COMPLIANCE

In addition to our internal requirements and guidelines, which we have set out in the Code of Conduct, we also require our suppliers to comply with standards and demand this through the Supplier Code of Conduct.

In addition to the topics of compliance with human rights requirements and occupational safety as well as environmental aspects, we obligate our suppliers to open up communication opportunities for employees. Our goal is to work together on the basis of ethically justifiable principles.

Respect for human rights is a foundation on which the cooperation at RECA NORM has always been built. With the Human rights policy statement, we like to communicate this standard of ethical conduct further beyond RECA NORM’s immediate internal sphere of influence and establish this standard in our supply chain. For us, the commitment to respect and uphold the rights of every human being is a central part of our daily work.

Studies show that information from third parties often leads to the exposure of fraudulent activities. This is why we have established a system that, besides employees of the Group, also allows third parties to give us information on criminal activity and other serious compliance violations. This is the Internet-based BKMS (Business Keeper Monitoring System) system.

If you want to use this system to give us information, you can quote your name or act anonymously. However, as we are looking for open communication, we would like to encourage you to give your name along with the information. We will always keep your information strictly confidential and consider the legitimate interests of all parties.

Please create a mailbox in the BKMS system that we can use to contact you. This is important if we have any questions or if you would like to add more information to your report later. If desired, communication via the mailbox can also take place anonymously.

The system is used exclusively to draw attention to suspected fraudulent activity or defined, serious compliance violations in the Group. Misuse for other purposes may constitute a criminal offence.

Complaints via email

You can send an email to compliance@recanorm.de to provide us with

• Information on human rights or environmental risks
• Information on violations of human rights or environmental obligations

regarding a business unit of our company or of a supplier.

In your email, please indicate your preferred method of communication so that we can discuss the matter with you. We will get in touch with you as soon as we can.

Once the information has been submitted, a RECA NORM employee will send you a confirmation of receipt (including a case number). The information you provide will be processed internally under this case number by our compliance officer. You can contact us again at any time after submitting information using the above email address. Please indicate the case number sent to you in the confirmation of receipt. All information provided to us will be treated confidentially.

The following code of procedure clarifies how the information you provide is processed:

What is the purpose of the complaints procedure?

This complaints procedure allows individuals to inform the company of

• Human rights or environmental risks
• Violations of human rights or environmental obligations

that have arisen as a result of our company’s business activities. The information may concern a business unit of our company or of direct or indirect suppliers.

What happens when information is submitted?

After information is submitted, each whistleblower receives a confirmation of receipt as soon as possible and no later than seven days after receipt of the information. Information is processed internally by the compliance officer.

What procedural steps are undertaken after the information has been received?

After receiving information, the responsible point of contact first verifies the plausibility of the information, in particular with regard to relevant human rights or environmental risks, or the violation of human rights or environmental obligations. After the validity of the information has been confirmed, the employee responsible for processing the message will discuss the case with you as the whistleblower. Please provide your contact details, in particular an email address, that we can use to contact you. If the information is taking a long time to process, we will inform you of the current processing status at the latest three months after the information is submitted.

Who processes the information?

The individuals that we entrust to process the information are independent, impartial and not bound by instructions. They are specifically obliged to maintain confidentiality.

Confidentiality and data protection

All information and documents made available to us will of course be treated as highly confidential and in compliance with the relevant data protection regulations. Your identity will remain confidential and you will be protected against any discrimination or punishment.