1. FOREWORD

The Code of Conduct of Koschaum GmbH forms the basis for the way we conduct our business and sets out the moral and ethical values and principles to which we are committed.

This Code of Conduct for management and employees serves as a guideline for appropriate conduct by each individual.

Our Code of Conduct establishes standards against which we should all measure our conduct on a daily basis. Ethical conduct, mutual respect, honesty, transparency and fairness in our dealings with colleagues, business partners and public authorities form the foundation of our company.

2. OUR PRINCIPLES AND VALUES

• Meeting customer requirements
• Employee motivation
• A safe working environment
• Protection of the environment
• Integrity and reliability
• Continuous improvement of quality awareness
• Compliance with all applicable legal and regulatory requirements

3. BUSINESS PRINCIPLES OF THE COMPANY
a. LAWFUL CONDUCT
We conduct our business in accordance with applicable national and international laws and regulations and place great importance on openness and honesty in our dealings with our business partners. In order to meet this commitment, our employees must be aware of and comply with the obligations and prohibitions relevant to their work.

b. INVITATIONS AND GIFTS
We reject invitations, gifts or other benefits from business partners that could place us in a position of obligation or create a relationship of dependency. The acceptance of symbolic gifts and invitations within the customary scope of business activities is permitted. Invitations to meals or events from business partners that exceed an appropriate value must be reported to the employee's direct supervisor.

c. SUSTAINABILITY AND ENVIRONMENTAL PROTECTION
We continuously strive to improve the sustainability of Koschaum GmbH and our product portfolio. This approach contributes to the conservation of resources and also helps reduce costs for our customers. We place a high priority on the responsible and efficient use of natural resources.

d. ZERO TOLERANCE FOR CORRUPTION
Corruption is understood as the abuse of a position of trust for the purpose of obtaining a material or immaterial benefit to which there is no legal entitlement. Corruption is a criminal offense. We prohibit all forms of corruption, including bribery and the granting or acceptance of improper benefits, regardless of whether such acts are carried out directly, through intermediaries, with private individuals or public officials.

e. FAIR COMPETITION
We always strive to establish sustainable, trustworthy business relationships with our customers and business partners based on mutual respect. Free and fair competition is the foundation of economic activity. All business transactions are conducted honestly and in an ethically responsible manner. We expect the same from our business partners.

4. CONFLICTS OF INTEREST
A conflict of interest arises whenever we have a personal interest in addition to our involvement in a business decision. Regardless of personal interests or relationships, all company decisions are made exclusively on the basis of objective criteria.

5. RIGHTS AND RESPONSIBILITIES OF EMPLOYEES

Our company is committed to equal opportunities, appreciation, trust and performance. We provide our employees with a challenging working environment and encourage them, through demanding and interesting tasks, to make full use of their abilities. We promote a culture of mutual trust, respect and open dialogue.

6. NON-DISCRIMINATION
Mutual respect forms the basis of a working environment characterized by appreciation and dignity. We are committed to respecting human dignity and human rights and to protecting our employees in the workplace.

Any form of discrimination, for example on the basis of gender, marital status, race, skin colour, origin, religion, sexual orientation, disability, political views or other personal characteristics, is prohibited.

We do not tolerate forced labour or child labour, either within our company or among our suppliers and customers.

We do not tolerate sexual harassment in the workplace. We do not accept any other form of discriminatory harassment, threats, intimidation or bullying. Colleagues must not be humiliated or excluded.

7. DRUGS AND ALCOHOL IN THE WORKPLACE
Drugs impair an employee's ability to make decisions and react appropriately and increase the risk of accidents in the workplace. The use of intoxicating substances, such as alcohol and other drugs, is strictly prohibited at our company, and employees must not be under the influence of such substances while at work. All employees must comply with the applicable designated smoking break arrangements.

Employees who are required to take medication should consult their doctor who prescribed the medication and/or the company physician to determine whether the medication may affect their ability to perform their work. If such an impairment is foreseeable, the employee should inform their supervisor accordingly.

8. OCCUPATIONAL HEALTH AND SAFETY
Workplace safety is our highest priority. We are committed to providing a healthy and safe working environment for our employees. Every employee is encouraged to identify potential accident risks in their own workplace and either eliminate them themselves, where possible, or report them to the relevant supervisor. We ensure that our employees receive regular information and training on occupational health and safety.

9. WORKING HOURS AND LEISURE TIME
Koschaum GmbH is committed to ensuring that employees are able to maintain a healthy balance between working hours and leisure time. We comply with statutory maximum working hours. Vacation is intended for rest and recovery, and supervisors are responsible for ensuring that employees actually take the vacation to which they are entitled.

10. CONFIDENTIAL INFORMATION AND DATA PROTECTION

Every employee is required to use confidential information belonging to the company or its business partners, such as technical data relating to products and processes, specifications or drawings, know-how or trade secrets, exclusively within the permitted scope. When sharing such information internally or externally, employees must verify whether the respective recipient is authorized to receive it. Every employee must respect the intellectual property rights of third parties and refrain from any unauthorized use.

The handling of personal data relating to our customers, employees and business partners is given careful consideration within our company. Personal information is collected, processed and used only where this is legally permitted or where the persons concerned have given their consent, and only for the intended purpose.

11. IMPLEMENTATION AND VIOLATIONS
Compliance with the principles set out in this Code of Conduct is mandatory for all employees throughout the company.
Every manager is responsible for ensuring that the employees assigned to them are familiar with the content of the Code of Conduct and comply with the rules and standards of conduct applicable to them.

Violations will be subject to disciplinary action in accordance with applicable laws and employment-related agreements and should be reported to the respective direct supervisor or to management.

Abenberg, August 2026

Martin Stieber
Management