Stahl Parent B.V.
BUSINESS PARTNER
CODE OF CONDUCTFebruary 2024

1. Introduction
STAHL is committed to the highest standards of social and environmental responsibility and ethical conduct
as described in the Stahl Parent B.V. (“STAHL”) Code of Conduct. STAHL requires its business partners tocomply with or demonstrate equivalent policies and standards and to operate in accordance with theprinciples in this Code of Conduct (‘Code’) and in full compliance with all applicable laws and regulations.
STAHL expects suppliers and/or business partners to use a proactive approach in establishing andmaintaining the standards set forth in this Code and to conduct themselves with responsibility and integrity.
The business partner is obliged to agree to the conditions in this Code and acknowledge that any deviations
found can have an adverse effect on the relationship with STAHL, including an immediate discontinuation of
the business relationship. The business partner commits, upon signing this Code, to all applicable legislation
and regulations. This Code therefore forms an integral part of the agreement between the business partnerand STAHL. To verify compliance with the Code, STAHL shall consult periodically with the business partner
either directly or through independent verification systems such as Ecovadis. STAHL has the right to speakwith and train business partner employees directly in order to fully comply with the Code. When appropriate,STAHL can request an audit be conducted by a third party to be appointed by STAHL. The Code obliges thebusiness partner to fully cooperate in this investigation.
STAHL expects its business partners to comply with the UN Global Compact Guiding Principles (see annex)
on human rights, labour, the environment, and anti-corruption and emphasizes the following specific areasof interest.

2. Ethical Behaviour & Integrity
REGULATIONS: The business partner operates in full compliance with international, national, and domestic
laws and regulations applicable to their business operations, and to obtain all necessary permits.
BUSINESS INTEGRITY: Stahl applies a zero-tolerance towards corruption. The business partner shall not
engage in any form of corruption, extortion, embezzlement, or bribery to obtain an unfair or improper
advantage. The business partner shall abide by all applicable anti-corruption laws and regulations of thecountries in which it operates including all applicable international anti-corruption conventions. Stahl does notcontribute to any form of ‘tied selling’ or ‘tying’, initiated by a media outlet.1
FREE AND FAIR COMPETITION: STAHL behaves openly and fairly in the marketplace. The business
partner must value free and fair competition throughout the world and comply with anti-trust and competitionlaws.

1 Tying exists among others when a media outlet makes the publication of an editorial article of a customer of the supplierdependent on the advertising purchase by (among others) this supplier.

Stahl | Business Partner Code of Conduct| For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend,
update or withdraw its corporate policies without prior notice. Version: February 2024.

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CONFIDENTIALITY: The business partner protects all confidential information provided by STAHL and its
respective business partners.
PROTECTION OF INTELLECTUAL PROPERTY: The business partner shall respect intellectual property
rights and safeguard customer information. The business partner shall manage technology and know-how ina manner that protects intellectual property rights.

3. Environment
Stahl is committed to protecting the environment, and environmental responsibility is at the core of how weoperate. The business partner shall develop, implement, and maintain environmentally responsible businesspractices. The business partner shall respect the environment and comply with all (supra) nationalenvironmental, health and safety legislation and regulations. The business partner shall conduct its businessprocesses in such a manner that compliance is guaranteed.
In addition to legislative requirements, Stahl strongly encourages its business partners to support andpromote good practices and high standards of environmental stewardship, in order to collectively reduce
environmental footprint, fight climate change and achieve more transparency in our supply chains. Chemicalcompliance initiatives like bluesign® or the Zero Discharge of Hazardous Chemicals (ZDHC) are examplesof initiatives and standards to which Stahl encourages its business partners to be aligned, when relevant.
The Renewable Carbon Initiative, which promotes de-fossilization in the chemical industry, is another. Themeasurement of environmental impact, using universally accepted methodology like Life Cycle Assessment(LCA), is also considered to be good practice. Stahl encourages its partners to use LCA to estimate theimpact of their products on the environment.

