Code of Conduct of the Uhlmann enterprise group

U H L M A N N G R O U P | C O D E O F C O N D U C T 5 DEALINGS WITH PEOPLE 1 9 AND THE ENVIRONMENT 6 HANDLING BUSINESS 2 3 INFORMATION AND IT DATA 1 9 5.1 We treat each other with dignity 2 3 6.1 We keep our accounts and and respect records in accordance with 1 9 5.2 We are mindful of environmental regulations protection and use natural resources 2 3 6.2 We consciously work to ensure sparingly and sustainably that business is documented 2 0 5.3 We stand for fair working 2 4 6.3 We protect personal information conditions and secure company information 2 7 2 7 7 RESPONSIBILITY AND SANCTIONS 8 POINTS OF CONTACT FOR THE CODE OF CONDUCT 2 0 5.4 We pay attention to occupational safety, health protection, and fire prevention 2 0 5.5 We stand for constructive relationships with employee representative organizations 03

U H L M A N N G R O U P | C O D E O F C O N D U C T 1 Compliance policy statement OUR DUTIES, OUR VALUES Transparent communication between employees, team As employees of the Uhlmann enterprise group*, members and managers and with our business partners it is our duty every day to provide our customers is necessary to ensure that compliance is effective and across the globe with excellent products, services, sustainable. This enables us to find practical solutions and solutions to support them in achieving their goals. for how to conform with compliance rules and still work In doing so, our conduct as a business is defined by efficiently. Uhlmann therefore expressly encourages all our core values: strength, transparency, reliability. employees to communicate their questions and infor- By living out these values in our everyday work and mation regarding compliance. Employees are to inform actively promoting them, we create a solid basis their manager or the responsible organizational unit of trust with our business partners for a long and without delay regarding violations or suspected viola- successful partnership. OUR OBLIGATIONS tions of compliance rules. It is only through transparent communication and consistent conduct that we can effectively limit compliance risks, avoiding damage to the company. All employees check within their relevant In order to carry out our duties sustainably and areas of responsibility whether business activities con- successfully, we must be reliable. However, we can form with compliance rules. We only conduct business only be reliable if our conduct in our everyday work dealings that also conform with aspects of compliance, is always in conformity with the law, which is why and therefore consistently and appropriately sanction the Uhlmann Group exclusively does business in any violations of compliance rules, which may also compliance with legal framework conditions. This lead to termination of employment. includes the relevant laws, regulations, and guidelines, as well as the specifications and standards applicable Uhlmann requires lawful, responsible, and accountable at Uhlmann (“compliance rules”). All employees of conduct from all employees and business partners the Uhlmann Group must observe the compliance and encourages this conduct through the company- rules. The managers set an example for legally wide compliance management system (CMS). Thanks com pliant conduct, meaning all employees make to the fact that this is constantly undergoing review a signi fi cant contribution to effective compliance the CMS always creates a reliable framework for con- through their behavior. duct in conformity with the rules. * The Uhlmann enterprise group comprises Uhlmann Group Holding GmbH & Co. KG and its direct and indirect subsidiaries. 05

U H L M A N N G R O U P | C O D E O F C O N D U C T 2 Basic principles of the Uhlmann enterprise group Any company can only enjoy success in the long term STRONG, TRANSPARENT, RELIABLE – these three if it has clear basic principles and a strong, reliable value system. The Uhlmann enterprise group has there- fore brought together its experiences from past and characteristics form the core values of the Uhlmann enterprise group and shape our everyday work. Our operational and strategic objectives are designed to be present to form common company principles. Uhlmann in line with these values, which is what our business aims to inspire with its company principles and the partners and employees particularly appreciate about values embodied within them. Uhlmann. Strong Transparent Reliable WE ARE STRONG WHEN:  We inspire our customers.  We recognize the needs of the market with strategic foresight and act accordingly.  We have excellent market presence and penetration. WE ARE TRANSPARENT WHEN:  We look out for ideas and trends, thereby creating momentum for the sector.  Constructive criticism helps us WE ARE RELIABLE WHEN:  Our customers can count on us.  We keep to our commitments.  Our dealings with customers, suppliers and employees are to improve constantly for the collaborative and authentic. benefit of our customers and  Our product range is the bench- employees. mark in the sector.  We are respectful in our dealings  Financial resources allow us to be with other people. independent, provide security, and enable investment required for the future. 3 Binding Code of Conduct We can only live out our basic principles and values if examples and demonstrating the limits of permitted they are built upon a strong, transparent, and reliable conduct. The Uhlmann Code of Conduct is recognized culture of compliance. We therefore require that we as binding by all companies belonging to the Uhlmann ourselves always behave with honesty and integrity in enterprise group. Compliance with the binding Code of our everyday dealings with business partners, em ploy- Conduct is ensured with the help of suitable measures ees, and authorities. The Uhlmann Code of Conduct in all parts of the organization, and its effective im- explains the most important aspects of our under- plementation is regularly reviewed with accordingly standing of honesty and integrity, providing numerous appropriate measures. 07

