Code of Conduct

2 Basic Requirements for Supervisors and Managers

Supervisors and managers have the following basic responsibilities:

• Lead by example and embody the highest standards of lawful, ethically integral, socially responsible, and environmentally conscious business conduct.
• Take the time to ensure that the Employees under your supervision understand how to apply the Code and where they can seek further assistance.
• Contribute to creating a work environment that fosters the development of trustful relationships, recognizes performance, and values mutual respect, fairness, and open communication.
• Be proactive and seek opportunities to discuss matters of lawful and ethical business conduct with others in an open and constructive dialogue.
• Foster an environment where everyone feels comfortable and empowered to ask questions and report apparent or potential violations of applicable national laws and regulations, this Code, or other MIH internal policies (group and corporate policies).
• MIH's goal is to create a safe and supportive environment where Employees can address compliance concerns or report potential violations without fear of retaliation. Retaliation against whistleblowers is prohibited. Supervisors and managers must strictly oppose retaliatory measures or behaviors that may be perceived as such.
• Respond to concerns brought to your attention within a reasonable timeframe. Avoid unnecessary delays, but also take the time to assess if you cannot form an immediate judgment. Think about it or get advice before you respond.
• Never require an Employee to act in a manner that is prohibited for you yourself.

3 Guidelines for Lawful, Ethical, and Sustainable Conduct

Regarding compliance with laws, ethical business behavior, respect for human rights, and environmental protection, the following guiding principles apply.

3.1 Lawful and Ethical Conduct

MIH places great importance on a legally compliant and ethically integral corporate governance from all our Employees. Our goal is to collectively minimize risks, avoid financial and legal consequences, and maintain the trust of the public, customers, Employees, investors, and other stakeholders. We aim for sustainable and ethically impeccable business operations. As a globally operating company, we adhere to all applicable laws and regulations in all countries and jurisdictions where MIH conducts business.

The following requirements are particularly noteworthy:

3.1.1 Combating Corruption and Bribery

Employees must refrain from any form of corruption, bribery, or participation therein, and comply with the applicable national anticorruption laws. In particular, it is prohibited to offer, promise, provide, or accept inducements in anticipation of receiving a quid pro quo, including, but not limited to, preferential treatment in business dealings.

The selection of suppliers for products and services must be based solely on objective criteria (such as price, quality, service, technical standards, product suitability, certification, and, if applicable, strategic considerations). Personal interests or relationships must not influence contract awards or allocations. No unlawful benefit shall be offered or provided to officials, public servants, or other individuals with government authority.

Invitations, gifts, inducements, or other benefits to MIH Employees are only permitted when transparently granted and are reasonable, align with customary hospitality, norms, and courtesy, and in compliance with applicable laws and regulations.

To ensure compliance with these guidelines, please note the following:

• Never directly or indirectly offer or provide money or valuables, or approve them, to obtain or retain orders unlawfully or to influence the activities of third parties in an inappropriate manner.
• Never directly or indirectly request or accept bribes, kickbacks, or other personal payments in connection with business dealings.
• Immediately report suspicious activities, such as payments to offshore bank locations, payments to third parties outside the area where the third party operates, or false invoices for sales.

3.1.2 Respect for Fair Competition

The regulations of antitrust and competition laws are designed to ensure fair and genuine competition for the benefit of all market participants. They apply to formal contracts and all other communications or agreements that restrict competition. They prohibit any obligations and actions that could lead to a restriction of trade or competition. Violations include price-fixing, agreements to boycott certain states, suppliers, or customers, customer or market allocation, and certain distribution or production restrictions.

We take pride in the competitiveness of MIH products and services, and they can compete under fair conditions against any competitor. MIH complies with all antitrust and competition laws and supports the goal of these laws to create fair competition. Violations of antitrust and competition laws can have serious consequences for MIH and individuals involved, such as negative headlines and reputational damage, significant fines, and imprisonment.

Our Employees are required to compete fairly, to comply diligently with applicable antitrust and competition laws, to avoid any anticompetitive practices, and must not abuse any potentially dominant market position of any MIH company.

In order to maintain strict compliance with the above guidelines, please note the following:

• If there is a risk of violating the complex antitrust and competition laws, it is imperative to seek guidance from your supervisor, who may, contact the legal or compliance team.
• Ensure that you do not illegally restrict competition by exchanging information with competitors, business partners, or third parties to set prices, allocate markets, or limit competition.
• Note that antitrust and competition laws generally prohibit price-fixing and any similar practices that set minimum selling prices.
• Seek guidance from your supervisor, who may contact the legal team, before making changes to terms and conditions for business customers, especially involving pricing or territory allocations.
• Any contacts with competitors, business partners, or other third parties that may violate antitrust or competition laws must be terminated immediately and immediately reported to the compliance team.

3.1.3 Combating Money Laundering

MIH has a zero-tolerance policy against money laundering. Money laundering is the deliberate attempt to introduce money or assets from criminal activities into the regular financial and economic cycle. At MIH, we make every effort to prevent our company from being used as a vehicle of money laundering.

