CODE OF CONDUCT

1.1 Scope of application

The rules and standards formulated in the Supplier Code of Conduct apply without exception to all suppliers of Bauer Group companies, their owners, managers and employees, and also to their suppliers, their owners, managers and employees. With regard to compliance with the requirements and rules of this Code of Conduct and to prevent violations, business partners are audited.

Regardless of the country in which the supplier is located, the supplier shall comply with applicable laws as well as the rules and standards set forth in this Code of Conduct. In each case, the stricter rule shall be complied with. With an appropriate organisation and a systematic approach as well as suitable measures, all parties shall ensure that these are complied with and implemented or applied. These measures are subject to regular audits, which are documented.

Our suppliers inform their respective suppliers in the supply chain and also oblige them to comply with the rules and standards in an appropriate manner; also about Privatmolkerei Bauer's right to check compliance. This could take the form of obtaining information or an audit, for example.

Privatmolkerei Bauer may at any time require suppliers to provide a full record of the supply chain of the product they supply.

1.2 Exclusion

Should rules formulated here conflict with legal ones or cannot be taken into account due to impossibility, Privatmolkerei Bauer must be informed of this fact immediately. See chapter 3.0.

1.3 Confidentiality

All information received from the supplier, observations made or findings obtained in the course of audits will be treated confidentially by employees of Privatmolkerei Bauer or by third parties commissioned by Privatmolkerei Bauer.

1.4 Amendments

The Supplier Code of Conduct is part of the supplier contracts and forms the basis for our business relations. The Bauer Group will adapt the Code of Conduct in the event of changes in the legal or normative framework conditions. In this case, we expect an acceptance of the appropriate changes. If this is not the case, Privatmolkerei Bauer must be informed immediately. See chapter 3.0.

2.1 Compliance with the law

Our suppliers and business partners comply with applicable laws, regardless of their location or the place of business. In addition, they respect the international conventions recognised by us. They undertake to comply with the applicable trade restrictions and other provisions of foreign trade law.

Cooperation with competent authorities is always open, constructive and reliable.

2.2 Corruption, conflicts of interest and fraud

There is zero tolerance for corruption, taking advantage and bribery. The conventions of the United Nations, the OECD as well as the relevant anti-corruption laws are observed without restrictions.

We expect that no personal advantages are offered, promised or granted to employees or other representatives of the Bauer Group companies with the aim of obtaining a contract or otherwise being favoured. This must also be taken into account in particular when issuing invitations and offering gifts.

We make our business decisions exclusively on the basis of objective criteria. We also oblige our suppliers to do so. Conflicts of interest with private interests, other economic or other activities, including those of family members or related persons and organisations, are to be excluded.

Our suppliers do not tolerate any fraudulent acts such as embezzlement, misappropriation or other fraud in the cooperation with their business partners.

2.3 Antitrust and Competition Law

We respect the laws and guidelines for maintaining fair competition, in particular antitrust and competition law. We do not accept any unjustified preferential treatment or discrimination.

2.4 Confidentiality

All information received by the customer and supplier in the course of their business relationship is confidential, unless it is generally known. This also applies to the time after the end of the business relationship.

Should the disclosure of such information by one party to a third party be necessary for the fulfilment of the business purpose, the written consent of the respective other party is required for this. The recipient of the confidential information shall be obliged to maintain its confidentiality.

2.5 Data protection

Personal data of the employees of Privatmolkerei Bauer shall be processed by our suppliers exclusively for a specific purpose and for business purposes, in a comprehensible manner, carefully and in compliance with the applicable statutory provisions of data protection law.

2.6 Data security

The companies of the Bauer Group and their suppliers undertake to ensure an appropriate standard of security for the processing of information. They shall take all necessary precautions to protect it from access and use by unauthorised parties. The aim is to ensure the confidentiality, integrity and verifiability of information and documentation.

2.7 Safety and health protection

The creation of safety and the preservation of health are unconditional values and a basic prerequisite for functioning work processes. The suppliers of Privatmolkerei Bauer take their responsibility for their employees as well as employees of external companies or suppliers and visitors very seriously and design the conditions of stay and working conditions (also ergonomics) in such a way that safety and health are not endangered.

Active monitoring of health and safety risks is the most essential prerequisite for preventing illness and occupational accidents. Each supplier takes safety measures and the necessary controls within an operational occupational safety management system to minimise health and safety risks; machines have suitable equipment for this purpose, employees have the appropriate protective equipment.

Safety information and warnings are clearly displayed in the hazardous areas. The safety information describes the risk/hazard and how the worker should behave in a simple and easily understandable way.

Before starting work at a new workplace for the first time, each employee receives a briefing that also contains all the necessary safety instructions. These must be recorded.