U H L M A N N G R O U P | C O D E O F C O N D U C T 4 Dealings with business partners and third parties 4.1 We stand for free and fair competition Antitrust laws protect free and effective competition. or sales territories with competitors, we do not share Any violation of antitrust stipulations may have far- information prohibited under antitrust law with com- reaching consequences for the employees con cerned petitors, and we do not coordinate any prohibited and the Uhlmann enterprise group. Possible con- conduct either expressly or de facto, and neither do sequences include fines, damage suits, custodial we take part in anti-competitive boycotts or other sen tences, or reputational damage. The Uhlmann unlawful competitive methods of any kind. enterprise group observes the antitrust laws applicable to it and undertakes to comply strictly with rules We select our business partners in accordance with and regulations for the promotion and protection of legally permitted, objective, and transparent criteria fair competition. on the basis of their services. Checks are carried out meticulously and fairly, and these must be reviewed Therefore, in order to maintain or increase our business by the compliance officer responsible for existing opportunities, we do not collude with competitors to fix restraints on competition before we enter into business prices or terms of sale, we do not divide up customers partnerships. Question Answer During the meeting of the professional association, a manager from our com- petitor starts talking about profit margins, To outsiders, e.g., to a regulatory pricing, and future projects. Do I have to authority, it may give the impression intervene here? that the parti cipants have entered into a tactical agreement regarding pricing. This con versation is inappropriate, which you should indicate. It is best to leave the event immediately and speak to the legal department of the Uhlmann enterprise group. 09

U H L M A N N G R O U P | C O D E O F C O N D U C T 4.1 We stand for free and fair competition Question Answer During a customer call, the end customer keeps showing me offers from different competitors. Am I allowed to use the Yes and no. There is no explicit prohibi - content of the offers in my work? tion against using this information if the customer has told you. However, the risk of allegations that you may have obtained this information illegally is very high. Even if it is difficult, advise the customer that you would not like to know this information, then carefully document the circumstances in which the information was obtained. 4.2 We stand for quality and safety in our products and services The Uhlmann enterprise group defines quality as people improve their lifestyle and must not endanger continuous improvement of all processes in order to the life or health of people at any point. Our production maintain and increase the quality standards achieved. processes must ensure that we comply with the appli- For Uhlmann, quality assurance means observing cable Product Safety Act at all times. We do everything all relevant security regulations and additionally within our power to ensure this. We will not tolerate implementing further provisions to ensure continuous anyone accepting the risk of a violation vis-à-vis appli- improvement. Our products and services are to help cable product safety regulations. 11

U H L M A N N G R O U P | C O D E O F C O N D U C T 4.3 We condemn corruption, bribery, and money laundering Question Answer As part of a FAT, the participating em - ploy ees from the customer’s purchasing department ask Uhlmann to cover the No, you are not allowed to give approval costs for their business class flights, for these costs to be covered. Clarify how to accommodation for seven nights in a proceed with the responsible compliance five-star hotel, two sightseeing tours, and officer. a shopping trip. Am I allowed to give approval for these costs to be covered? What is the correct way for me to react? Question Answer During a supplier visit to a country with a different culture, the sales representative gives me a watch worth several hundred No, you are not allowed to accept the euros. Gifts of this value are normal in watch. Familiarize the gift giver with the this country and are simply understood content of the Uhlmann Code of Conduct. as a show of politeness. Is it therefore OK If it is not possible to refuse the gift, make for me to accept the watch? the gift giver aware that strict customs regulations do not permit you to take the watch to your home country, in all like- lihood. Then inform your superior and the responsible compliance officer immediately about what has happened. If the supplier then sends the gift by post, provide infor- mation in the same way. 13