Regarding anti-money laundering efforts, please particularly note the following:

• We conduct business activities only with reputable partners who comply with applicable laws and use legitimate sources.
• Carefully evaluate potential business partners and customers before entering into contracts or transactions to ensure transparency in our business relationships.
• Irregular payment transactions and any suspicious behavior by customers or other parties should be considered as warning signs and reported to your supervisor. As a general rule, the repayment of amounts to business partners may only be made to the account from which the funds were received.
• Attention must be paid to warning signs associated with money laundering—not only, but particularly, in the case of new customers and business partners. These include unusual payment methods (especially cash), escrow accounts, and unclear beneficial ownership. Cash transactions are generally problematic and should be avoided whenever possible. Cash transactions exceeding EUR 10,000 are prohibited.

3.1.4 Protection of Intellectual Property and Confidential Information

The protection of intellectual property and confidential information is crucial for the success of MIH's business model. Our company's success, its value, growth, and competitive advantage over competitors are based on work, research and development results, inventions, designs and trademarks, copyrights, knowhow, trade secrets, and other nonpublic and confidential information such as production processes, business plans, financial data, marketing and sales strategies, product launches, and activities related to corporate mergers, acquisitions, and licensing, which Employees gain access to in the course of their work for MIH (collectively referred to as ’Intellectual Property and Confidential Information’).

The ’Patents, Licenses, and Trademarks’ department is responsible for the legal protection of Intellectual Property and Confidential Information, both through the filing of applications for industrial property rights such as patents, utility models, designs, trademarks, and related property rights and through the consistent establishment of other appropriate legal and physical technical protective measures, as well as the prevention and prosecution of infringements.

Regardless, all Employees are required to treat all Confidential Information they receive during their employment with MIH strictly confidentially. This means that such information should not be disclosed to anyone outside of MIH unless there is a legitimate business need to do so. Even within MIH, not all Employees who do not have a current and legitimate business need for this information shall have access to it. These confidentiality obligations are part of any employment relationship and continue after employment with MIH has ended.

All Employees must also be aware that in a competitive environment, third parties are seeking to obtain Confidential Information about MIH's business activities. Such competitive surveillance activities are common in every industry. For this reason, extreme caution should be exercised when handling with Confidential Information in public places such as airplanes, trains, trams, bars, and restaurants, etc.

MIH, in turn, respects the rights of third parties, especially business partners, to their Intellectual Property and Confidential Information, and expects the same from all Employees.

MIH expects its Employees to:

• Maintain and protect MIH's Intellectual Property rights and Confidential Information and, respect the rights of third parties. When in doubt, you should seek advice from your supervisor and, if necessary, internal experts.
• Consult with the responsible persons at the ’Patents, Licenses, and Trademarks’ department if you intend to patent or otherwise protect an innovation or have the impression that it requires protection against disclosure to third parties.
• Obtain approval from the ’Patents, Licenses, and Trademarks‘ department for scientific publications.
• Only disclose Confidential Information to individuals who require it and are authorized to receive it.
• Be aware of third-party competitive surveillance activities that could harm MIH's assets and interests. Be cautious and careful when handling with Confidential Information, especially in public places and when using communication devices.
• Report to supervisors when violations of MIH's Intellectual Property and Confidential Information rights by third parties are identified or suspected.
• In case of doubts regarding the legal protection situation, consult your supervisor to clarify the situation.
• Continue to adhere to contractual confidentiality obligations even after the employment relationship has ended.

3.1.5 Data Privacy and IT Security

MIH Employees shall only collect, store, process, transmit, and disclose personal data in accordance with applicable data protection regulations and solely for legitimate purposes. They are responsible for ensuring the confidentiality, integrity, and availability of data and protecting it from unauthorized access, alteration, disclosure, destruction, or loss.

The information technology (IT) provided (including, but not limited to, IT systems, devices, applications, computers, laptops, digital media, services, mobile phones or smartphones, tablets, infrastructure, collaboration tools, and related support documentation, among others) is owned by MIH. To ensure the confidentiality, integrity, and availability of our IT, Employees shall use the assigned IT solely for business purposes and not for personal use without prior approval from their supervisor. The use of IT is subject to review by MIH in accordance with applicable law.

MIH-provided IT and related access credentials and devices must be protected from unauthorized access, even during Employees' absences from their workplaces. Strict adherence to IT security standards is essential, especially to protect our Intellectual Property and Confidential Information, including information that has been lawfully provided to us by third parties (cf. above).

Please take particular note to the following conditions:

• Protect personal data of colleagues, applicants, business partners, and customers from unauthorized access, alteration, disclosure, destruction, or loss.
• Do not access data without the required authorization.
• Share Confidential Information only with prior approval.
• Report data loss or accidental disclosure immediately.
• Do not install unauthorized or unlicensed software on the company's IT devices and systems.
• Allow the installation of software programs exclusively by the IT department and adhere to the manufacturer's/provider's license terms and conditions.
• Do not use company software or digital services for personal purposes.
• Immediately report any suspicion of fraud, theft, or misuse of company assets or IT devices, data, passwords, PINs, and authentication devices.
• Do not share IT devices, data, passwords, PINs, and authentication devices with unauthorized individuals and do not use company resources without authorization.

