior by even one employee can cause considerable
damage to the company.
Every employee is required to pay attention, maintain and promote the good reputation of
ams OSRAM in order to fulfill our social, ecological and societal responsibility as acompany.
Management, Responsibility and Supervision
Integrity and compliance start at the top of the company. All managers must fulfill theirduties of organization and supervision. They bear responsibility for all employees
entrusted to them. They must earn respect through exemplary personal behavior,performance, openness and social competence. This means, among other things, thatmanagers must always emphasize the importance of ethical behavior and compliance withlegal requirements and internal guidelines in day-to-day business, make them regular
topics, and promote them through their personal leadership style and open
communication. Managers must also set clear, ambitious and realistic goals and lead byexample.
Managers should permit their employees as much individual responsibility and leeway as
possible, while making it clear that compliance is always required as a top priority, under
all circumstances. All managers shall also be accessible in case employees wish to raisecompliance concerns, ask questions or discuss a professional or personal problem .
It is the responsibility of all managers to ensure that no violations of the law occur in his
or her respective area of responsibility that could have been prevented by appropriate
supervision. Even if individual tasks are delegated, the manager retains responsibility.
These responsibilities of managers do not relieve employees of their own responsibilities ,though. We must all work together to comply with applicable laws and internal guidelines.
The following list of specific managers' responsibilities is intended to give employees anidea of the guiding and supporting actions they can expect from a manager.
In particular, the following duties apply to managers:•

Managers must carefully select employees based on their personal andprofessional qualifications and suitability. The duty of due care increases with theimportance of the task that the employee must perform (duty to select);

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•

Managers must set the tasks precisely, completely and bindingly, in particularwith regard to compliance with legal provisions and internal guidelines (duty to
instruct);•Managers must ensure that compliance with statutory provisions and internal
guidelines is monitored (duty to monitor);•

Managers must clearly communicate to employees the importance of integrity
and compliance in everyday business. He/she must also communicate that
violations of the law will not be accepted and will result in disciplinary action (dutyto communicate).

B.

Treatment of Business Partners and Third Parties

B.1 Fair Competition and Antitrust Laws
Fair competition is a precondition for free market development and the associated social
benefits. Antitrust law protects free, undistorted and effective competition for the benefitof consumers, companies and society. Agreements that restrict competition, in particularanti-competitive agreements between competitors, are prohibited.
Every employee is obliged to comply with the rules of fair competition. There are certain
types of behavior that can lead to a violation of antitrust law. Employees are therefore notallowed, for example:▪

To discuss with competitors prices, production volumes, capacities, sales, bids,
profits, profit margins, costs, distribution channels or any other parameters that
determine or influence the company’s competitive behavior with the aim ofinducing the competitor to behave similarly;▪

To enter into an agreement with competitors not to compete, to restrict business
relations with specific suppliers, to submit token (non-responsive or overpriced)
bids (“cover pricing”) or to divide up customers, markets or territories;▪

To influence our distributors' resale prices, or attempt to cause them to restrict
exports or imports of our products; and▪

To acquire competitively sensitive information through industrial espionage,
bribery, theft or wiretapping, or knowingly disseminate false information about acompetitor or its products or services.

Antitrust assessments can be difficult, particularly because the applicable rules may varyfrom country to country and from case to case. For example, special antitrust requirements
apply in many places. If you have any questions or are unclear, the colleagues in the Legalor Compliance departments can help.
B.2 Anti-Corruption: Offering and Granting Benefits
We compete fairly for orders with the quality and the price of our innovative products andservices, not by offering improper benefits to others. As a result, no employee may directly
or indirectly offer, promise, grant or authorize the giving of money or anything else of value
to a government official to influence official actions or decisions, or to obtain an improper
benefit. The same applies to a private commercial counterparty in a business transaction
in consideration for an improper benefit.
Any offer, promise, grant or gift must comply with applicable laws and internal guidelines
and must not raise an appearance of bad faith or unsuitableness. This means that no suchoffer, promise, grant or gift may be made if it could reasonably be understood as an effort
to improperly influence a government official or as a bribe to a commercial counterparty to
grant ams OSRAM a business advantage.
The term “government official” is defined broadly to include officials or employees of any
government or other public body, agency or legal entity, at any level, including officers or
employees of state-owned enterprises and public international organizations. It also
includes candidates for political office, political party officials and employees, as well as
political parties.

