In the context of these social responsibilities, it is also imperative that we abide by applicable laws at all times and wherever we operate, while also respecting fundamental ethical values and behaving in an exemplary manner. These responsibilities must be embraced by each and every one of us, be it our Management Board, our executives or our members of staff.

In order to ensure that these requirements can be met in full, we have drawn up a policy statement for the company as a whole, which has been enshrined in our Code of Conduct. It defines guidelines that can be applied to our day-to-day business activities, in addition to containing mandatory directives and rules of procedure based on specific statutory provisions.

As an integral element of compliance management, the Code of Conduct includes fundamental directives covering all SIMONA business activities in the following areas:

• Acting in conformity with laws

• Product safety and product quality

• Fair competition and anti-trust laws

• Prohibition of corruption

• Conflicts of interest, gifts and invitations

• Occupational health and safety

• Use of company resources

• Confidentiality, protection of intellectual property and data protection

• International trade and prevention of money laundering

• Insider law

• Diversity, equal opportunities and mutual respect

• Human and employee rights

• Environmental responsibility

Compliance with statutory provisions and guidelines on conduct is ensured by applying the principle of prevention, control and sanction.

Preventative measures include internal guidelines and organisational structures aimed at preventing non-compliance (e.g. separation of duties, approval procedures, signatory requirements or the consistent use of the four-eye principle). Legislation relating to insider trading and directors' dealings is also of particular relevance to SIMONA as an exchange-listed company. This also includes professional support offered to our employees by the company-appointed Compliance Officer. Additionally, our compliance system is embedded within SIMONA's risk management. As part of an annual process, compliance risks considered specific to SIMONA are identified, analysed and updated on a systematic basis. If additional risks emerge, appropriate measures for risk management are drawn up and introduced. If required, new guidelines are put in place.

Recurring controls take place as part of Group audits, but also through the mandatory involvement of the Legal department/Compliance Officer in the case of transactions that are susceptible to risk exposure; this includes the issuance of directives. Both controlling bodies assess whether requirements and directives are being met in Germany and abroad. Another key component of control in respect of compliance-related infringements is the possibility of notifying the Compliance Officer (contact details below), in confidence, of potential departures from rules as well as associated risks.

If it is confirmed that the Code of Conduct, laws or internal directives have been contravened, the company will impose sanctions, based either on employment or civil law or even on criminal law.

In order to meet the high standards prescribed by the law and by our directives concerning conduct, SIMONA has appointed a Compliance Officer (CCO). The CCO is the central point of contact for all issues relating to compliance and is responsible for enshrining the aspect of compliance within our corporate culture.

If you have any questions or would like to notify our Compliance Officer with regard to specific issues, please feel free to contact:

Mark Jost
compliance@simona-group.com

All questions, concerns and issues will be taken seriously, processed quickly and treated in the strictest confidence.

If you wish to submit your information anonymously, our Speak-Up Line is available for you.

Information the Act on Corporate Due Diligence Obligations in Supply Chains (Lieferantenkettensorgfaltspflichtengesetz – LkSG) can be found here.

This document is published in German and as an English translation. Only the German original shall be deemed authoritative.