3.1.6 Use of Social Media

MIH Employees must use social media platforms – which are online platforms where users can interactively share, discuss, and consume information, news, and content (e.g., Facebook, X [formerly: Twitter], Instagram, LinkedIn, YouTube, WhatsApp, Snapchat, Pinterest) – with diligence and caution.

Business communication is permitted only through official MIH communication channels.

The creation and operation of MIH communication channels on social media are the responsibility of MIH's relevant corporate department. Official statements, especially to the press and other media, shall only be made by authorized MIH Employees.

Employees do not need to register their private social media channels with MIH. However, it is important to be aware that behavior on private communication channels can also impact the company. It is not allowed to represent or act on behalf of any MIH Group company on private communication channels or to publish and share data, especially trade secrets or other internal or confidential company information.

Also, pay attention to protecting your own privacy and respecting the privacy of others. When using private social media, local and potentially international data protection laws must also be observed.

Please follow these guidelines:

• Familiarize yourself with MIH's policy on the internationally recognized '10 Golden Rules for the Use of Social Media.'
• Never publish confidential, export-restricted, or secret company information.
• Never publish false information or anything that could defame third parties or harm our brand or reputation.
• Never publish material that could be obscene, threatening, or offensive to any person.
• Use corporate IT exclusively for business purposes.

Use personal social media responsibly.

3.1.7 Use of AI Systems

AI Systems (Artificial Intelligence) are software models that automatically generate content or make predictions based on probabilities and learned patterns. Unlike conventional software, AI systems do not follow strictly predefined rules. Instead, they "learn" from examples and can deliver results even in unknown situations that were not explicitly programmed.

In short: Conventional software is hardcoded and behaves predictably – AI systems are "trained" and can produce partially unpredictable results.

AI systems can create text, code, images and analyses, significantly supporting employees' work. At the same time, the use of AI systems is prone to errors and may lead to data protection or security breaches. Agentic AI refers to systems that act in a goal-oriented and autonomous manner to pursue specified tasks.

In individual cases, AI-generated content may be completely fabricated ("hallucination"), erroneous, misleading, outdated, discriminatory, or infringing. The unverified use of such content can result in harm to individuals or companies. Furthermore, the use of agentic systems or specific models can pose security risks to the MIH Group's infrastructure.

To minimize risks, the use of AI systems within the MIH is permitted only in compliance with the separate AI Code. It enables the use of AI systems while taking into account potential violations of law, data protection, or information security.

The AI Code includes a globally applicable section and is supplemented at the local level by local (national) AI guidelines, which incorporate the applicable local (national) legal and other local requirements regarding usage.

In this regard, all companies within the MIH Group ensure at the local level that applicable (national) legal requirements are met when deploying AI systems. Relevant guidance can be found, for example, in national legal provisions concerning the processing of personal data, automated decision-making, AI transparency, mandatory specialized training, and the use of agentic AI. Other applicable laws must also be observed, particularly those relating to copyright, data protection, trademarks, designs, and competition law (this list is not exhaustive).

In addition to this Code, employees are required to comply with the separate AI Code—and thus with the relevant MIH guidelines, applicable local (national) AI guidelines, and relevant laws.

The following fundamental principles for the responsible use of AI systems must be strictly observed by all employees when using AI systems:

• Use AI systems only for legitimate purposes related to your professional duties; do not use them for private, illegal, or unethical purposes—such as generating content that is harmful, misleading, glorifies violence, is subversive, discriminatory, or infringes upon rights.
• Adhere to the terms of use of the respective providers.
• You are responsible for how you use or work with AI systems.
• Before using an AI system, you must strictly observe data classification guidelines, associated risks, and the applicable approval process.

The MIH Group is under no obligation to purchase or license AI systems or to provide all employees with company accounts for unrestricted use.

• Use for legitimate purposes: Use AI systems only for legitimate purposes related to your professional tasks. AI systems can be used, for example, to support research, translations, text or image creation, analyses or brainstorming sessions. The terms of use of the respective software providers must be strictly adhered to.
• Prohibited use: AI systems must not be used for illegal or unethical purposes, such as creating harmful, misleading, violence-glorifying, anti-state, discriminatory or infringing content. The use of AI systems for private purposes is not permitted.
• Approval & Privacy: Use only approved AI systems and enter data only from authorized data classes. familiarize yourself with the AI register beforehand (see below).
• Risk awareness: Keep in mind that AI systems are not reliable. AI systems make mistakes, have no factual knowledge and no understanding of their own they merely recognize patterns and calculate probabilities but do not "understand" any content. Therefore, AI systems can produce completely false or invented results (so-called "hallucinations").
• Accountability: You are fully responsible for everything you enter in or create with AI systems. You remain responsible for your work results, even if they were generated with AI support. In short: AI is an assistant, not a decisionmaker. Always critically review inputs into AI systems and AI-generated content.
• MIH IT and user accounts: Use AI systems exclusively through resources provided by corporate IT (see Section 3.1.5) and company accounts. Applications or plugins of AI systems may not be independently installed without the approval of corporate IT. Under no circumstances should technical safeguards of an AI system be bypassed. The use of private user accounts is prohibited.
• Compliance with laws and MIH guidelines: All applicable laws, in particular copyright, data protection, trademark, design and competition law, as well as MIH policies, must be strictly adhered to when using AI systems.

