We attach highest priority to consistent compliance with statutory provisions, regulations and voluntary commitments. Our Compliance Programme provides the necessary framework to achieve that goal. The basis of the Compliance Programme is our Code of Conduct, which is mandatory for all OTTO FUCHS employees¹ regardless of their responsibilities or position within the hierarchy. The Code of Conduct defines our standards of ethically responsible behaviour.

We are committed to the rules of fair competition and free markets and therefore will not tolerate any form of corruption or violations of antitrust law. We respect the universally acknowledged rights of all human beings and strictly reject any form of forced labour or child labour. We are actively committed to tolerance and fairness and refuse to tolerate any form of discrimination. We have additionally formulated this commitment to respecting human rights and fair working conditions in our Human Rights Policy.

We expect our business partners to respect the principles laid down in our Code of Conduct especially also with regard to the observance of human rights and to act in accordance with those principles.

whistleblowing management

We provide our employees and business partners with mechanisms for drawing attention to circumstances indicating that laws or internal rules have been broken. To that end, we have nominated persons who can be contacted on Compliance matters and have appointed an external lawyer of trust (Vertrauensanwalt) whom employees and business partners can approach in confidence. Any leads or tip-offs will be pursued meticulously, respecting the anonymity of the whistleblower if so desired, and taking into account the rights of all those concerned.

Our whistleblower system is available to anyone who believes they have been harmed or adversely affected by business activities of OTTO FUCHS or its business partners. These include, but are not limited to:

• OTTO FUCHS employees,
• suppliers,
• service providers and
• Business partners (including temporary workers and subcontractors) in any country
• Any other external parties