U H L M A N N G R O U P | C O D E O F C O N D U C T 4.5 We avoid conflicts of interest Personal and private interests must not unduly in- to misuse our employment at Uhlmann in order to fluence our judgment in our everyday work to ensure obtain unjustified personal advantages or advantages no conflicts of interest arise. This is why we always for relatives, loved ones, or friends. We must check maintain separation between business and private carefully for conflicts of interest before we pursue a interests. A conflict of interest arises if our personal secondary occupation. and private interests are contrary to the interests of Uhlmann, which causes divided loyalties that Many actual or potential conflicts of interest can be may regularly have a negative effect on Uhlmann. solved in a reasonable way, for both Uhlmann and As employees of Uhlmann, we must avoid situations the employees concerned. The employees concerned where our personal and private interests may come must contact the responsible office at Uhlmann (e.g., into conflict with those of Uhlmann, or create the the compliance officer, HR department) so that an impression that this is the case. appropriate solution can be found. Employees must Activities of our relatives, loved ones, and friends may avoid situations in which outsiders may gain the lead to conflicts of interest. We do not take part in impression of a conflict of interest, even if this is not decisions which may cause a conflict between our own the intention of the employees concerned. interests and those of Uhlmann. We are not permitted not only avoid actual conflicts of interest, but also Question Answer I am organizing an appropriate venue for a company event. My cousin owns a suitable conference hotel. Am I allowed to include No. There may be exceptional cases him when obtaining suitable offers? where including an offer is permitted for mainly objective reasons. The potential conflict of interest must be transparently declared to your superior before contacting the hotel, and the existence of an excep- tional case must be justified objectively. The decision regarding inclusion is then made by the superior after consultation with the responsible compliance officer. 15

U H L M A N N G R O U P | C O D E O F C O N D U C T 4.7 We respect the property of others We always treat other people’s property that we and other business partners. We do not collect, acquire, obtain from third parties for business purpose use with read, or use intellectual property which is protected by care and exclusively for the intended purpose. This copyright through third parties or only disclosed in a also includes intellectual property. Protection of this limited manner. In cases of doubt, we clarify the state property is particularly important to us, in cluding but of affairs and legal situation with the responsible office not limited to in relation to our customers, suppliers, at Uhlmann in good time before use. Question Answer A customer sends pharmaceutical test products. I determine that not all test products are needed. Am I allowed to use No. Handling pharmaceutical test the excess test products myself or pass pro ducts is subject to very stringent them on to my colleagues? legal requirements. You are not allowed to use such products for anything other than the intended purpose under any circumstances. This also applies if a test product is not required for test purposes. Inform your superior without delay. 17

U H L M A N N G R O U P | C O D E O F C O N D U C T 5 Dealings with people and the environment 5.1 We treat each other with dignity and respect In everything we do, we always respect and expect We do not tolerate discrimination or bullying, nor compliance with human rights and employee rights child labor or forced labor in any form. Rather, we and do everything we can to embody these in the stand for equal treatment of all employees, irrespective value chain. We behave fairly and respectfully in all of ethnic or social background, nationality, gender, our interactions with staff and business partners. age, culture, sexual identity or orientation, physical The UN Guiding Principles on Business and Human and we actively promote equality and equality of Rights is an important point of reference for the opportunity for everyone. features, religion, worldview or political conviction, Uhlmann enterprise group. 5.2 We are mindful of environmental protection and use natural resources sparingly and sustainably We have a comprehensive approach to sustainability possible so that we can make a positive contribution for purposes of compliance with economic, environ- to environmental and climate protection with our mental, and social standards. products and services. This strategy results in a pro- portionate carbon footprint. The Uhlmann enterprise group believes in environ- mental and climate protection, including preservation We constantly strive to prevent or reduce negative and efficient use of resources as another important effects on the climate and environment linked to our goal. All process steps have been designed to have business activities, even if Uhlmann has neither caused as little impact on the environment and climate as nor contributed to these effects. 19

U H L M A N N G R O U P | C O D E O F C O N D U C T 5.5 We stand for constructive relationships with employee representative organizations Question Answer I get the feeling that my department is not observing or is violating national environmental laws. How do I deal with Our company undertakes to comply this? with the law. Please speak to the manager of your department or the responsible offices. Question Answer I have a suspicion that our supplier is paying their employees less than the legal minimum wage. Should I report this? Speak to your manager and the manager responsible for the supplier company about the issue. It is important to us that our suppliers do not exploit their employees and do not act in any way that is unlawful. Question Answer Various team members are always talking about a colleague’s appearance and back- ground and make comments about this. No! Please first talk to your manager, When I talk to them about it, they say your responsible compliance officer or the that it is only a joke and there is no ill will. HR department. You can also be confident Should I accept that? in contacting the Works Council. If the issue is not appropriately handled inter - n ally or you feel that you are not being taken seriously, you can also contact the external, independent trusted lawyer via the whistle-blower system. 21

