Rules of Procedureon the complaints procedure pursuant to § 8 of theGerman Act on Corporate Due Diligence
Obligations in Supply Chains (LkSG)

These Rules of Procedure contain the mandatory legal
requirements for the complaints procedure pursuant to the LkSG
and are based on the Handout "Complaints Procedure pursuant tothe Act on Corporate Due Diligence Obligations in Supply Chains”,
published by the German Federal Office of Economics and Export
Control (BAFA).
These rules of procedure apply to the ams OSRAM group, i.e., toams-OSRAM AG and all its affiliated companies.

Issuer:ams OSRAM Compliance Organization
Geographical validity:
GlobalValid from:2023-01-01

Table of Contents:
1. Background and purpose of the complaints procedure2

2. Who can file a complaint or report?

3

3. What exactly can I report?

3

4. What information should a complaint/ report contain?

4

5. Do I have to disclose my name in my complaint/ report?

4

6. What channels can I use to submit complaints/ reports?

4

7. Who will take care of my complaint/ report?

5

8. How will my complaint/ report be handled internally at ams OSRAM?

6

9. How long can it take for my complaint/report to be fully processed?

7

10. Is the complaint procedure free of charge for me?

7

11. What are the procedural principles and internal guidelines for the complaints procedure?

7

12. Is it ensured that my complaint/ report will be treated confidentially?

8

13. How else is my personal data protected?

8

14. As a whistleblower, am I protected from discrimination and reprisals?

8

15. Who are my contacts for questions about the complaints procedure?

9

16. Closing words: Thank you very much for your support!

9Note: When referring to persons or group of persons in this document, persons of any gender are meant in the following for li nguistic
simplification and better readability. The term "employees" also includes managers at all levels and members of executive bodies.

1.

Background and purpose of the complaints procedure

As part of our corporate activities, we are fully committed to our social responsibility
and, as a globally operating group, take human rights, environmental protection,
integrity, and compliant behavior within the company and along our supply chainsvery seriously. Accordingly, fulfilling human rights and environmental due diligenceobligations is also a top priority for ams OSRAM 1. This includes ensuring fair, safe,and healthy working conditions both in our own business and in our global supplychain.
On January 1, 2023, the Act on Corporate Due Diligence to Prevent Human Right
Violations in Supply Chains (The Act on Corporate Due Diligence Obligations in
Supply Chains, hereinafter LkSG) came into force. The aim of the Act is to improve
the protection of human rights and the environment in companies' own business
operations and along their supply chains. To this end, the law imposes several due
diligence obligations on the companies concerned.
Among other things, the LkSG requires that companies have an adequate andeffective complaints procedure through which both internal (i.e., employees) andexternal persons (such as suppliers) can report human rights and environmental
risks or violations both in their own business operations and along their supply
chains.
Compliance with the LkSG is a top priority for ams OSRAM. Accordingly, we haveestablished an effective complaints procedure through which notifications of humanrights and environmental risks or violations can be made. The ams OSRAM
complaints procedure is an important part of upholding our corporate values and1The term “ams OSRAM” refers to ams OSRAM group, i.e. ams-OSRAM AG and all affiliated companies.