Only approved AI systems may be used. Employees are only allowed to use AI systems after approval and with the authorized data classes.

MIH companies independently determine, through local approval processes, which AI systems their employees may use, and which data classes may be entered into an AI system. The following applies:

• Approved AI systems: Approved AI systems offer high security standards and are provided by an MIH company. Employees are allowed to use these AI systems to support the performance of their professional tasks. The use may be mandated within the scope of the employer’s right of direction to issue instructions. When using these systems, only the authorized data classes may be entered.
• Restrictedly approved AI systems: AI systems that are only restrictedly approved are in the testing phase or are not provided by an MIH company. There is a risk that these AI systems do not meet all of MIH's data protection standards or that entered data will be shared with third parties. The use of these AI systems is voluntary. Employees must never enter confidential company data or personal data of employees or customers into these AI systems. In case of doubt, it must be clarified with the supervisor whether corporate or personal information is to be classified as confidential.
• Other AI systems: AI systems that are not explicitly approved must not be used. This also applies to AI systems that are freely available on the Internet and have not been approved.

MIH companies provide their employees at the local level with an overview of the approved AI systems (hereinafter referred to as the "AI register"). The AI-register fundamentally documents which AI systems are approved for use, which data classes may be entered into an AI system, and what requirements, if any, apply for the use of an AI system.

The MIH Group and MIH companies are not obliged to acquire, license, approve or provide corporate accounts for AI systems for unrestricted use by all employees.

Inputs into AI systems must not lead to the uncontrolled disclosure of confidential information. Protecting trade secrets and confidential information of the MIH Group, as well as the safeguarding of data protection and the personal rights of employees, applicants, customers, suppliers, prospects or other persons are the top priority when using AI systems.

When entering information into AI systems – whether in the form of text inputs ("prompts"), uploaded files or the granting of access rights – the following points must be strictly observed:

• Observe data classes: Input into the AI system only such information that is authorized for the respective system according to the data classes in the AI register. In cases of uncertainty or doubt, refrain from inputting information or anonymize or disguise the information (e.g., by removing personal identifiers).
• Caution with restrictedly approved AI systems: Never enter trade secrets, confidential company data, employee and customer information, or data protected under local laws (e.g., personal data within the scope of the GDPR) into AI systems that are only restrictedly approved.
• Non-Confidential Information: You may enter purely factual, nonconfidential information, such as publicly available facts, general expertise, generic examples, or artificially generated or anonymized data.
• Prompt content: Always adhere to ethical principles when entering information. Avoid prompts that could generate illegal, discriminatory, or security-relevant content. Also, ensure that you only use information to which the necessary rights exist (e.g., no images, logos or trademarks of third parties without appropriate authorization).

AI-generated content refers to all content, results and information generated by AI systems, such as text, tables, analyses, images, videos, program code or other responses generated by a chatbot.

AI-generated content may be fictitious, erroneous, misleading, outdated, discriminatory or infringing. The unchecked use of content can cause harm to individuals or companies.

To minimize these risks, AI-generated content must be critically reviewed according to the following principles:

• Quality: AI-generated content must always be checked for accuracy, completeness and timeliness. Unintentional distortions or biases must be identified and corrected. Ensure an appropriate level of quality. You remain responsible for your work results.
• Third-party rights: AI-generated content must not be used if it infringes on third-party rights (e.g. personal rights, copyright, trademark or design rights). This is particularly important for AI-generated images, where it must be verified whether real people, third-party trademarks, logos, company names or protected designs are depicted.
• Critical reflection: Ask yourself for every AI-generated content: "Is this accurate, complete, and appropriate for its intended purpose?"
• No blind adoption: An unchecked adoption of AI-generated content into your work results is prohibited. AI systems provide suggestions, not finished work products

AI-generated content is generally not protected by copyright. Therefore, it can be copied, used and published by anyone – including outside the MIH Group. However, copyright protection in favor of MIH may arise if AI-generated content is substantially edited or supplemented by employees.

In light of this and to protect MIH's corporate interests, the following principles must be observed for any further reuse of AI-generated content:

• Important work results: Never adopt AI-generated content unreflectively, unchecked and, if necessary, only after your own revision into any of your work results. Before adopting, check whether unrestricted copying of your work product by third parties would be acceptable. In case of doubt, refrain from using AI-generated content.
• Editing & documentation: Ideally, any edits carried out should be documented where possible. The minimum requirement is to note that a work result was achieved with the support of AI.
• Copyright notice: Without further editing, AI-generated content may not be marked with a copyright notice for MIH.

Failure to comply with the above rules and Local AI Guidelines may result in disciplinary action.

