1. Foreword

Vitrulan is of the firm conviction that it can grow sustainably and find solutions for the challenges of the future through its commitment to ethical, lawful and socially responsible corporate governance.

We also expect this conduct from all those with whom we maintain business relationships.

The Vitrulan Code of Conduct for Suppliers and Service Providers (hereinafter "Code") describes the essential requirements expected of our suppliers and service providers with regard to compliance with laws and regulations, corruption and bribery, problematic resources, social and labour conditions, child labour and the environment.

2. Compliance with laws and regulations

Vitrulan expects its suppliers to comply with applicable national and international laws and regulations, including the standards of the International Labour Organization (ILO) and the United Nations Universal Declaration of Human Rights and all other relevant legal provisions.

3. Compliance and integrity

Vitrulan expects its suppliers to comply with all applicable national laws and regulations regarding corruption, bribery, fraud and prohibited business practices.

3.1 Prevention of bribery

The Supplier shall ensure that its employees and subcontractors do not offer, promise or grant Vitrulan employees any advantages that are intended to obtain an order or other preferential treatment in business dealings. Invitations and gifts to Vitrulan employees or their related parties are only granted if they are of insignificant financial value and in line with customary business practices. Equally, the Supplier may not demand any inappropriate advantages from Vitrulan employees.

3.2 Fair competition

Vitrulan expects its supplier to behave fairly in competition and to comply with the applicable antitrust laws. The supplier does not participate in agreements with competitors that violate antitrust law, nor does it abuse any dominant market positions that may exist.

3.3 Money laundering

The supplier does not participate in money laundering activities and complies with the relevant legal obligations to prevent money laundering.

3.4 Intellectual property

The supplier handles business correspondence with utmost confidentiality. Confidential information, any kind of data worthy of protection and Vitrulan's intellectual property rights are properly secured in accordance with the relevant legal requirements.

4. Social and labour conditions | Human rights

Vitrulan expects its suppliers to recognise the fundamental rights of their workers and to commit to respecting them and treating workers with dignity and respect as understood by the international community. Suppliers shall comply with the following provisions, in particular:

4.1 Free choice of employment

All employment is voluntary. Forced labour, forced prison labour, forced conscription of labour or human trafficking is strictly prohibited.

4.2 No child labour

The use of child labour is strictly prohibited.

4.3 Remuneration and benefits

All applicable national laws, regulations on remuneration and benefits must be complied with. Deductions from benefits as a disciplinary measure are not permitted.

4.4 Working hours and wages

All applicable national laws, regulations on working hours and minimum wages must be complied with. If there is no applicable minimum wage law, the appropriate wage is determined according to the laws applicable at the place of employment.

4.5 No discrimination

The Supplier shall comply with all applicable national laws prohibiting discrimination in hiring and employment on the basis of race, colour, nationality, disability, physical condition, sexual orientation, medical condition, political affiliation, gender, age, appearance or membership in associations.

4.6 Freedom of association

The supplier recognises the right to freedom of association within the respective legally permissible framework.

4.7 Health and safety

The supplier must provide its employees with safe and healthy workplaces in compliance with all applicable national laws and regulations.

5. Ecological sustainability and environmental protection

Vitrulan expects its suppliers to comply with all applicable national laws and regulations as well as internationally recognised standards for the protection of the environment.

5.1 Environmental permits and authorisations

The supplier shall ensure that all necessary environmental permits and authorisations are obtained, kept up to date and complied with in order to act in accordance with the law at all times.

5.2 Resource consumption, avoidance of environmental pollution and waste minimisation

The supplier undertakes to optimise the consumption of natural resources, including energy and water. This also includes the prevention of harmful changes to the soil, water pollution, air pollution, harmful noise emissions and excessive water consumption. Proper measures are taken to prevent pollution and minimise the generation of waste, sewage and air emissions. Sewage and waste is appropriately labelled and treated prior to discharge or disposal in accordance with the applicable laws and regulations.

The supplier undertakes to label hazardous materials, chemicals and substances and to ensure their safe handling, movement, storage, recycling, reuse and disposal. All applicable laws and regulations regarding hazardous materials, chemicals and substances must be strictly adhered to. Substance restrictions stipulated by applicable laws and regulations must be complied with.

6. Supply chain

Integrity, transparency and trust are of great importance in everything we do and are deeply rooted in all our business relationships. As part of our supply chain, we encourage our suppliers to anonymously report violations of the Code of Conduct or other non-compliant behaviour via the complaints management system on our website. We expect our suppliers to share this commitment and to make reasonable efforts to promote compliance with the principles of this Code among their own suppliers and subcontractors.

7. Revision of the Code

Vitrulan will review this Code on a regular basis. The current version of the Code can be found at the following address on the Vitrulan homepage: www.vitrulan.com/coc

8. Monitoring and enforcement

a.) The supplier shall execute appropriate internal inspections.

b.) In the event of violations of the Supplier Code of Conduct, the supplier shall take appropriate measures to remedy the situation, including the implementation of corrective measures and, if necessary, the termination of the cooperation.

9. Scope of application

This Supplier Code of Conduct is a binding and integral part of the business relationship with Vitrulan.

Marktschorgast, 1/08/24

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