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In addition, employees may not give money or anything of value indirectly (for example, toa consultant, agent, intermediary, business partner or other third party) if thecircumstances indicate that all or part of may be directly or indirectly passed on•

to a government official to influence official action or obtain an improper benefit;or•to a private commercial counterparty in consideration for an unfair advantage ina business transaction.

Employees responsible for engaging consultants, agents, partners in joint ventures orother business partners must appropriately:•

ensure that those third parties understand and will abide by our anti-corruption
policies or comparable equivalents;•

evaluate the qualifications and reputation of such third parties ; and•include appropriate provisions in agreements and contracts designed to protect
ams OSRAM.

This applies in particular if they have contact with public officials on behalf of ams OSRAM.
Finally, each investment decision made by ams OSRAM – whether it is the purchase of acontrolling interest in a company or a minority interest, or a joint venture arrangement –must be based on a prior compliance check.
B.3 Anti-Corruption: Demanding and Accepting Benefits
Employees are not permitted to use their jobs to solicit, demand, accept, obtain or bepromised benefits. This does not apply to the acceptance of occasional gifts of purely
symbolic value or meals or entertainment reasonable in value that are consistent with local
customs and practices and the company’s internal policies. Any other gifts, meals or
entertainment must be refused.
B.4 Political Contributions, Charitable Donations and Sponsoring
Our company does not make any direct or indirect donations or other contributions topoliticians, political parties or political organizations. It does not maintain any lobbying
offices or employ any corresponding agencies. As a responsible member of society, we
make monetary or product donations for education and science, art and culture, and socialand humanitarian projects. All donations must be transparent. Among other things, thismeans that the identity of the recipient and planned use of the donation must be known.
The reason for and the intended use of the donation must be legally justifiable anddocumented. Donation-like remuneration, i.e. benefits that appear to be granted asremuneration for a service but significantly exceed the value of the actual service, violate
the transparency requirement and are prohibited.
Generally, not permitted are:•Donations to individuals and for-profit organizations;•

Donations to private accounts;•

Donations to organizations whose objectives are incompatible with our corporate
principles; and•Donations that damage the reputation of ams OSRAM.

Sponsorship agreements that provide us with advertising opportunities, as well as
contributions to industry associations or membership fees to organizations that servebusiness interests, are not considered donations.
Sponsoring means any contribution in cash or in kind by ams OSRAM, for an event
organized by a third party, which in return provides the opportunity to promote brands ofthe company, e.g. by using the company logo, by mentioning the company name in the
opening or closing speech, by the participation of a speaker in a panel discussion or byreceiving tickets for the event free of charge.

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All sponsoring activities must be transparent, set forth in the form of a written agreement,
intended for a reputable business purpose, and commensurate with the value offered inreturn by the organizer.
Sponsoring contributions may not be promised, offered or provided in order to gain
unlawful business advantages for ams OSRAM or for other improper purposes.
Sponsorship for events held by individuals or organizations whose objectives areincompatible with our corporate principles or for events that damage the reputation of ams
OSRAM is generally not permitted.
B.5 Government Procurement
Our company competes for contracts from government entities and state-owned
enterprises around the world. In all business dealings and interactions with governments,
we act transparently, honestly and correctly.
We comply with all applicable laws and regulations related to government procurement,
including legislation prohibiting the undue influence of public officials.
B.6 Anti-Money Laundering
Money laundering is the process of disguising the nature and source of money connectedwith criminal activity – such as terrorism, drug trafficking or bribery – by integrating “dirty
money” into the stream of commerce so that it appears legitimate or its t rue source orowner cannot be identified.
It is our stated goal to maintain business relationships only with reputable customers,
consultants and business partners whose business activities are in compliance with legal
regulations and whose financial resources are of legitimate origin . We do not support
money laundering.
All employees are required to strictly comply with anti-money laundering laws and to use
the company's internal procedures designed to detect and prevent suspicious forms of
payment that may indicate money laundering. To avoid problems in this area, the attentionof all employees is required to report suspicious behavior by customers, consultants andbusiness partners. In addition, employees are required to comply with all applicable
record-keeping and accounting requirements for cash and other transactions andcontracts.
B.7 Trade Compliance
We comply with applicable export controls and customs laws and regulations in the
countries where we do business. Export controls generally apply to the transfer of goods,
services, hardware, software or technology across certain national borders, including by
email. Export control laws may be triggered in connection with direct or indirect exports toor imports from sanctioned countries or parties, who, for example, may be designatedbased on national security grounds or because of participation in criminal activit y.
Violations of these laws and regulations may lead to serious penalties, including fines andgovernmental withdrawal of simplified import and export procedures (interruption of
seamless supply chain).
Employees involved in the import and export of goods, services, hardware, software or
technology as described above must follow applicable economic sanctions, export control
and import laws and regulations, as well as all policies and processes required by theirbusiness activities.
B.8 Working with Suppliers
We expect our suppliers to share our values and comply with all applicable laws.
Furthermore, we expect our suppliers to act in accordance with the following principles,
similarly adopted by our company, concerning responsibilities vis-à-vis stakeholders andthe environment:•

