Code of Conduct for Suppliers and Business Partners

Scope of Application:

This Code of Conduct for Suppliers and Partners (“CoC SaP”) applies to suppliers and business partners of Asterix HoldCo SE (“Asterix HoldCo”) and all its affiliated companies (Asterix HoldCo and all its affiliated companies together referred to as the “TQG Group”).

1. Our Value Compass

1.1

We, the TQG Group, are a young, growing company in a constantly changing society. Our goal is to offer unique, high-quality products together with our suppliers and business partners that meet the highest ethical, social, and environmental standards.

1.2

Business relationships with our business partners are based on mutual trust, integrity, and respect.
This CoC SaP sets out the expectations that represent our value compass. It contains the standards we set for our suppliers, business partners, and their supply chain regarding human rights, environmental protection, business ethics, and integrity.

1.3

We strive for a long-term partnership with our suppliers and business partners, based on ethical
principles. Therefore, we require all suppliers and business partners acting on behalf of the TQG Group and/or providing goods or services for payment to comply with this CoC SaP.

1.4

This applies to all suppliers and business partners of the TQG Group and their subsidiaries, affiliates, subcontractors, and business partners. We expect every member of the supply chain to comply with this
CoC SaP.

2. Compliance with Legal Regulations and Obligations

2.1

We expect our suppliers and business partners to be aware of and strictly comply with all laws, regulations, and international agreements applicable to them and their business. This applies in particular to labor law, environmental protection, health, and food safety. Where local laws deviate from the standards of this CoC SaP, we expect compliance with the strictest requirements.

2.2

We require our suppliers and business partners to always meet the strictest requirements, regardless of whether they are set out in this CoC SaP or in local or global laws. We focus on quality and therefore expect that the requirements set by us or by the legislator are regarded as a minimum standard, but that a higher quality performance is strived for.

2.3

We expect all our suppliers and business partners to pass on the stated requirements to their supply chain through effective management systems, policies, procedures, and training.

2.4

Suppliers and business partners are obliged to inform the TQG Group immediately of any significant issues related to the goods and services they supply.

2.5

Furthermore, all contractual obligations towards the TQG Group must be fully met.

3. Respect for Human Rights and Fair Treatment of People

3.1

Our suppliers and business partners must respect the rights of their employees and ensure safe, fair, and healthy working conditions throughout the supply chain. Any form of human trafficking, forced labor, or child labor as defined by the International Labor Organization (ILO) is strictly prohibited.

3.2

Furthermore, they must ensure an inclusive and ethical work environment free from harassment and discrimination, guaranteeing equal opportunities for all employees regardless of gender, ethnicity, age, sexual orientation, religion, or disability.

3.3

We expect our suppliers and business partners to respect employees’ right to freedom of association, to raise concerns without retaliation, and to meet or exceed statutory standards for compensation and working conditions. The right of employees to freedom of association and collective bargaining must also be respected throughout the supply chain.

4. Sustainability and Environmental Protection

4.1

Our suppliers and business partners and their subcontractors must take proactive measures to minimize their environmental impact and ensure a sustainable supply chain. This includes reducing CO2 emissions, avoiding waste, and efficiently using resources. We expect our suppliers and business partners to apply practices that contribute to environmental preservation and continuously improve their environmental impact.

4.2

Furthermore, we require the implementation of sustainable production processes that are in line with industry standards and our environmental commitment. This includes the regular evaluation of production methods, resource consumption, and waste management. Suppliers and business partners should prioritize environmentally friendly innovations and use clean technologies wherever possible.

4.3

Continuous improvement in environmental management is essential. We encourage suppliers and business partners to set clear sustainability goals, track progress, and be accountable. Together, we can reduce our collective footprint and promote a more sustainable future.

5. Quality and Product Safety

5.1

We set the highest quality and safety standards for our products and require our suppliers, business partners, and sub-suppliers to strictly comply with all legal regulations and the requirements of the
TQG Group. This includes, in particular, conducting regular quality controls, inspections, and audits to ensure that the agreed standards are consistently met.

5.2

Furthermore, immediate notification to the TQG Group of potential safety or quality issues is required to ensure product safety. Prompt and transparent communication, as well as quick
and solution-oriented action, are crucial to address any concerns that could affect the integrity of our products.

5.3

We also expect our suppliers and business partners to adhere to the highest standards in the manufacturing, storage, packaging, and transportation of food to protect our products and consumers. Suppliers and business partners must meet or exceed agreed specifications to ensure the quality promised to our customers. Any concerns regarding product safety or quality must be reported accurately, completely, and without delay, in full compliance with our requirements.

