The aspiration of Röchling, which is a family business, is to be a reliable and fair partner for all of its business associates and employees, and one that complies with the law, statutes, and contracts as a matter of course. This aspiration serves both as our own benchmark and the one that we are happy for others to apply to our performance. The Röchling Code of Conduct describes our aspiration as it applies to the individual sectors in which we operate, and establishes certain irrevocable minimum requirements. Our Code of Conduct does not seek to cover every conceivable situation. Instead,...

2.2 Executives serve as role models 8 3. Conduct towards business partners and third parties 9 3.4 Consultancy and service agreements 11 3.5 Supplier and customer relationships 11 4. Human rights and labor and social standards 12 5. Environmental protection, health, and safety 15 5.2 Occupational health and safety 16 8. Data protection and data security 19 13. Questions, reporting of irregularities 24

Founded in 1822, the Röchling Group has emerged as an international leader and globally oriented group of small and medium-sized businesses in the plastics processing sector. Pioneering, excellent, and reliable: These are the corporate values that Röchling measures when assessing its performance. As a family business, we attach the utmost importance to the principle of compliance with the law, both inside and outside the company. Acting in compliance with the law and a close relationship with our employees are key symptoms of the way we engage in business. The present Code of Conduct is a binding...

Principles We comply with applicable law. Lawful conduct Röchling subscribes to the principle of strict compliance for all acts and measures of the Röchling Group. Every employee is therefore obliged to comply with applicable law, and every line manager must ensure that his or her employees fulfill this obligation. It is strictly forbidden to induce third parties either to act contrary to the law or knowingly to participate in such acts. Executives serve as role models Board members and executives have a special part to play as role models in the implementation of this Code of Conduct. They must...

Conduct towards business partners and third parties We support fair competition and strictly comply with statutory provisions governing competition. We condemn every form of bribery and corruption. Supporting fair competition is consistent with our company’s business policy. We therefore expect all employees strictly to comply with applicable antitrust and competition law. Agreements in restraint of competition and concerted practices with competitors are accordingly prohibited because their purpose or outcome is to prevent or restrict competition. This shall include, in particular, the allocation...

Suppliers and business partners are to be selected exclusively according to objective criteria. An employee harboring any doubt concerning admissibility under antitrust law must consult his or her line manager. If applicable, advice is to be sought from an attorney. Every form of giving or taking bribes or granting of advantage is forbidden, whether practiced by or benefiting public officials or in the course of business. No employee is allowed to accept, offer or grant bribes or other monetary gifts in connection with his or her business activity. Public officials are not to be offered, promised...

Subject to the stricter provisions set forth above, such gifts to and from third parties can have an approximate value of 100 euros. The giving or accepting of monetary gifts is forbidden in every instance. As a general rule, employees must never accept or grant benefits capable of giving rise to the impression that inadmissible influence has been exerted, or that an attempt has been made to exert an inadmissible influence. Employees who allow themselves to be unfairly influenced by customers or suppliers, or seek unfairly to influence same, shall face disciplinary proceedings regardless of criminal...

Human rights and labor and social standards We observe the internationally recognized human rights as well as labor and social standards. By way of the provisions set forth below we wish to ensure that all employees act in compliance with the internationally recognized human rights and the key labor and social standards. Human rights The Röchling Group is expressly in favor of and supports respect for the internationally recognized human rights. The Röchling Group undertakes to ensure equal opportunity with respect to employment and to refrain from any discrimination unless national law expressly...

Equal opportunity The principle of equal opportunity applies. Röchling clearly proclaims its opposition to discrimination and exclusion and favors integration and tolerance not only among the employees, but also between and with the management. The employees and management shall treat each other with respect and understanding and place trust and confidence in each other in order to achieve the common company objectives. Forced labor Röchling rejects any type of forced labor. Child labor is prohibited. The minimum age of employees shall be based on the applicable national laws and collectively...

The existing skills and know-how of the employees are of tremendous importance to the future viability of Röchling at all facilities throughout the world. For this reason, Röchling supports and promotes employee training measures that are capable of expanding and deepening the professional and technical knowledge and essential for the relevant work activity. Training and further training are assigned special importance in future development. The right of employees of Röchling to form non-affiliated unions and join such as they see fit is hereby recognized. Röchling accepts the establishment of...

Environmental protection, health, and safety We protect the environment and manage resources in a sustainable way. We set high standards in occupational health and safety. The products and services of Röchling are to be environment-friendly, now and in the future. Protection of the environment and the improvement of living and environmental conditions are important company objectives of Röchling. Cooperation shall take place in practice with the competent local institutions in order to achieve and maintain the relevant international, European, and national environmental standards. As early as...