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commitments and serves to learn of potential grievances and remedy them asquickly as possible.
These rules of procedure provide information on the main features of the complaints
procedure, access to the procedure or how to reach it, and responsibilities.
Furthermore, it also provides information on what happens with incoming notices
and complaints and how to reach a solution for reported grievances. It is important
for ams OSRAM to present this information in an understandable andcomprehensible way and to create the greatest possible transparency about theprocess.
2. Who can file a complaint or report?
All persons or groups of persons who are potentially affected by human rights orenvironmental risks or violations in their own business area or within the ams
OSRAM supply chain, or who are aware of such abuses, can submit information via
the complaints procedure. Thus, our complaints procedure is open to both ams
OSRAM employees and external parties (directly or indirectly affected). This
includes, for example:• Employees of indirect and direct suppliers;• Business partners, e.g. customers;• Trade unions, non-governmental organizations;• other third parties, e.g., residents of local sites.
To report, a person does not have to be affected by the risk or violation himself;
external observers can also submit a report.
3. What exactly can I report?
The complaints procedure can be used to report all indications of possible humanrights or environmental risks or violations that have arisen as a result of ams
OSRAM's economic activities in its own business operations or in the supply chain.
Human rights risks and violations include in particular:• Child labor;• Forced labor and slavery;• Working conditions that are hazardous to health / disregard for occupational
health and safety;• Disregard for freedom of association, freedom of association and the right tocollective bargaining;• Discrimination and unequal treatment in the workplace;• Withholding of a fair wage;• Unlawful evictions or the unlawful deprivation of land;• Unlawful use of private or public security forces;• Pollution of water, soil, and air that may contribute to human rights violations.
Environmental risks and violations specifically include:• Use of mercury (under the Minamata Convention);• Use of persistent organic pollutants / POPs (as per Stockholm Convention);• Non-environmentally sound storage, handling, import and export ofhazardous waste (according to the Basel Convention).
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4. What information should a complaint/ report contain?
In order for a complaint/ report to be handled appropriately, it is important that it isas specific as possible. Information on the following five questions is helpful:
••
•
•
•

Who? - Who is it about? Who is affected?
What happened? Description of the facts (the more detailed, the better).
When? - When did the incident occur? Is the violation still ongoing?
How? - How many times did it happen?
Where? - Where did the incident occur?

The above information will facilitate and expedite the proper processing of a report.
However, it is not a requirement for processing that the report contain informationon all of the above.
5. Do I have to disclose my name in my complaint/ report?
No, you can also submit your complaint/ report without stating your name. However,
the more information you provide, the better we can investigate and remedy thesituation. Often, being open and transparent about the complaint (including
disclosing your name) helps resolve the issue. However, the decision whether todisclose your name rests solely with you as the person providing the information.
6. What channels can I use to submit complaints/ reports?
To ensure that the complaint procedure is accessible to any person, ams OSRAM
has created various reporting channels for submitting complaints or notices:a. Tell ams OSRAM whistleblowing system (https://www.bkms-system.net/TellamsOSRAM)
Our main reporting channel, Tell ams OSRAM, is a group-wide electronic
whistleblowing system through which you can submit complaints or reports ina web form. It is managed by an independent operator in compliance withstrict European data protection regulations. The web link to Tell ams OSRAM
can be accessed from any computer or mobile device with an internet
connection and is available around the clock in various languages. The useof Tell ams OSRAM is of course free of charge for you as a whistleblower.
When submitting your complaint/ report via Tell ams OSRAM, you can remaincompletely anonymous if you wish. In addition, Tell ams OSRAM allows you
to set up a secure mailbox through which you can communicate with us
securely and, if you wish, anonymously throughout the entire process.
Qualified compliance personnel will take care of you report and assign it tothe respective responsible department.
b. Email to the following central corporate offices:• ams OSRAM Compliance Organization: compliance@ams-osram.com• ams OSRAM Human Resources Organization: humanrights@amsosram.com• ams OSRAM EHS Organization: environment@ams-osram.com

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•

ams OSRAM Procurement
management@ams-osram.com

Excellence

Organization:

supplier-c. Postal letter to the ams OSRAM Compliance Organization at the following
postal address:
Marcel-Breuer-Strasse 480807 Munich
Germanyd. For ams OSRAM employees: respective line manager and the local HumanRights Coordinator
7. Who will take care of my complaint/ report?
To ensure the best possible processing of reports of potential grievances, experts
from various internal company functions are involved, in particular due to the sizeand complexity of the ams OSRAM group and the processes along our supply chain:•All reports of human rights and environmental risks and violations received
via "Tell ams OSRAM" are first reviewed by the Compliance Organization andchecked for their plausibility. Depending on the main topic, the report is thenassigned to the relevant department for further processing/ investigation tothe respective responsible department:- ams OSRAM Human Resources Organization - for reports on humanrights-related risks and violations affecting the ams OSRAM workforce;- ams OSRAM EHS Organization - for reports on environment-related risks
and violations affecting ams OSRAM's own business;- ams OSRAM Procurement Excellence Organization - for reports on humanrights and environment-related risks and violations affecting ams OSRAM
suppliers.