Compliance with all applicable laws;

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C.

•

Prohibition of corruption;•

Respect for the human rights of the employees;•

Compliance with laws prohibiting child labor;•

Observance of intellectual property rights;•

Protection of information and data;•

Assumption of responsibility for the health and safety of the employees;•

Compliance with relevant national laws and international standards onenvironmental protection; and•Requiring that these values are also implemented and adhered to in thecompany's own supply chain.
Avoiding Conflicts of Interest

It is the duty of ams OSRAM employees to make business decisions in the best interestof the company and not based on personal interests. Conflicts of interest arise whenemployees pursue their own activities or personal interests at the expense of thecompany’s interests.
Employees must declare any personal interest that may exist in connection with theperformance of their official duties to the respective line manager and responsible HR
department in good time in advance. It is important that all our employees recognize andavoid any conflicts of interest that may arise in the course of their professional activities
from the outset. A conflict may also arise if a close relative acts in this way.
No employee may have private orders carried out by companies with which he/she hasbusiness dealings in the course of his/her work for ams OSRAM if this could result inadvantages for him/her. This applies in particular if the employee has or can have a direct
or indirect influence on the commissioning of the company for ams OSRAM.
Further points of conflict may arise from business relationships with or shareholdings in acompetitor or customer of ams OSRAM, as well as sideline activities of employees thatprevent them from fulfilling their duties for our company in a dutiful manner.
C.1 Competing with ams OSRAM
Employees may not operate or assist a company that competes with ams OSRAM. They
must also not engage in any activities that compete with our company.
C.2 Sideline Activities
Employees may not maintain a side job that competes with ams OSRAM. Before
employees take a side job for remuneration, they must notify the line manager and seek
written permission. Occasional writing activities, lectures, and comparable occasional
activities are excluded. Permission will not be granted if it is detrimental to the interests of
ams OSRAM. Permission may be refused if employees have dealings in the course of
their official duties with the company in question. Previously granted permission may be
revoked on these grounds as well.
C.3 Interests in Third-Party Companies
Employees who directly or indirectly hold or acquire a stake in a competitor company must
notify the responsible HR department if the interest gives them the opportunity to influence
the management of that company. The possibility of influencing the management cangenerally be assumed if the shareholding exceeds a share of 5% of the total capital .
Employees who directly or indirectly hold or acquire an interest in one of our business
partners, or in a company in which ams OSRAM holds an interest, must also notify the
responsible HR department if they are involved with the company in question on official
business or will exercise a mandate in this company. For shareholdings in listedcompanies, this only applies if the shareholding exceeds a share of 5% of the total capital.

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After notification of the participation in third-party companies, ams OSRAM may takeappropriate measures to eliminate a potential conflict of interest.
D.