4. Social
HUMAN RIGHTS: The business partner shall conduct their activities in a manner that respects human rights
as per The United Nations Universal Declaration of Human Rights.
DISCRIMINATION: The business partner shall unconditionally respect all anti-discrimination conditions in(supra) national legislation and regulations.
MODERN SLAVERY: Modern slavery, or any form of forced or compulsory labour, is a violation of humanrights. Stahl takes a strong stance against modern slavery and works to ensure high labour rights standards.
Stahl condemns any form of modern slavery and child labour, and shall not participate in the trafficking,recruitment, or receipt of any persons, by means of threat or abuse of power. Stahl allows employees toresign from their position at any time. By behaving ethically and honestly with all its partners, Stahl iscommitted to ensuring that modern slavery does not occur elsewhere and strives only to do business withorganizations who uphold similar principles.
WORKING HOURS: The business partner shall not force their employees to work excessive hours and shallcomply with all (supra) national legislation and regulations concerning labour and labour conditions. In case
employees are asked to work overtime, their extra work is compensated in line with local legislation.
CHILD AND FORCED LABOUR: The business partner shall respect all (supra) national legislation andregulations applying to child labour in line with Convention 138 (Minimum Age) and Convention 182 (WorstStahl | Business Partner Code of Conduct| For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend,
update or withdraw its corporate policies without prior notice. Version: February 2024.

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forms of Child Labour) of the International Labour Organisation. The business partner shall not use work thatis performed involuntarily under threat of penalty.
HEALTH AND SAFETY: The business partner shall implement strict policies with the aim of creating anincident and injury free work environment. At all levels, the business partner will play an active role inidentifying and rectifying unsafe (health) situations.

5. GovernanceThe business partner’s highest governance body (e.g. the board of directors) is ultimately responsible foradherence to this Code and for compliance to relevant governance codes and guidelines. This body should
also be transparent about the corporate governance structure of their organization and provide, whenneeded, sound reasons for any non-compliance to this Code (using the ‘comply or explain’ principle).
‘Governance is the systems and processes that ensure the overall effectiveness of an entity – whether abusiness, government or multilateral institution.’ - United Nations‘Good corporate governance helps to build an environment of trust, transparency and accountability
necessary for fostering long-term investment, financial stability and business integrity, thereby supportingstronger growth and more inclusive societies.’ – OECD

6. Grievances & Whistleblower Policy
Grievances and/or suspension of non-compliance to this code can be expressed through Stahl’s
whistleblower communications line: whistleblower@stahl.com or reported through the internet form which
can be found on Stahl’s website (see https://www.stahl.com/sustainable-development/policies-statementsreports/policies-statements).

Stahl | Business Partner Code of Conduct| For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend,
update or withdraw its corporate policies without prior notice. Version: February 2024.

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SIGNATURE FOR COMPLIANCE
Business partner CoC

Organization:
Name:
Title:
Place and date:
Signature:

ANNEX: UN GLOBAL COMPACT 10 PRINCIPLESSTAHL expects its business partner to comply with the UN Global Compact Guiding 10 Principles in
the areas of human rights, labour, the environment, and anti-corruption and wishes to emphasize thefollowing specific areas of interest.

Ten principles of the UN Global Compact in the areas of Human Rights, Labor, Environment and Anti-Corruption
Principle 1:

Support and respect the protection of internationally proclaimed human rights.

Principle 2:

Ensure that business practices are not complicit in human rights abuses.

Principle 3:

Uphold the freedom of association and the effective recognition of the right to collective bargaining.

Principle 4:Eliminate all forms of forced and compulsory labor.

Principle 5:

Abolish child labor.

Principle 6:

Eliminate discrimination in employment and occupation.

Principle 7:

Adopt a precautionary approach to environmental challenges.

Principle 8:

Conduct environmentally responsible activities.

Principle 9:

Encourage the development and diffusion of environmentally friendly technologies.

Principle 10:Fight corruption in all its forms including extortion and bribery.

Stahl | Business Partner Code of Conduct| For Stahl Parent B.V. and affiliated companies internal use only. Stahl Parent B.V. reserves the right to amend,
update or withdraw its corporate policies without prior notice. Version: February 2024.

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