•Complaints and information reported directly to the responsible HR, EHS orPurchasing department are processed directly by the respective responsible
company department.

In any case, the processing of the information (including all necessary measures
within the scope of the clarification of the facts as well as the development ofremedial measures) is carried out according to a strict geographical responsibility
criterion: Reports may only be seen and processed by the employees of the abovementioned departments who are responsible for the country / ams OSRAM locationin question (in the sense of the "need-to-know principle").
All employees of the above departments are impartial, independent in theperformance of their duties and bound to secrecy. Furthermore, they are obliged tocomply with data protection regulations and to ensure transparency and the rights
of all people concerned.

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8. How will my complaint/ report be handled internally at ams OSRAM?
Receipt of thereport

Check ofthe report

Clarificationof the facts

Developing
a solution

Remedialmeasures

Review &Closure

The processing of all incoming reports follows a structured process that includes thefollowing main steps:
I. Acknowledgement of receipt of your report
Depending on the reporting channel selected, receipt of your report will be confirmedin writing or electronically, unless you have provided us with your contact
information. This will take place no later than seven days after we receive yourreport.
II. Checking your report
The content of the report is then checked for plausibility and validity by the relevant
departments. In particular, it will be checked whether there are sufficient indications
from the report that human rights or environmental risks have occurred or could
occur. In this context, it is also checked what ams OSRAM company or what supplieris affected by the report.
Furthermore, it is checked whether sufficient information is available for furtherprocessing. If this is not the case, we will contact you (if possible) or otherwise try toobtain the missing information. If this is not possible despite all efforts, we wi ll not
pursue your report any further and will inform you of this, stating an appropriate
reason. This will be documented accordingly.
The report will then be passed on to the responsible office for further processing.
III. Clarification of the facts
If the procedure continues, the reported facts will be discussed and examined withyou as the person providing the information. Optionally, a procedure for the amicablesettlement of disputes may be suggested. In this step, the respective responsible
department will take necessary measures to clarify the facts reported by you, suchas internal interviews/ discussions, review of documents and/or production facilities,etc.
IV. Developing a solution
A proposal for a solution is drawn up on the basis of the facts ascertained. This will
be discussed with you if you yourself are affected as the person providing theinformation. We will endeavor to involve you as much as possible in the developmentof a solution.

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V. Remedial measures
If, in the course of clarifying the facts, it is determined that a violation of human rights
and/or environmental obligations is imminent or already taking place, remedial
measures are initiated without delay. These include, for example, supplier
discussions to develop a concept for ending or minimizing the violation, as well aspersonnel measures, adjustments to processes and even the termination ofbusiness relationships. If remedial measures have been agreed, theirimplementation is consistently followed up.
VI. Review of the remedy and conclusion of the process
Together with you, the implementation of the proposed solution and the remedial
measures is reviewed, and the outcome of the procedure is evaluated. In particular,
this also involves your satisfaction with the process and outcome of the procedure.
If the risk or violation has been sufficiently eliminated, the interim report becomesthe final report, and the procedure is closed.
9. How long can it take for my complaint/report to be fully processed?
Depending on the scope and complexity of the matter, the proper investigation of acomplaint/ report can take a few days or weeks, but sometimes several months. Asa matter of principle, we make every effort to process all incoming reports andcomplaints quickly and without culpable delay. At the same time, we make sure thatyou, as the person providing the information, are given sufficient time to respond toqueries and explain relevant aspects as part of the fact-finding process. In addition,
we always endeavor to keep you informed of the measures taken and the further
course of action.
10. Is the complaint procedure free of charge for me?
Yes, you as a whistleblower may use the complaints procedure described in theseRules of Procedure free of charge. However, ams OSRAM shall not be liable for any
costs and expenses incurred by you in connection with the use of the complaints
procedure; in particular, no travel expenses or costs for legal advice shall be borneby ams OSRAM.
11. What are the procedural principles and internal guidelines for thecomplaints procedure?
ams OSRAM strives to investigate all information and complaints in a fair, balanced
and transparent manner and to resolve them as efficiently and effectively as
possible. Uniform processes as well as confidential and professional handling ofreports by internal experts form the foundation of the complaints procedure.
In detail, the following applies:
I. Objectivity and presumption of innocence
All information and complaints are handled neutrally, objectively, appropriately andwith due regard for the presumption of innocence. Just as clues that incriminate
suspects are investigated, so are those that may exonerate them.