3.1.8 Customs, Trade, and Export Control

MIH companies engage in international business activities in accordance with foreign trade laws, including laws, regulations, and provisions related to cross-border trade, export, import, investments, and technology transfer. Compliance with these regulations is crucial to ensuring lawful business transactions and avoiding legal consequences.

Foreign trade regulations may vary by country and can be influenced by international trade agreements. We primarily adhere to the German legal system unless it contradicts the local regulations of the respective country. Additionally, in specific justified cases, management may decide to comply with foreign trade laws of other countries. When uncertainties or doubts arise, export transactions are not carried out to mitigate risks.

Compliance with export, import, trade, customs, foreign exchange control regulations, embargoes, and antiterrorism laws is of the utmost importance to us. Violations can lead to legal consequences and jeopardize export privileges. If you have questions regarding trade controls, your supervisor is available to provide guidance and may seek further advice when necessary.

Our goal is to ensure that our deliverables do not fall into the wrong hands. Our Employees strictly adhere to all relevant trade and export regulations to uphold the integrity of our business.

Please observe the following guidelines:

• Understand trade controls for MIH products, technologies, and information, and adhere to restrictions on the transfer of these goods to external entities.
• Comply with all export and import laws, regulations, and requirements, as well as the company's trade control policies. This includes customs regulations and provisions aimed at preventing the production and distribution of chemical, biological, and nuclear weapons and their delivery systems. Additionally, certain products, technologies, and services are prohibited to specific countries, organizations, or individuals for the purpose of preventing international terrorism.
• Any trade or transactions with individuals associated with terrorist activities, terrorist organizations, or groups are strictly prohibited.
• Ensure that the required end-user certificates are in place, if necessary, before exporting goods.
• Verify that a new business partner is not on any national or international blacklists before establishing a business relationship.
• Prior to exporting goods, software, or technology, ensure that the item is not subject to any restrictions and that no export/reexport authorization from authorities is required.
• Adhere to comprehensive trade restrictions such as embargoes or sanctions on specific destinations and conduct additional checks before proceeding with further steps.

3.1.9 Conflicts of Interest

MIH Employees must separate personal interests from professional judgment. Conflicts between company interests and personal interests must be avoided. A conflict of interest arises when personal interests conflict with those of MIH, potentially creating loyalty conflicts. Situations where personal interests may conflict with or appear to conflict with MIH's interests must be avoided.

Also in personal matters, Employees must avoid conduct that counteracts the interests of the company, which could financially or reputationally harm it. Activities involving relatives or close associates can also lead to conflicts of interest. Employees must not exploit their position at MIH to gain personal benefits or benefits for relatives or close associates.

Actual or potential conflicts of interest can often be resolved in an acceptable manner. Affected Employees should promptly contact their supervisor to find an appropriate solution.

Please consider the following:

• Ensure that you always make business decisions in the best interest of MIH. When in doubt, seek advice to avoid potential conflicts of interest.
• Both entering into an additional employment or service contract with a third-party employer during your employment at MIH and any other paid or unpaid employment, including business engagements in other sectors, require prior written consent from the management or the relevant supervisory body.
• Exempt from this requirement are customary stock or share purchases for private investment purposes in compliance with the prohibitions on insider trading.
• Membership in representative bodies or boards of another company also requires prior written consent from the relevant supervisory body.
• Any investments in competitors, customers, and suppliers in the form of holding stake, (co)ownership, financing agreements, or any other type require prior written approval from the management or the relevant supervisory body. Significant holdings by relatives in competitors, customers, and suppliers must be promptly disclosed to the management or the supervisory body, as legally permissible.
• The conclusion of contracts or business activities involving one's own person, entities controlled by oneself, or relatives requires prior approval from the management or the relevant supervisory body, at least two levels higher in the hierarchy. In exceptional cases, these activities may be approved by the management or the supervisory body, provided the affected person is not involved in the decision to award the contract

3.1.10 Data Integrity, Accounting, Reporting, and Press

We are committed to integrity and accuracy in our business activities and the creation of corporate data and information. All work results, documents, and files must be correct, detailed, clear, and timely. Our Employees adhere to all relevant laws, regulations, and company policies concerning this matter.

For the collection and transmission of company information, we take care of complete, sincere, correct, and understandable communication. All documents are maintained in a way that allows representation by colleagues at all times. We develop and publish accurate and fair financial and nonfinancial information. Data integrity is crucial for our business, and we ensure that all data, information, and records created are accurate and fair.

It is strictly prohibited to make false or misleading statements in reports, publications, records, or documents of MIH. Forging records or falsifying facts can have severe legal consequences.

Official statements to the press or other media are made exclusively by authorized Employees.

Important instructions:

• Ensure that all work results and corporate data are correct, detailed, clear, and timely.
• Official statements, especially to the press or other media, shall only be made by authorized Employees.
• Communicate all company information that you collect and transmit to relevant authorities completely, sincerely, correctly, timely, and understandably.
• Maintain all documents and files in a manner that allows representation by colleagues at any time. Files and folders must be complete, orderly, and easily understandable
• Provide data integrity in your business activities and produce accurate and fair financial and nonfinancial information. At no time should you make false or misleading statements or claims in reports, publications, or expense reports.

