Policy statement – Supply chain due diligence obligations*

(Status: January 2025)

Preamble

As an international company, we are aware of our responsibility to respect and protect human rights and environmental standards along our entire supply chain. Our business activities should contribute to a sustainable and fair global economy, whereby we are clearly committed to the fundamental values of respect for human dignity, fair working conditions, protection of the environment and the fight against corruption.

Compliance with the legal requirements of the Supply Chain Due Diligence Act (“LkSG”) is not only a legal obligation for us, but also an expression of our corporate ethos. In this policy statement, we define the measures and principles that we implement in order to fulfill our corporate duty of care. Our aim is to identify human rights and environmental risks in our supply chain at an early stage, counteract them and continuously improve our processes in order to make a positive contribution to a sustainable and fair value chain.

We expect our business partners to respect these principles as well and to work closely with us to ensure compliance with human rights and environmental standards. This commitment covers all stages of the supply chain and underlines our efforts to create long-term added value for all parties involved by acting responsibly.

This policy statement applies to Asterix HoldCo SE (“Asterix HoldCo“) and all its affiliated companies (Asterix HoldCo and all its affiliated companies together“TQG Group“).

What we stand for

We are aware of our social and ecological responsibility and it is important to us as a group of companies to integrate these attitudes into the TQG Group ‘s business model. This declaration covers all activities of the TQG Group.

Respect for human rights and environmental concerns

We are committed to our responsibility to minimize the impact of our actions on the environment, conserve resources and reduce environmental pollution. We take an ambitious approach to what we can do ourselves, worldwide, at all locations. We expect the same from our partners. Our actions are based on internationally recognized framework conditions and standards, which we support unreservedly:

  • United Nations Guiding Principles on Business and Human Rights

  • Core labor standards of the International Labor Organization (ILO) and their basic principles the four areas of freedom of association, prohibition of discrimination in respect of employment and occupation, abolition of child labor and elimination of forced labor

  • OECD Guidelines for Multinational Enterprises on Responsible Business Conduct

  • UN Convention on the Status of Women

  • UN Convention on the Rights of the Child

Our expectations of employees and business partners

We expect our employees and business partners to comply with applicable laws and to support the corporate values we have defined. We expect transparency and consistent compliance with social and environmental standards from our suppliers and their upstream suppliers. In particular, compliance with humane working conditions is never negotiable for us.

These expectations are reflected in ourCode of Conduct. Compliance with this Code of Conduct is mandatory for our employees. OurSupplier Code of Conduct also sets out the ethical, social and environmental standards that we expect from our suppliers and business partners. The current versions of both the Code of Conduct and the Supplier Code of Conduct can be accessed at any time via the website.

Human rights and environmental risk management

As a globally active company with complex supply chains, we attach great importance to treating human rights and environmental protection with the utmost care in order to avoid risks and violations at an early stage. Our aim is to identify these risks at an early stage, minimize them through targeted measures and react quickly and appropriately in the event of violations. To this end, we implement a wide range of measures in various business areas.

We continuously review our risk management and corporate processes, with a particular focus on the effectiveness of our preventive measures, corrective actions and complaints procedure. We review the results of our risk analysis in detail and on a regular basis.

Risk analysis

As part of a comprehensive risk analysis, we systematically examine potential risks. To do this, we make use of the extensive range of solutions offered by Scrioo, a renowned platform for supplier management. In doing so, we look at general risks arising from geographical and industry-specific circumstances once a year, as well as specific risks on an ad hoc basis. We then evaluate and prioritize the identified risks in order to derive suitable preventive and – if necessary – remedial measures for our own business areas and along our supply chain. All relevant decision-makers are informed of the results of the risk analysis.

Priority human rights and environmental risks

As part of a risk assessment of our own business area, all companies were analyzed for their risk potential with regard to human rights and environmental risks.

In the area of our business activities, human rights and environmental risks exist primarily in the areas of procurement and temporary employment. The relevant companies were subsequently examined in more detail and, where necessary, appropriate preventive measures were taken.

The TQG Group also has preventive internal control measures in the area of temporary staffing.

Preventive and remedial measures

At the TQG Group, we implement various preventive measures both in our own business area and in relation to our direct suppliers. The protection of human rights and the environment is an integral part of our purchasing process and anchored in our purchasing guidelines. In addition to our Code of Conduct and our Supplier Code of Conduct, we have taken further measures.

To protect against occupational accidents and work-related health risks, we have established extensive measures to ensure health and safety in the workplace. Our risk management includes abstract and contractual control mechanisms and regulates their risk-based implementation. We have special quality assurance agreements for raw materials and packaging materials.

In addition, we continuously sensitize our employees as well as suppliers and business partners to the importance of human rights and environmental protection and offer appropriate advice on an ad hoc and needs-based basis. In the event of (imminent) violations of protected legal positions, the TQG Group will immediately take appropriate remedial measures. Clear processes with defined responsibilities have been established for this purpose.

The TQG Group carries out the risk analysis with the help of scrioo. The scrioo risk analysis for direct suppliers and business partners is carried out on the basis of the statutory provisions of the LkSG and the corresponding guidelines of the responsible Federal Office of Economics and Export Control (BAFA).

First, the supplier and business partner data of the divisions, subsidiaries and branches is collected. These are merged and integrated into scrioo. In the first step, the abstract risk in terms of country and sector risks is determined using a system. Statistical data and established indices are used for the assessment. The suppliers are then examined in detail as part of the concrete risk analysis, subjected to continuous media monitoring and analysis and dynamically evaluated with a risk score. The identified risks are evaluated and prioritized. In the case of potentially relevant risks, a questionnaire is sent to the supplier/business partner, which is used to evaluate whether and, if so, which measures need to be taken with regard to the specific supplier/business partner.

In addition, scrioo ensures continuous monitoring of suppliers/business partners and conflict minerals as well as sanctions list entries.

The effectiveness of the preventive measures is reviewed once a year and on an ad hoc basis.

Responsibilities

The Management Board is responsible for compliance with the declaration of principles.

The independent Human Rights Officer is responsible for managing and monitoring the procedures with which the TGQ Group fulfills its obligations under the LkSG . She reports to the Management Board at least once a year and proposes improvements where necessary.

Complaints procedure

The TQG Group has appointed an external lawyer as ombudswoman and contact person for our whistleblower system in the course of combating violations of legal regulations and/or internal company compliance rules as well as violations of human rights and environmental due diligence obligations. The ombudswoman is available to all whistleblowers who wish to make a confidential report of irregularities at the TQG Group.

The TQG Group encourages its employees and business partners to report any activities that indicate a violation of applicable laws or our Code of Conduct or that are inconsistent with ethical business practices. The link to the complaints office can be found here: Compliance.

Documentation and reporting

Based on the documentation, the TQG Group will fulfill all applicable reporting obligations in a timely manner. The Human Rights Officer performs a supporting and coordinating function in this regard. Compliance with our human rights and environmental due diligence obligations is documented and kept for seven years from the date of preparation.

Signed:

Management Board of Asterix HoldCo SE

(Date of first publication: December 2024)

* For reasons of better readability, the masculine form is used below for personal designations and personal nouns. Corresponding terms apply to all genders in the interests of equal treatment. The abbreviated form is for editorial reasons only and does not imply any judgment.