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II. Compliance with the principle of proportionality and the right to be heard
All fact-finding measures must comply with the principle of proportionality, i.e. theymust be suitable, necessary and appropriate to fulfill their purpose. Accused persons
must be treated fairly and with respect, and the right to be heard must be granted.
III. Confidentiality principle
The confidentiality of information obtained, especially personal data, must beguaranteed. This information may only be disclosed by applying the "need-to-knowprinciple". For more on this, see section 13 below.
IV. Compliance with data protection
Compliance with applicable law and internal policies regarding the protection ofprivacy and the collection of personal data must be ensured. In cases of doubt andthose defined in this process, the responsible data protection officer must beconsulted.
V. Involvement of the person providing the information
As the person providing the information, you will always be informed about theprocessing of your complaint/report and the outcome of the individual proceduralsteps. The greatest possible transparency towards you will be strived for.
VI. Avoidance of conflicts of interest
ams OSRAM employees who are responsible for processing your complaint/ reportmust avoid actual or impending conflicts of interest or identify and report them at an
early stage. They must maintain their impartiality throughout the complaint process.
VII. Participation rights
Insofar as employee representatives have participation rights during the processingof complaints, the necessary department will be involved in this respect.
12. Is it ensured that my complaint/ report will be treated confidentially?
Regardless of which reporting channel you have chosen, we will of course treat yourcomplaint/ report confidentially. Confidential data may only be passed on if this isnecessary and legally permissible.
13. How else is my personal data protected?
Your personal data will only be processed with your consent and solely for thepurpose of processing your complaint/ report. The complaint investigation will beconducted in accordance with the European General Data Protection Regulation(GDPR), including the storage and deletion of data and the regulations on
international data transfer.
14. As a whistleblower, am I protected from discrimination and reprisals?
Protecting whistleblowers from retaliation for filing complaints or reports is an
important part of our complaint procedure.
ams OSRAM prohibits any form of retaliation or other adverse treatment (inparticular intimidation, hostility, punishment, labor law measures, etc.) against
persons who have filed a complaint with us to the best of their knowledge and belief.
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It does not matter whether the complaint ultimately turns out to be well-founded or
unfounded.
If you believe that you or any other person has been retaliated against or that you orsuch person has been disadvantaged in any way because of filing a report, please
immediately inform the corporate department responsible for your complaint or theams OSRAM Compliance Organization (see section 7 above).
We will investigate the situation and take appropriate action if necessary. We will
investigate all plausible allegations of discrimination. Substantiated allegations ofdiscrimination constitute a compliance violation and will be punished accordingly as
serious misconduct, which is also enshrined in the ams OSRAM Code of Conduct.
15. Who are my contacts for questions about the complaints procedure?
Central responsibility for the complaint procedure described here and primarycontact for questions or comments is as follows:
OSRAM GmbH
Compliance Organization
Marcel-Breuer-Strasse 480807 Munich, Germany
E-mail: compliance@ams-osram.com
We also recommend that you use the option of communicating via our whistleblower
system “Tell ams OSRAM” to address questions or comments directly to theresponsible corporate department.
16. Closing words: Thank you very much for your support!
For ams OSRAM, human rights and environmental protection have a high priority even before the introduction of The Act on Corporate Due Diligence Obligations inSupply Chains. With your reports you support us in protecting human rights and theenvironment sustainably and efficiently. Thank you for your support!

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