Handling of Company Property

ams OSRAM has numerous facilities and equipment in its offices and operating rooms ,such as telephones, copiers, computers, software, Internet/Intranet, machines and otherwork equipment such as e-mail and answering systems. These may only be used forcompany purposes and not for personal benefit. Exceptions and payment, if applicable,
may be made on a local basis, provided the use of the facilities:•

is not related to illegal activities;•

does not create a conflict of interest or the appearance of such a conflict ;•does not result in significant additional costs, disruption of business or othernegative impact to the company, e.g. due to a conflict of interest with respect tothe professional duties of the respective employee or other employees .

In no case may information be retrieved or transmitted that supports or incites racial
hatred, glorification of violence or other criminal acts, or has content that is sexually orotherwise offensive against the respective cultural background.
Employees are not permitted to make any recordings, files, images, sounds or
reproductions using company equipment without the consent of the respective manager,
unless this is directly related to the professional activity.
Property rights are very important to us and are part of our corporate resources. We
therefore ensure that our own innovations are protected.
E.

Handling of Information

E.1 Records and Financial Integrity
Open and effective communication requires accurate and truthful reporting. This applies
equally to the relationship with investors, employees, customers and business partners aswell as with the public and all government agencies.
ams OSRAM is also required to ensure, through appropriate processes and controls, thattransactions are conducted only as approved by management. ams OSRAM must also
take preventive measures against the unauthorized use of its property and ensure that
instances of unauthorized use are identified. All employees must ensure that books andrecords prepared by them in the course of their official duties, or otherwise under their
responsibility:•

are complete and accurate;•honestly reflect each transaction or expense; and•are prepared in a timely manner and in accordance with applicable rules andstandards.

This applies whether or not the information is intended for publication or submission to agovernment agency. These books and records include all data, audit certificates and otherwritten documents necessary for financial reporting and compliance with disclosure
requirements, as well as records collected for other purposes. This also includes internal
accounting records (including expense reports).
E.2 Confidentiality
Internal confidential or proprietary information that is not intended to be made public issubject to the requirement of confidentiality. Non-public information from or about
suppliers, customers, employees, agents, consultants and other third parties must also beprotected in accordance with legal and contractual requirements. This applies both tocommunications with competitors and other external third parties, but also to friendly
discussions among colleagues in the context of private occasions.

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Confidential or proprietary information may include, in particular:•

details of a company’s organization and facilities, prices, sales, forecast, profits,markets, customers and other business matters;•

information on manufacturing or research and development; and•internal reporting figures.

The obligation to maintain confidentiality applies beyond the end of the employment
relationship, since the disclosure of confidential information, regardless of when it occurs,
may harm the business of ams OSRAM or its business partners.
E.3 Data Protection and Data Security
Access to the Intranet and Internet, worldwide electronic information exchange anddialogue, and electronic business transactions are all crucial to the effectiveness of eachof us, and for the success of the business. However, the advantages of electronic
communication are associated with risks to personal privacy and data security. Effective
precautions against these risks are an important part of information technology
management, leadership and also the behavior of each individual employee.
Personal data may only be collected, processed, or used insofar as it is necessary fordefined, clear, and lawful purposes. In addition, personal data must be stored securely
and may only be transferred using the necessary precautionary measures. A high standard
must be ensured regarding data quality and technical protection against unauthorizedaccess. The use of the data must be transparent for the data subjects; their rights to
information and, if necessary, to object, block and delete must be safeguarde d.
In some jurisdictions (such as the European Union) there are strict laws and regulations
pertaining to the collection and use of personal data, including data of third parties, suchas customers or business partners. All employees are bound by these applicable laws inorder to protect the personal rights of third parties.
E.4 Insider Trading Rules
Persons who have inside information relating to ams-OSRAM AG and/or to OSRAM Licht
AG, or another company, e.g. a customer, supplier or joint venture partner, whose
securities are admitted to trading on a stock exchange or an organized market, may nottrade in securities or financial instruments of such companies whose price depends
directly or indirectly on the securities of such companies.
Inside information is any specific information about circumstances not known to the publicwhich relates directly or indirectly to one or more issuers or to one or more financial
instruments and which, if it becomes publicly known, is likely to have a significant influenceon the stock exchange or market price of these financial instruments ("price relevance").
Such suitability is given if a reasonable investor would be likely (rather than not) to takethe information into account in making an investment decision.
Inside information may be obtained as a result of an employee’s position andresponsibilities or inadvertently, and comprise, among others, information about:•financial results;•

forecasts, financial plans or budgets;•

dividend changes;•

significant mergers or acquisitions;•investments, divestiments;•

particularly important contract wins or strategic plans;•major developments in litigation;•technical or product developments;

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•

significant changes in management structure, joint ventures and major businessagreements; and•business relationships.