All staff and visitors are guaranteed clean drinking water, hygiene facilities including adequate toilets and hand washing facilities as well as first aid equipment accessible at all times.

A hygiene and fire protection concept is in place as well as an emergency plan for disaster situations with a procedure for the safe and quick evacuation of all those present. All staff members are regularly trained on this and drills are conducted. All other persons entering our suppliers' facilities are informed of the rules in an appropriate manner.

An alcohol and drug policy to prevent work under the influence of alcohol or drugs is actively communicated to all employees on a regular basis.

2.8 Fairness

Suppliers to Bauer Group companies pay fair wages and align the organisation of their working hours and social benefits with industry standards or international conventions. Laws and regulations are complied with. This concerns, among other things, recruitment, contracts, working hours, minimum wage, time off, social benefits and other allowances.

Employment contracts are always agreed in writing. Wage and working time records used as a basis for wage payments are available and up-to-date. Wages, including overtime compensation, are paid on time and at regular intervals, but at least monthly.

2.9 Co-determination

Our suppliers respect the active and passive freedom of association and the right to collective bargaining within the framework of country-specific legislation.

In countries where this right is regulated, restricted or prevented by law, the supplier shall not prevent the implementation of alternative, free and independent workers' organisations.

At the suppliers of Bauer Group companies, workers have the right to negotiate collectively with the employer without fear of retaliation or other discrimination.

2.10 Forced labour, child labour

Forced labour is not permitted. Employees of our suppliers have a legal work permit. They may extend or terminate the employment relationship at any time, in accordance with the terms of the contract. Personal documents or property are not withheld by the employer. Any recruitment costs or placement commissions are in principle paid by the employer and are also not indirectly passed on or claimed from the employee.

The companies of the Bauer Group support the legal employment of minors if they are of the minimum legal age to work and are employed in accordance with the laws that apply accordingly.

Child labour is not permitted. Proof of age of all employees is available. The minimum age for employment of workers shall be observed in accordance with the respective national laws and international agreements. A measure to prevent child labour at suppliers is implemented and documented.

2.11 Anti-discrimination

There shall be no discrimination against workers on the basis of race, religion, creed, marital status, maternity, age, political orientation, national origin, illness, disability, health status, sexual orientation or any other grounds.

2.12 Protection of the environment, animal welfare

Our actions along the entire value chain, from raw materials to finished products, in all regions and at all levels - from management to each individual employee - are geared towards sustainability. Animal welfare in farm animal husbandry is also of particular importance.

Appropriate suppliers are committed to animal welfare and take into account the contractual production and quality rules, animal welfare guidelines and the Farm Animal Husbandry Ordinance. The standards set are exceeded where possible. We do not accept serious environmental pollution in the sense that the pollution has a negative effect on the environment beyond the scope of the company and is difficult to remedy.

Suppliers to Bauer Group companies take care to minimise resource requirements, including energy use and emissions, water consumption and wastewater, as well as waste in the supply chain. Waste is sorted and fed into a recycling system in accordance with local regulations and available infrastructure.

Contractors for transport, storage and disposal of waste have the necessary official permits. All procedures and standards must at least meet or exceed legal requirements.

Our suppliers have undertaken to comply with the rules of this Code of Conduct. We work towards compliance with the Code of Conduct in direct contact with our suppliers and check compliance on a random basis.

If rules formulated here are violated, if they conflict with legal rules or if they cannot be observed due to impossibility, Privatmolkerei Bauer must be informed of this fact immediately.

If this is neglected or prevented, we shall consider this to be a gross breach of duty. Violations that are not reported may therefore result in termination of the cooperation without notice.

Employees of the companies of the Bauer Group, their suppliers, their subcontractors as well as all persons who become aware of a violation can report violations. The report can be addressed to the management of Privatmolkerei Bauer:

Michael Janker, Compliance Management: [email protected]

Also to the Compliance Officer of Privatmolkerei Bauer: Rosemarie Schneider [email protected]

As a matter of principle, we treat the reporting of violations confidentially. Nevertheless, in individual cases it may be unavoidable to disclose this information to third parties, for example when opening an official investigation in which the whistleblower is to be heard as a witness.

3.1 Anonymous whistleblower system

It is also possible to submit a whistleblower anonymously:

https://division.hinweisgeber-systeme.de

Reports made through this system can be forwarded anonymously to the Compliance Office. In this case, it is impossible to trace the reporter.

This Code of Conduct represents the most important principles of behaviour and rules that we jointly commit to uphold.

We regard this commitment as a prerequisite for our joint success. Therefore, we support each other in creating the conditions necessary for this and in complying with the regulations and requirements.

This commitment is a foundation of the business relationship. We regard non-compliance as a gross breach of duty.