3.2 Social and Working Conditions

All MIH Employees, both at national and international level, shall be treated with respect and dignity. We expect our Employees to apply this principle to their interactions with each other as a guideline for their collaboration.

We adhere to national laws and international conventions regarding human rights, particularly concerning social and working conditions. We expect our Employees to also respect the principles of sustainable and ethically responsible conduct in their work for MIH and to apply these principles appropriately in their dealings with business partners.

It is particularly important to adhere to the following standards with regard to social and working conditions:

3.2.1 No Discrimination and Harassment

The diversity of our Employees is a strength of MIH and provides us with a competitive advantage. Any form of discrimination based on origin, culture, language, mindset, gender, ethnicity, skin color, disability, health status, political belief, worldview, religion, age, pregnancy, or sexual orientation is unlawful and will not be tolerated.

We expect all Employees to treat each other and their colleagues with respect, fairness, friendliness, and professionalism in their daily business interactions. Discrimination and harassment must be actively avoided. The personal dignity, privacy, and personal rights of each individual are respected at MIH.

In your interactions with others, pay particular attention to the following:

• Treat all colleagues with respect and professionalism and support diversity in the workplace.
• Avoid any comments, jokes, or sharing of materials that may be considered objectionable by others.
• Do not discriminate against anyone based on a legally protected characteristic.
• Ensure that your decisions are based on objective and quantifiable criteria as well as business considerations.
• Any form of harassing behavior is not tolerated. This includes inappropriate gestures, comments, physical contact, or the display of offensive images. Promising a promotion or special treatment in exchange for sexual favors is also considered harassment.

3.2.2 Health, Safety, Working Hours, and Conditions

At MIH, we strictly adhere to all applicable laws, regulations, and industry standards for a safe and healthy work environment. Adequate occupational safety systems are established and implemented to provide preventive measures against accidents and health hazards that may be associated with the work activity. Appropriate measures are taken to prevent physical or mental fatigue.

Regarding working hours, MIH is committed to complying with all relevant laws, regulations, and industry standards. Overtime is voluntary and not compulsory.

MIH's working conditions ensure that Employees have access to adequate work facilities. We ensure that Employees have access to sufficient drinking water and clean sanitary facilities. Additionally, we ensure fire safety, medical emergency care, and appropriate lighting and ventilation.

As an Employee at MIH, it is also your responsibility to adhere to and enforce these standards and to contact the relevant supervisors or responsible parties with any concerns or questions. By collectively adhering to these standards, we contribute to creating a safe, healthy, and sustainable work environment.

Practical Instructions:

• Strictly adhere to all applicable laws, regulations, and industry standards for a safe work environment. Each Employee is responsible for safety in their work area.
• Utilize provided occupational safety systems and follow preventive measures to minimize accidents and health hazards.
• Show initiative and develop a safety awareness that considers not only your own but also your colleagues' and the entire MIH group's interests.
• Report potential hazards or safety concerns to your supervisor or the safety team immediately.
• Ensure you take appropriate breaks during working hours to prevent physical or mental fatigue.
• If you feel overworked or have difficulties with your workload, discuss possible solutions with your supervisor.
• Adhere to established working hours according to applicable laws and industry standards.
• Utilize provided work facilities and maintain them properly.
• Pay attention to fire safety and know the locations of medical emergency equipment.
• Familiarize yourself with emergency procedures and evacuation plans.
• It is strictly prohibited to bring weapons or other prohibited objects like explosives to work, company facilities, or company-sponsored events.
• Do not enter company facilities under the influence of alcohol or drugs, and do not perform work-related duties under such influence.
• Adhere to the non-smoking policy and only smoke in designated areas outside the buildings.

3.2.3 Respect and Enforcement of Human Rights and Employment Standards

MIH is committed to upholding high and internationally recognized human rights standards not only in Germany but also in all other countries where the company has subsidiaries, branches, or representatives. This commitment extends to our internal operations as well as our agreements with business partners, particularly within our global procurement and supply chain (see section 4).

As basic minimum standards that must be observed by all our Employees in their respective roles, we consider:

• The free choice of employment. Any form of forced labor, compulsory prison labor, indentured labor, or human trafficking is strictly prohibited at MIH.
• A strict prohibition of child labor. We adhere to the provisions of the International Labour Organization (ILO), United Nations conventions, and/or national laws that prohibit the use of child labor. In all cases, we abide by the law with the strictest requirements.
• We ensure fair compensation and benefits for our Employees. All applicable laws, regulations, and industry standards regarding compensation and benefits are upheld. Disciplinary actions shall not result in deductions from pay that are not provided for by applicable (national) law, unless the affected Employee expressly consents.
• We recognize the right to freedom of association and collective bargaining for our Employees, within the legal framework of each respective country and without discrimination.

3.3 Environmental Sustainability

Mitigating, managing, and preventing environmental hazards is a significant component of MIH's responsible and sustainable business practices. This includes environmental protection and the preservation of natural resources. Therefore, in the production or development of our products and the provision of our services, MIH complies with both national legislation and international conventions aimed at environmental protection.