6. Accounting and Financial Transparency

6.1

Maintaining proper, transparent, and accurate accounting, as well as clear and verifiable documentation of all transactions, is a central obligation of our suppliers and business partners. We require that all financial records and books accurately, honestly, completely, and timely reflect transactions, ensuring that no detail is omitted or obscured. Fraud, bribery, or any form of unfair business practices will not be tolerated under any circumstances.

6.2

Suppliers and business partners are expected to apply appropriate audit and compliance processes to ensure the highest standards in areas such as product and food safety, employee health and safety, financial reporting, and labor practices. These processes must be robust and regularly evaluated to ensure compliance with legal regulations and our corporate standards.

6.3

Any form of fraud, bribery, misuse of assets, or unfair business practices, as well as the mere attempt, will not be tolerated. To promote transparency, we require the disclosure of facility locations and the known origin of materials upon request, to enable full traceability throughout the supply chain. This level of transparency is crucial for maintaining trust and accountability in all business areas.

7. Responsible Market Presence

We insist that our suppliers and business partners do not use misleading marketing strategies and provide transparent, fact-based information about their products. Furthermore, all our
suppliers and business partners must establish clear guidelines to ensure that all claims about their products are supported by reliable evidence, to promote honesty and integrity in all marketing efforts.
This commitment to transparency not only protects consumers but also strengthens the trust and credibility of our brands.

8. Corruption Prevention and Ethical Conduct

8.1

Any form of corruption, bribery, money laundering, or unethical conduct by our suppliers, business partners, and their subcontractors is strictly prohibited. Transparent and fair business relationships based on trust and integrity are of utmost importance to us.

8.2

All suppliers and business partners must ensure that their activities and practices meet the highest ethical standards and foster an environment where integrity is paramount. At no time may gifts or payments be offered to members or employees of the TQG Group or public officials with the aim of influencing business decisions.

8.3

Furthermore, it is essential for all our suppliers and business partners to comply with all anti-corruption laws and regulations applicable to their activities in the countries where they conduct business.
Compliance with these laws not only protects our shared reputation but also strengthens the foundation of our business relationships. We are convinced that by promoting ethical conduct and adherence to laws, we can create a culture of accountability and respect that benefits all stakeholders.

9. Fair Competition and Integrity

9.1

We insist that our suppliers, business partners, and subcontractors act fairly in free competition. It is essential that their supply chain distinguishes itself through performance and innovation, and not through
illegal agreements or unfair means. Our suppliers and business partners must never offer or accept undue incentives in connection with the TQG Group’s business. Business practices that unduly restrict competition, such as unauthorized information exchange, espionage, and price fixing, are strictly prohibited.

9.2

Furthermore, we attach great importance to avoiding conflicts of interest with employees of the TQG Group.
All business decisions must be made on the basis of integrity and transparency to ensure that no financial interests or other agreements create inappropriate relationships with our
employees. By adhering to clear boundaries and ethical standards, we can foster an environment of trust and accountability that benefits all parties involved.

10. Protection of Confidential Information

10.1

Our suppliers and business partners are obliged to protect the confidential information of the TQG Group, including business data, intellectual property, and personal data, and to prevent unauthorized disclosure, as well as to ensure the protection of this confidential information throughout their entire supply chain.

10.2

The systems and practices used must ensure that confidential data is secure and protected from misuse at all times. This includes the protection of all confidential information about the TQG Group, its suppliers, employees, and consumers. All suppliers and business partners must take careful measures to protect intellectual property, trade secrets, patents, and financial information as long as they are under their control. Furthermore, it is crucial to avoid situations that could negatively impact our business interests or reputation.

10.3

Furthermore, compliance with insider trading laws is essential. Suppliers and business partners must take proactive measures to prevent their employees from trading in TQG Group securities while in possession of material non-public information.
This includes implementing training and awareness programs to ensure that all employees understand their responsibilities regarding confidentiality and the legal consequences of insider trading. By prioritizing these practices, we can preserve the integrity of the TQG Group’s sensitive information and maintain the trust our stakeholders place in us.

11. Reporting Violations

11.1

Anyone who suspects that a supplier or business partner of the TQG Group is committing or has committed a violation of the aforementioned regulations has the option to contact the external ombudsperson of the TQG Group. The ombudsperson will objectively and, if desired, anonymously review each report and take appropriate measures to clarify the incident, remedy the violation, and/or prevent further incidents.

11.2

The TQG Group’s ombudsperson can be contacted as follows:

Attorney Dr. Kathrin J. Niewiarra, Ombudsperson
Philippistraße 11
D-14059 Berlin
Phone: +49 (0) 30 / 4036750-17
TQGG@compliance-aid.com
compliance-aid-tqgg.hintbox.de – Hintbox

Signed:
Board of Directors of Asterix HoldCo SE