Whistleblower System

1. GUIDELINE

Sustainable business practices lay the foundation for the future of the environment, society, and the economy, as well as for every individual employee and business partner of Assmy & Böttger Electronic GmbH.

The cornerstones of Assmy & Böttger Electronic GmbH’s corporate culture are the allocation of key requirements and their independent implementation and management, as well as a shared understanding of values and risk minimization to ensure sustainable corporate development.

The whistleblower system, supported by the legal expertise of Ratisbona Compliance, creates additional trust and assurance through a clearly defined structure accessible to everyone and a legally sound initial assessment, enabling individuals to report misconduct and thereby ensure the sustainable success of Assmy & Böttger Electronic GmbH and prevent harm.

2. SCOPE OF APPLICATION

a) This policy describes the procedure for reporting confirmed or suspected misconduct or wrongdoing.

b) It applies to all employees (including temporary workers), customers, suppliers, and anyone with an interest in the well-being of the company.

3. KNOWLEDGE OR REASONABLE SUSPICION OF A MISConduct

a) We encourage every employee who has knowledge of or a reasonable suspicion regarding a material instance of misconduct (a violation of the law or unethical behavior contrary to our Code of Conduct) to report it.

b) We encourage every employee to report such matters through the known and established reporting channels. These include, among others:

i. Confidential advisors

ii. Human Resources

iii. Management

iv. Internal suggestion and reporting system

v. Compliance department

c) If none of these reporting channels are suitable for your report, the whistleblower system—backed by the legal expertise of Ratisbona Compliance—is available as a reporting channel. The Ratisbona Compliance whistleblower system is operated by an independent third party.

d) Reports submitted through the whistleblower system—which is supported by legal expertise from Ratisbona Compliance—are forwarded directly to Ratisbona Compliance. Reports can be submitted digitally via the Ratisbona Compliance reporting platform, by phone, or in person.

4. INTENTIONAL FALSE REPORTS

Intentional false reports are considered a violation of the Code of Conduct and will be treated accordingly. They may result in disciplinary action and/or criminal prosecution.

5. ALLOCATION OF RESPONSIBILITIES

a) The Ratisbona Compliance whistleblower system enables anonymous communication with the whistleblower and ensures this capability when necessary. Upon receipt of a report regarding alleged misconduct or fraudulent behavior, the facts of the matter are subject to an initial review based on the information provided.

b) Ratisbona Compliance is responsible for reviewing and processing incoming reports in a timely manner.

c) It is possible to contact the whistleblower to gather additional information for further assessment of the facts while preserving their anonymity.

d) Based on this initial review, the next steps for handling the matter are determined. Depending on the severity of the allegation, the group of individuals involved, and the area of law, the report is forwarded to the responsible department of the respective subsidiary or group of subsidiaries concerned. External experts may be consulted during the further investigation of the matter. There may be a legal obligation to report the matter if there is reasonable suspicion of a criminal offense. Ratisbona Compliance ensures that all reported cases are investigated and resolved with adequate documentation.

e) Assmy & Böttger Electronic GmbH expects managers and supervisors at all hierarchical levels to take such reports seriously, treat them as strictly confidential, and promptly address them in accordance with the relevant guidelines and necessary measures to remedy the misconduct.

6. DECISION NOT TO FOLLOW UP ON A REPORT

Ratisbona Compliance may decide not to follow up on a report, for example, if

a) there is insufficient information available to conduct an adequate investigation, and there is no way to obtain further information.

b) the report is proven to be false.

7. REPORTING

Reporting is handled by the Legal Department of Ratisbona Compliance. Detailed reports are prepared for cases investigated by Ratisbona Compliance.

8. PROTECTION AND RIGHTS OF THE REPORTER

a) The identity of all reporters is treated with absolute confidentiality. Ratisbona Compliance will under no circumstances disclose voice messages, IP addresses, and/or phone numbers, unless “8 c” applies.

b) No one who submits a report need fear negative consequences as a result. However, reporters (as whistleblowers) do not enjoy protection in cases of misconduct.

c) Protection of the reporter is not guaranteed in the following cases:

i. Upon request, e.g., from law enforcement agencies, Ratisbona Compliance is obligated to provide voice messages, IP addresses, and/or phone numbers.

ii. Cases in which it has been determined that reports were intentionally false or made against one’s better judgment and/or with malicious intent (“in bad faith”);

iii. or if the report itself must be classified as a criminal offense or a violation of the Code of Conduct (e.g., defamation or threats).

d) If the reporter disagrees with the outcome of the investigation, they have the option to raise this issue again through the whistleblower system with legal expertise provided by Ratisbona Compliance.

9. PROTECTION AND RIGHTS OF ACCUSED PARTIES

a) If an investigation is initiated as a result of a report, Assmy & Böttger Electronic GmbH will inform the affected parties within 30 business days at the latest. This period may be extended depending on the specific circumstances of the case, e.g., if there is a risk that evidence may be destroyed or the investigation may otherwise be obstructed.

b) Affected individuals have the right to file a complaint regarding investigations directed against them. To do so, affected individuals should contact:

i. Their supervisor or managing director

ii. Ratisbona Compliance. Contact information can be found at the end of this policy.

10. DATA PROTECTION

Ratisbona Compliance will treat all information as strictly confidential. The protection of data for both reporters and data subjects is guaranteed within the legal framework. Information will be made available on a restricted basis—both in terms of content and the group of individuals to whom it is disclosed (the so-called “need-to-know” basis). This policy involves the processing and storage of personal data. This is done exclusively in accordance with data protection regulations.