We also expect our Employees, both domestically and internationally, to respect the principles of sustainable and ethically responsible conduct in their work for MIH and to apply these principles appropriately in their interactions with business partners.

It is particularly important to adhere to the following standards:

3.3.1 Environmental Permits

Our business operations as a company may require obtaining environmental permits and approvals. MIH shares the goal of protecting the environment and promoting sustainable development, and fully supports and cooperates with the relevant authorities.

• Ensure that all necessary environmental permits and approvals are obtained.
• Keep these permits and approvals up to date.
• Follow the terms and regulations specified in the granted permits and approvals.

3.3.2 Resource Conservation and Environmental Impact Mitigation, Waste Minimization

We commit to conserving and using natural resources, including energy and water, efficiently. We take substantial measures to prevent environmental pollution in general and illegal soil, water, air contamination, and noise emissions in particular. Waste and wastewater are to be avoided, their quantities minimized, and they must be labeled according to applicable laws and regulations before disposal and treated to prevent environmental impact. The reuse of products and materials, as well as the recycling of material or energy recovery of waste, is to be promoted.

• Save and utilize natural resources like energy and water efficiently.
• Implement concrete measures to prevent environmental pollution, especially regarding soil, water, air, and noise emissions.
• Minimize waste and wastewater as much as possible and actively reduce their quantities.
• Label waste according to applicable laws and regulations and treat it to minimize environmental impact.
• Promote the reuse of products and materials and the recycling of material or energy recovery of waste.

3.3.3 Hazardous Substances and Product Safety

We are obliged to labeling hazardous substances, chemicals, and materials and ensuring their safe handling, movement, storage, recycling, reuse, and disposal. All applicable laws and regulations regarding hazardous substances, chemicals, and materials must be strictly followed. Substance restrictions and product safety requirements are to be mandatorily adhered to in accordance with applicable laws and regulations.

• Label hazardous substances, chemicals, and materials according to regulations and ensure their safe handling, movement, storage, recycling, reuse, and disposal.
• Strictly adhere to all applicable laws and regulations related to hazardous substances, chemicals, and materials.
• Ensure that all substance restrictions and product safety requirements are mandatorily followed as per applicable laws and regulations.

3.3.4 Respect and Enforcement of Environmental Standards

MIH is obliged to upholding high and internationally recognized environmental legal standards, not only in Germany but also in all other countries where the company has subsidiaries, branches, or representatives. This obligation applies to our internal operations as well as our agreements with business partners, particularly within our global procurement and supply chain (as detailed in section 4).

As basic minimum standards that must be observed by all our Employees in their respective roles in the field of ecological sustainability:

• First, compliance with and updating of environmental permits and approvals.
• Second, efficiency in the use of natural resources like energy and water.
• Third, prevention of environmental pollution and waste minimization.
• Fourth, safe handling, labeling, and disposal of hazardous substances and chemicals in accordance with laws and regulations.

4 Responsibility in the Procurement and Supply Chain

Our responsibility extends not only to our own internal processes but also to our business partners. We take care that they adhere to the same high human and environmental rights standards. Therefore, we place particular emphasis on the (global) procurement and supply chain to ensure that no human and environmental rights violations occur there. Suppliers, distributors, contractors, consultants, representatives, and agents are crucial to MIH's sustainable growth and overall success. We expect them to maintain high performance and integrity standards, adhere to all applicable laws, regulations, industry guidelines, contract terms, and recognized sustainability standards. This includes protecting human rights, ensuring safety and environmental protection, as well as complying with basic standards of ethical business conduct. The goal is to have a sustainable and ethically sound supply chain.

Our basic requirements for sustainable behavior are outlined in the MIH Supplier Code of Conduct. Essentially, these requirements are:

• Business Conduct Standards: MIH places special emphasis on legally compliant and ethically sound corporate governance by all of its business partners. These requirements particularly pertain to combating corruption and bribery, adhering to fair competition practices, and fighting money laundering. Additionally, suppliers must protect intellectual property and confidential information while ensuring data privacy and security.
• Human Rights Standards: With the MIH Supplier Code of Conduct, we also take care that our business partners adhere to internationally recognized basic human rights standards, particularly regarding the prohibition of child labor, forced labor, slavery, violation of labor protection norms, employment discrimination, inadequate compensation, environmental pollution, resource exploitation, and unlawful eviction and dispossession of natural livelihoods. This is based on the Supply Chain Due Diligence Act of the Federal Republic of Germany and the international conventions on human rights mentioned therein (nos. 111 of the Annex).
• Environmental Standards: Lastly, the MIH Supplier Code of Conduct requires our business partners to adhere to internationally recognized standards for avoiding environmental risks, especially the prohibition of inadmissible mercury emissions under the Minamata Convention, the prohibition of the production and use of chemicals and the improper handling, collection, storage, and disposal of waste under the POPs Convention, the export of hazardous and other waste under the Basel Convention and Regulation (EC) No. 1013/2006, as well as the import of hazardous waste and other waste from noncontracting parties to the Basel Convention. This is based on the Supply Chain Due Diligence Act of the Federal Republic of Germany and the international conventions for environmental protection mentioned therein (nos. 1214 of the Annex).

