Code of Conduct

1 Preamble and scope of application

DENA Stahlbau GmbH & Co. KG (hereinafter: DENA) is committed to the values set out in this corporate constitution.

Sustainability, responsibility and integrity are the foundations of our actions. We are convinced that ethical and economic values are not in conflict with each other. We value the careful use of natural resources and the continuous reduction of the environmental impact of our activities. We promote respectful and cooperative cooperation, diversity and tolerance and do not tolerate any form of discrimination.

Compliance with the law, fairness and ethical conduct - in short, integrity -characterize not only our external dealings with our customers and business partners, but also the way we do business. internal conduct of our employees. Both our strategic decisions and our day-today business are based on high ethical and legal standards, which are reflected in our Code of Conduct and, where necessary, specified in individual guidelines.

All employees, in particular the management and executives, embrace these corporate goals and fulfill their responsibility for DENA's image by observing the principles set out here and by acting only in accordance with the law and the company's internal guidelines.

We expect these values not only to be implemented by ourselves, but also to be shared by our business partners who are involved in our value chain and at the end of which our products and services are provided.

2 Law-abiding behavior

Compliance with the law is DENA's top priority. Every Employees must observe the applicable legal regulations at all times. Compliance with the law and DENA's guidelines is the duty of every employee.

In the event of a violation, every employee must expect the general consequences provided for by law or contract. We also reserve the right to take measures under labor law.

3 Responsibility of our employees

DENA's public and competitive image is largely determined by the actions and behavior of our employees.

Misconduct by even a single employee can cause DENA considerable damage. In addition to the economic damage, the risk of damage to our reputation and thus to our market position.

Even the appearance of an infringement can lead to legal consequences and not only shape public opinion, but alsolead to a detrimental change in customer behavior.

4 Special responsibility of our managers

Our managers bear responsibility for the employees entrusted to them not only through their organizational and supervisory duties, but also through their exemplary personal conduct, performance and social skills.

Our managers create a trusting work environment and are always available to our employees if they are unclear about the scope of legal provisions, have questions or professional or personal concerns. Managers communicate clearly to their employees that DENA disapproves of violations of the law and will take legal action. Each manager is responsible for ensuring that no violations of the law occur in their area of responsibility that could have been prevented or impeded by appropriate supervision. This fundamental responsibility remains even in the case of delegation of individual tasks. The manager must also ensure in the case of delegation that compliance with legal requirements is verified.

The rules of the Code of Conduct take precedence over any conflicting instructions from a superior. In the event of a conflict, the decision of the Compliance Officer (see section 13) must be obtained.

5 Competition law

DENA is committed to fair competition. The principle of integrity applies not only in competition, but also when drafting contracts with our customers and business partners.

DENA employees do not participate in agreements or arrangements with suppliers, vendors or competitors with the purpose or intent of fixing or influencing prices or other terms of sale, obtaining customers or to divide up sales territories or boycott certain suppliers or customers.

Even coordinated behavior, informal conversations or informal agreements with the aim of impairing competition are prohibited by law and must therefore be avoided. Any appearance of participation in such unlawful or concerted actions must be avoided.

In principle, the following applies: If there are doubts about the permissibility of anti-competitive behavior in an individual case, a decision must first be made by the Compliance Officer.

6 Anti-corruption

DENA is interested in a lasting business relationship with its business partners, based solely on the quality of their own deliveries and services. DENA is committed to fighting corruption. Corruption is not only a criminal offense, but also undermines trust in the actions of DENA and its employees.

All prices, services, conditions and agreements must stand up to an objective and transparent assessment. Suppliers are exclusively selected on the basis of their pricing, performance or the quality and suitability of the product.

Our employees must avoid any appearance that a business decision may have been made on the basis of extraneous considerations, personal interests or relationships.

Any personal interest that may exist in the context of a business relationship must be reported to the Compliance Officer.

6.1 Offering or granting benefits

6.1.1 Officers

Public officials or other office holders are granted, offered or promised benefits (gifts or other advantages, benefits, etc.) in connection with their office and invitations are extended to office holders (hospitality, events, etc. ) are only extended if they are in line with DENA's internal regulations, are based on customary or polite practices, are related to official business and the value does not exceed what is socially customary.

6.1.2 Business partners

No benefits (gifts, invitations and hospitality, but also courtesy gifts or promotional gifts, etc.) may be offered or granted, directly or indirectly, to business partners (suppliers, customers, consultants) or other third parties in connection with business activities if there is any possibility that they may create the impression of improper influence, whether in the form of a non-cash benefit or other monetary benefit. Donations of any kind to business partners or other third parties may only be made if the occasion and value are appropriate and socially acceptable.

6.2 Demanding or accepting benefits

DENA employees make their decisions solely on the basis of appropriate and transparent criteria. For this reason, no employee may exploit their official position to demand, accept promises of, or accept material or immaterial benefits.

If an employee receives an offer from a third party that could even appear to constitute an attempt to influence them, they must reject it and inform the compliance officer of the offer.

The acceptance of gifts of a value of up to €50.00 (per year) other than those given as a token of goodwill is prohibited.

Accepting invitations from business partners is only permissible if the occasion and scope of the invitation are appropriate and socially acceptable and refusing the invitation would be impolite. If there is any doubt as to the appropriateness of an invitation, or in the event of repeated invitations within a year, the invitation must be reported to the respective superior or the compliance officer.

Detailed rules can be found in DENA's anti-corruption guidelines.