In order to avoid even the appearance of a violation of insider trading rules, those
employees who, due to their job or function, have access to business results or othermaterial information that has not yet been published are generally prohibited from tradingin shares or other securities of ams-OSRAM AG and/or OSRAM Licht AG during the period
from seven trading days before the end of the relevant quarter or fiscal year until two days
after publication of the quarterly, half-yearly, or fiscal year results (blackout period).
A self-imposed, even shorter trading period of three weeks after the end of the blackout
period (i.e. two days after publication of the quarterly, half-yearly, or fiscal year results)
applies to members of the ams OSRAM Management Team (MT) 3. The Supervisory Boardof ams-OSRAM AG has undertaken to comply with this shorter trading period as well.
In the period after the end of a reporting quarter until the publication of quarterly or fiscal
year results, the persons who, due to their activity or function, have access to the businessresults or other material information that has not yet been published, shall be registeredin a separate list that may be submitted upon request by the authorities.
Inside information may not be disclosed or made available to another person withoutauthorization. The disclosure of inside information is unauthorized if it is not made in thenormal course of the insider's work or profession or in the performance of the insider's
duties for the issuer. This applies both to information disclosed within ams OSRAM and to
information disclosed outside our company. This includes journalists, financial analysts,
customers, consultants, family members or friends. Furthermore, employees must always
make sure that insider-relevant information is secured or kept under lock and key in sucha way that unauthorized persons cannot gain access to it.
Persons who have inside information may neither recommend to another person thepurchase or sale of securities for which this information is relevant, nor induce anotherperson to do so in any other way.
Managers can be held personally liable for damages in certain cases if an employee
violates insider trading rules and this violation could have been prevented by appropriate
supervision.
In addition to these rules, further or special insider rules as well as any requirements oflocal law may have to be observed.
F.

Environment and Climate

Protecting the environment and the climate as well as conserving natural resources arehigh priority corporate goals for us. Through appropriate leadership responsibility on thepart of management and the commitment of employees, ams OSRAM aims to make its
business and products environmentally friendly and is constantly working to improve its
eco-balance.
A worldwide environmental management system ensures compliance with the law andsets high standards for this. Accordingly, designing our products to be environmentallyand climate friendly is already a fixed target in their development.
Each employee must contribute to these goals within his or her sphere of influence andthrough his or her own behavior.
G.

Human Rights, Working Conditions, Occupational Health and Safety

G.1 Human Rights and Working Conditions
ams OSRAM is committed to upholding the human rights of its employees and treatingthem with dignity and respect. This applies to all workers, including permanent andtemporary workers, migrant workers, student workers, and all other types of workers . The
following working conditions apply:3

An overview of current MT members is available on the Intranet.

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•

Any form of forced labor, servitude (including bonded labor) or compulsory labor,
involuntary or exploitative prison labor, slave labor or labor based on humantrafficking is not permitted;•

The use of child labor is prohibited at any stage of the manufacturing process ;•Working hours shall not exceed the maximum number of hours applicable underlocal law. In addition, weekly working hours, including overtime, shall generally
not exceed 60 hours. Exceptions include emergencies and exceptional
circumstances. Our goal is for all overtime to be worked voluntarily. Employees
must be granted one day off at least every seven days, provided there are no
emergencies or exceptional circumstances;•

Compensation paid to employees shall comply with all relevant laws concerning
this matter, including laws on minimum wage, overtime and legally establishedsocial benefits;•

In accordance with local laws, the right of all employees to form or join unions of
their choice, to bargain collectively and to hold peaceful assemblies shall be
respected.