When dealing with the MIH Supplier Code of Conduct, our Employees should follow these guidelines:

• In coordination with your supervisor, ensure that suppliers, distributors, contractors, consultants, representatives, and agents, etc., with whom you are responsible for communication, receive the MIH Supplier Code of Conduct, become familiar with its requirements, and acknowledge them to MIH.
• Set clear expectations for your business partners regarding compliance with the MIH Supplier Code of Conduct.
• If irregularities or potential violations of the MIH Supplier Code of Conduct are identified in business partners, contact your supervisor to clarify the matter and take necessary actions.
• In consultation with your supervisor, you may offer support and cooperation to the business partner for the implementation of the MIH Supplier Code of Conduct if necessary.
• Encourage all Employees to report any concerns regarding the compliance of business partners with the MIH Supplier Code of Conduct to the responsible authorities at MIH (provide clear reporting and escalation channels for such cases).

5. Indications of Compliance Violations and Their Handling

’Compliance‘ refers to the adherence and observance of internal corporate policies and rules, laws, regulations, and ethical standards by all Employees and organs of the company. The goal of compliance is to ensure that the company and its Employees operate in a legally compliant, ethically correct, and responsible manner.

An effective compliance culture ensures that the company complies with all applicable laws and regulations, minimizes economic risks, avoids reputational damage, and ensures fair and ethically sound business operations. This includes protection against corruption, money laundering, antitrust violations, environmental violations, human rights violations, and other legal and ethical infractions.

As mentioned earlier, this Code is an important integral part of MIH's compliance guidelines. MIH compliance within the company is responsible for the development, implementation, and monitoring of compliance policies and procedures. It raises awareness among Employees about compliance issues, provides training, and assists in identifying and managing compliance risks. A strong compliance culture allows our company to build trust with its stakeholders and ensure long-term sustainable success.

Therefore, all Employees also have the responsibility to prevent, detect, and respond to noncompliant behavior, which includes reporting compliance violations, including violations of this Code.

5.1 Asking Questions, Seeking Advice, and Help

To prevent noncompliant behavior, MIH encourages its Employees to ask questions and seek advice and help when uncertain or in doubt. MIH promotes an open culture of asking questions, and supervisors are responsible for ensuring that Employees receive the support they need to comply with the Code.

All Employees are encouraged to evaluate and adjust their behavior in light of the presented standards. If there are doubts about whether a violation of these standards has occurred, Employees can seek advice from the relevant specialized department (MIH Corporate Office).

5.2 Expressing Concerns and Reporting

MIH encourages and expects its Employees to openly address any violations of the Code, other company policies, or laws and regulations (compliance violations) in good faith, as this is in line with MIH's values. But also reporting potential compliance concerns allows management to address integrity issues promptly and trustworthily, and protecting the interests of MIH and its Employees.

If Employees observe or suspect unlawful or unethical conduct, they are expected to first raise the issue with their supervisor or one of the contacts as listed below.

If you find it uncomfortable speaking to your supervisor, please contact the MIH Human Resources Department or MIH Compliance via email at:

compliance@messerinvestment.com

It is important to note that violations of the Code, company policies, or laws and regulations are taken seriously. Severe violations may result in disciplinary actions up to and including termination, and additional legal proceedings and penalties.

5.3 Protection from Retaliation

All our Employees are protected from any form of retaliation when reporting a reasonable suspicion of a compliance violation. Whether the suspicion later proves to be accurate or not, Employees can report suspected violations confidentially and without fear of retaliation.

MIH rejects any form of retaliation against Employees who express concerns in good faith and holds responsible those who take such measures accountable. ’In good faith‘ means making a sincere attempt to provide honest, complete, and accurate information, even if it later turns out to be unfounded or incorrect. Retaliation may include exerting pressure or threatening an Employee to deter them from reporting the suspected violation. If an Employee takes retaliatory measures against a colleague who has reported or intends to report a suspected compliance violation, this will result in disciplinary action.

Any Employee who witnesses or suspects a violation of this principle should also report it. Retaliation constitutes a violation of our Code, and knowledge or suspicion of retaliation should be reported immediately.

5.4 Collaboration in Investigations and Inquiries

All Employees are expected to cooperate in internal and company-initiated external audits, investigations, and inquiries.

Withholding information or knowingly providing false or misleading information constitutes a serious breach of our duties as Employees.

¹ In this Code, ‘Employees’ includes all persons who are in the service of a company of the MIH Group worldwide on the basis of a contract under private law, such as an employment contract, service contract, or other types of employment contract, including training and temporary employment contracts. This also includes management bodies such as managing directors or members of the executive board, the supervisory board, the board of directors and the advisory board, as well as all persons who work in personal dependency and are subject to the instructions and regulations of an MIH company.

² Any changes to this Code are exclusively under the responsibility of MIH's Corporate Office and will be announced through internal communication channels.