U H L M A N N G R O U P | C O D E O F C O N D U C T 6 Handling business information and IT data A large proportion of the Uhlmann enterprise group’s to information security and data protection. The information is highly confidential. This is therefore procedure occurs in accordance with the applicable subject to a confidentiality obligation and must be regulations and laws. handled with great care. We pay very close attention 6.1 We keep our accounts and records in accordance with regulations The Uhlmann enterprise group uses the basic princi- ples of bookkeeping and accounting in accordance with regulations and complies with these. This includes but is not limited to the following basic principles:  Completeness  Correctness  Security  Documentation  True and fair representation  Clarity and clearness  Single valuation All relevant data and records are correctly and completely created in good time. 6.2 We consciously work to ensure that business is documented We comply with all laws and statutory provisions our integrity. Any form of deception is an offense and appli cable to us, as well as appropriate technical and is not tolerated in our company. professional standards for storage of documents and files. A stringent monitoring system for finances, When dealing with the tax authorities, we work in a business processes and compliance, and an effective way that is transparent and open to scrutiny, make our risk management system are part of our everyday work. tax strategies and business activity freely accessible to the authorities, and comply in all business matters Deliberately inaccurate representations in business with the tax regulations applicable at Uhlmann. documentation, reports, products, or services affect 23

U H L M A N N G R O U P | C O D E O F C O N D U C T 6.3 We protect personal information and secure company information We classify and process business information in company, which is why it must be protected against accordance with the company regulations. Confidential un authorized use and disclosure using cybersecurity documents or information must not be used outside and IT security. We perform IT security measures with - of the company. Sensitive company information is out delay and do not bypass them. All data-related only allowed to be sent and stored when encrypted. documents and information are stored in such a way When handling company information, we place great that only authorized persons can access it. value on compliance with the basic principles of con- fidential communication. This applies in both official Without authorization, we do not hand over confi- and private spheres, including but not limited to use dential material or material protected by copyright, of social media. business secrets or software to third parties. At the same time, we are not allowed to receive documents, Our technologies, intellectual property, and sensitive materials, or software if we do not have express business information are crucial resources for our authorization from the appropriate office. Question Answer A former team member has become self-employed. This person has asked me to send them the names and addresses No. This is personal data, which is subject (including company e-mail addresses) to data protection and must not be given of my team members for marketing out to third parties. Any violation may purposes. Is that permitted? have legal consequences for you and/or the company. Question Answer In my department, measures to protect company data and information keep being neglected. What should I do? Security measures must never be bypassed or neglected at any point. Contact your manager. If your manager cannot help or cannot solve the problem, contact the next highest level of management or the Information Security Officer (ISO). 25

U H L M A N N G R O U P | C O D E O F C O N D U C T 7 Responsibility and sanctions The content of this Code of Conduct is essential for are responsible for compliance with the Code of the corporate activities of the Uhlmann enterprise Conduct. Violations of the content of this Code of group. Uhlmann therefore expressly makes employees Conduct are sanctioned proportionately and may and business partners aware of the binding nature of lead to termination of employment. compliance with this Code of Conduct. The employees 8 Points of contact for the Code of Conduct QUESTIONS If Uhlmann employees do not want to contact the Employees have the opportunity to ask questions aforementioned points of contact, they also have the regarding observance and correct implementation of option of con tacting the trusted lawyer, Dr. Carsten Thiel the Code of Conduct. Superiors and offices responsible von Herff in writing (e-mail, letter, fax), by telephone for compliance are available for this purpose. The or in person, at any time: contact details of the compliance officers can be found via the established communication channels in Dr. Carsten Thiel von Herff, LL.M. the company. INFORMATION Loebellstraße 4 33602 Bielefeld Germany All employees are urged to report violations or suspicions of violations immediately. The Uhlmann Phone +49 521 557 333-0 enterprise group ensures that there are no disadvan- Fax +49 521 557 333-44 tages for persons who report violations or suspicions Mobile +49 151 582 303 21 of violations to the responsible offices. [email protected] www.report-tvh.de The following institutions or groups are named as points of contact for the aforementioned topics:  The Group Management Board  Managers  Employees with compliance roles (all compliance officers) and those in the legal department Laupheim, January 20, 2022 UHLMANN GROUP HOLDING GMBH & CO. KG Tobias Uhlmann Prof. Dr.-Ing. Matthias Niemeyer Chair of the Supervisory Board CEO 27