Compliance of H. Gautzsch Firmengruppe

Respecting and strengthening internationally recognised human and environmental rights within its own business areas and its supply chains and complying with legal regulations and internal rules and operating instructions is a top priority for the H. Gautzsch Group of Companies. With our Compliance Management System and our Code of Conduct we create the preconditions for ensuring correct behaviour and integrity among all employees.

Nevertheless, rule violations can never be completely prevented. This can have highly damaging consequences and will not be tolerated. Therefore, it is important that violations are identified at an early stage so that appropriate measures can be taken and potential damage to employees (in the company's own business units and along the supply chain), the company, business partners and the environment can be averted.

In order to learn about violations within the company in good time and to be able to follow up on tips appropriately, the H. Gautsch Group has set up a reporting channel. Employees as well as third parties can use this reporting channel to confidentially or anonymously report indications of violations.

You can report violations by telephone to our external ombudsperson at equeo CompCor GmbH. You can reach them from Mon. - Fri. from 9:00 am - 6:00 pm at the toll-free number +800-5959 3333.

You can contact our internal complaints unit in writing at compliance@gautzsch.de. We would like to point out that the internal complaints unit also preserves your anonymity and that tips can be given in the whistleblower's home language.

Both the ombudsperson and the internal complaints unit are:

• impartial
• independent
• not bound by instructions
• sworn to secrecy
• properly trained
• provided with sufficient time resources

The H. Gauutzsch Group of Companies attaches great importance to presenting the information on the complaint procedure in an understandable and comprehensible manner and to creating the greatest possible transparency about the process. The complaints procedure is therefore available in German, English and Chinese.

Below you will find important information to consider before submitting a report:

When should a report be submitted to the office of the ombudsperson?
An open corporate culture significantly supports a functioning compliance system. If you become aware of a violation or have a reasonable suspicion, we encourage you to file a report.

The complaints procedure is intended to provide any person or group of persons with the opportunity to report relevant complaints or information to the H. Gautzsch Group of Companies.

What may be reported?
Violations of applicable EU law are intended for reporting. This includes, but is not limited to, the following areas of law:

• Product safety
• Road safety
• Environmental protection
• Consumer protection
• Money laundering and tax evasion
• Data protection
• Public procurement

Furthermore, the complaints procedure makes it possible to draw the attention of persons to human rights and environmental risks as well as to violations of human rights or environmental obligations that have arisen as a result of the economic actions of the H. Gautsch Group of Companies in its own business operations or in the supply chain.

What should not be reported?
The established reporting channel is explicitly not intended for complaints or reporting interpersonal differences. Knowingly false, misleading, malicious or abusive reports will also not be tolerated and are not protected. In the event the identity of the reporting person is discovered, sanctions under labour law will be considered in order to also ensure the protection of honest whistleblowers.

What information is required from the reporting person?
Please submit your report as informatively as possible, taking into account the following questions: Who? What? When? How? Where? As a whistleblower, you should also make sure that your information can be understood by persons outside your field of expertise.

Confidential or anonymous?
You decide for yourself whether you want to reveal your identity or not. Communicate what you prefer to the ombudsperson during the interview. In any case, it is ensured that both your identity and your reported information are kept strictly confidential. The responsible office of the ombudsperson of CompCor Compliance Solution GmbH is your neutral and independent point of contact and only transmits names and contact details of whistleblowers with express consent.

What happens after I report?

If the report concerns a violation or suspected violation of human rights or environmental rights, the procedure is as follows:

1. After a complaint or tip is received, the person making the tip-off receives an acknowledgement. This confirmation of receipt will be sent within approximately one week.
2. Throughout the entire procedure, the H. Gautsch Group of Companies will be in contact with the person providing the information, if this is desired and if there is a possibility of contact.
3. In principle, the complaints or tips are first examined centrally to determine whether the reported facts constitute a human rights or environment-related risk or a violation of human rights or environment-related obligations. The system also checks which company or supplier is affected by the notification. The complaint or tip is then passed on to the responsible body, e.g. within the company.
4. The next step is to clarify the facts of the case, which is generally done within three months. 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.
5. The staff involved in the grievance procedure follow up on whether and to what extent the remedial actions are implemented.
6. Furthermore, a proposal for further action will be developed based on the findings of the clarification of the facts.

In the case of indications of violations of applicable EU law, your tip will be checked for plausibility and validity by the ombudsperson. Subsequently, the information for the internal investigation is transmitted to the audit department of the H. Gautzsch Group of Companies.

How are whistleblowers protected from discrimination and reprisals for making a complaint or whistleblowing?

Protecting whistleblowers from being disadvantaged or penalised as a result of complaints or whistleblowing is an important part of our complaints procedure.

The following measures serve to protect the persons providing the information:

• All complaints and tips are only handled by a small group of selected and trained employees.
• All information, such as personal data and other information that allows conclusions to be drawn about the identity of the person providing the information, will be treated confidentially. This also applies after the conclusion of the proceedings.
• Protection against discrimination and reprisals based on a complaint or a tip is contractually established with our suppliers.

In accordance with legal requirements, internal company documentation is kept for seven years and then destroyed.

What happens if my tip turns out to be incorrect in retrospect?
If your tip can be based on a valid suspicion, but subsequently turns out to be untrue, you have acted in accordance with the EU Directive and the LkSG (Supply Chain Act) and do not have to fear any further consequences. However, remember in advance that tips or accusations can have serious consequences for those accused. For this reason, we ask you to use it responsibly.

What happens if my identity is discovered despite my desired anonymity?
Protecting your identity is a top priority. If you submit your tip anonymously, we will not receive any information from the office of the ombudsperson that would allow us to infer your identity. Nevertheless, your identity may be revealed in the course of the investigation. If your report is based on valid evidence, you will still be protected despite the disclosure and will not have to fear any reprisals.

amfori BSCI “Speak for Change”
To protect whistleblowers in the context of human rights violations, we have joined amfori BSCI's "Speak for Change" program. Today, the initiative is accepting tips from the following countries (more to come): Turkey, Vietnam, Bangladesh and India.