Each employee must contribute to these goals within his or her sphere of influence andthrough his or her own behavior.
G.2 Occupational Health and Safety
Protecting the health and safety of employees in their workplace is a high priority for ams
OSRAM. It is the responsibility of every employee to support our company in its efforts tocreate safe working conditions. Every employee must devote his or her constant attention
to occupational safety.
Our company's responsibility towards employees includes adequate protection andappropriate training and precautions against accident hazards, and applies to :•the technical planning of workplaces, facilities, machines and processes;•

safety management; and•personal behavior in everyday work.

The work environment must meet the requirements of a health-oriented design. Housing
accommodations provided for employees must be well-maintained, clean and safe.
Each employee must contribute to these goals within his or her sphere of influence andthrough his or her own behavior.
H.

Quality and Product Safety

ams OSRAM stands for high quality standards, safety and reliability of its products andsolutions. Our global quality management ensures compliance with legal andcorresponding external requirements and at the same time sets correspondingly highinternal standards. Environmentally and climate-friendly design, technical safety andhealth protection are therefore already fixed targets in the development of our products.
Every employee must contribute to these goals within his or her sphere of influence andthrough his or her own behavior.
I.

Complaints and Reports

Any employee may raise a complaint to his or her manager, to the responsible Compliance
Officer, to the responsible HR manager or other person/office designated for this purpose,or vis-à-vis a company employee representative body.
Circumstances that indicate a violation of the Code of Conduct can be reported to the
Head of Compliance, the responsible Compliance Officer, any other employee of theCompliance Organization or via the whistleblowing system “Tell ams OSRAM”.

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It is possible to make a confidential and anonymous report; all reports will be followed up.
If necessary, appropriate corrective measures will be taken.
All documents and other information collected or otherwise obtained in the course ofclarifying a report will be kept confidential to the extent permitted by law. Reprisals against
whistleblowers of any kind will not be tolerated.
J.

Compliance Implementation and Monitoring

In exercising its overall responsibility for the Compliance Management System in thecompany and fulfilling its management, due diligence and supervisory duties, theManagement Board actively promotes the widespread communication of the Code of
Conduct worldwide and ensures its implementation and sustainable anchoring in thecorporate culture through its exemplary behavior ("tone-from-the-top").
The Compliance Organization supports the Management Board in fulfilling its statutory
responsibility and its organizational duty of care for ensuring the appropriate and effective
management of compliance risks in the group.
Compliance with applicable laws, the Code of Conduct, and all other internal guidelines
must be regularly reviewed and ensured in all companies of the ams OSRAM groupworldwide. This is done through internal audits, compliance risk assessments and ongoing
business-related controls.
K.

Further Information and Contacts

Integrity is at the heart of our entrepreneurial activities. The Code of Conduct defines what
integrity means for our business. But it cannot reflect everything that belongs to this topic,
nor can it answer every question. The Compliance Intranet site provides additional
information that add content-related details to the Code of Conduct.
If an employee is not sure about the correct behavior in a particular case, there are manysources of information available to help. In particular, he or she can turn to his or her
manager, his or her responsible Compliance Officer or any other employee of theCompliance Organization.
In addition, if an employee has identified a case of possible misconduct, various channels
are available to report it. Not only the line manager and the employees of the Compliance
Organization are available for this purpose, but also the whistleblowing system “Tell ams
OSRAM”.

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Appendix
Agreements and Recommendations of International Organizations
In addition to the laws and regulations of individual countries, there are some important
agreements and recommendations of international organizations. They are primarily
addressed to the member states, not directly to the individual companies. However, they
are a very significant guidance for the behavior of the employees of an internationallyoperating company. ams OSRAM supports the requirements of these agreements andrecommendations.
Our company therefore expects its employees, suppliers and business partners worldwide
to comply especially with the following guidelines:•

UN Universal Declaration of Human Rights;•

UN Convention Against Corruption;•

ILO (International Labor Organization) Declaration on Fundamental Principles
and Rights at Work;•ILO Tripartite Declaration of Principles concerning Multinational
Enterprises and Social Policy;•

OECD Guidelines for Multinational Enterprises;•

UN Global Compact and the fundamental principles it statutes;•

RBA (Responsible Business Alliance) Code of Conduct.

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