7 Donations & Sponsoring

DENA makes donations (voluntary contributions without consideration) and sponsorships (contributions with a contractually agreed consideration) with the aim of positively shaping DENA's reputation and public perception. In order to avoid conflicts of interest and to ensure consistent behavior within DENA, donations and sponsorships are only permitted in accordance with the law and DENA's internal guidelines, as part of a transparent approval process.

8 Avoiding conflicts of interest

Employees provide DENA with their full working capacity and loyalty. A detailed regulation on sideline activities and/or equity investments that can be approved in individual cases can be found in DENA's sideline activities guidelines.

DENA strives to avoid any kind of conflict of interest or loyalty among its employees in the course of their business activities. Possible conflicts of interest must be disclosed immediately. Decisions are made on the basis of objective considerations and are not influenced by personal motives or private interests.

9 Social responsibility, sustainability and environmental protection

9.1 Human rights and anti-discrimination

We respect the applicable regulations for the protection of human and children's rights as fundamental and universal requirements for all economic activity. We reject any use of child, forced or compulsory labor, as well as any form of modern slavery and human trafficking.

We do not tolerate any discrimination based on ethnic or national affiliation, gender, religion, ideology, age, disability, sexual orientation, skin color, political opinion, social origin or other legally protected characteristics.

Equal opportunity, tolerance and fair, unprejudiced and respectful interaction are the basis not only for our internal dealings with each other, but also for our dealings with customers and business partners.

9.2 Environmental protection and technical safety

Environmental protection and the conservation of natural resources are corporate goals of DENA. As a manufacturing company, we are responsible for the environmental compatibility and sustainability of our activities beyond the region. Environmental friendliness, a continuous reduction in the impact on the climate, technical safety and health protection are fixed targets for all the products we sell and the services we provide. As a municipal company, we ensure compliance with the existing legal requirements and are also in dialog with politics and society about ensuring ecologically sustainable development in our business areas.

10 Working conditions and occupational safety

We have set ourselves the goal of protecting and promoting the health of our employees and customers as well as occupational safety in the best possible way. Every employee is jointly responsible for occupational safety in their area. To achieve this goal, employees support DENA in identifying risks, take part in training, inform the responsible department as needed and thus enable the introduction of any necessary corrections.

DENA ensures that the statutory occupational health and safety regulations and the corresponding company agreements are complied with and respects the right of employees to form and join trade unions and employee representative bodies on a democratic basis. Employees who belong to a trade union or employee representative body are neither disadvantaged nor favored.

11 Data protection and data security, IT security

11.1 Data protection

DENA is aware of its responsibility to protect personal data. Every employee is obliged to process personal data exclusively in accordance with legal requirements and DENA's data protection guidelines.

11.2 Artificial intelligence

Insofar as DENA uses artificial intelligence (AI), this is done in accordance with the law and only for purposes that are ethically justifiable and socially accepted. Any content created by AI is carefully checked before use and corrected if necessary. Content generated by AI is marked as AI-generated.

11.3 Trade secrets and confidential information

Every employee must respect and protect DENA's trade secrets. DENA's trade secrets include, for example, patents, purchase prices and dealer lists, cost, pricing, marketing or service strategies, and non-public financial reports. In addition, all information that could be advantageous for competitors to know or whose publication could harm the company must be treated confidentially.

DENA therefore takes appropriate confidentiality measures to prevent unauthorized persons inside and outside the company from accessing such information. In addition, DENA ensures that such third-party information is treated confidentially and respects third-party business secrets.

12. Compliance organization

DENA's management appoints a compliance officer. This person is the point of contact for all questions regarding compliance with the Code of Conduct and provides support and advice on general compliance issues.

DENA's management also appoints an external lawyer as a compliance consultant to support the implementation of the Code of Conduct.

In all matters concerning the Code of Conduct, the implementing company guidelines and compliance with them, each employee should first seek clarification with their supervisor before contacting the compliance officer or the external compliance consultant.

If an employee has evidence of a violation or even just a suspicion of a violation of the Code of Conduct or the implementing guidelines, the following options are available to them for clarification:

• The employee reports the compliance-relevant facts to his or her immediate superior.
• If the employee does not feel that clarification of the compliance-relevant facts with the immediate superior is appropriate, he or she can turn to the compliance officer or the external compliance consultant; the employee is free to choose.

In addition, DENA operates a legal whistleblower system (Compliance Hotline), which allows the whistleblower to provide information (anonymously if they wish) about professional misconduct, violations of the Code of Conduct, but in particular criminally relevant behavior within DENA. The details are regulated in DENA's Whistleblower Guidelines.

Regardless of whether employees contact their immediate superior, the compliance officer or the compliance hotline, every report will be treated with the seriousness it deserves and handled confidentially.

No employee has to fear any disadvantages from DENA for contacting the aforementioned offices. In addition, we protect the whistleblower from retaliation or other disadvantages.

The compliance officer and the external compliance consultant report to the management of DENA as required, but at least once a year, on the compliance-relevant issues that have come to light during the reporting period.

DENA ensures that managers and employees receive regular training and are made aware of compliance-relevant business processes. The training and participation are documented.

Each employee receives a copy of the Code of Conduct. The text is also made available on the homepage.

13 Contact details

The compliance officer appointed by the management is:

Sandra Kötter

DENA's external compliance consultant can be reached at the following address:

Dr. Marcus Böttger, Attorney-at-Law

VBB Rechtsanwälte

Königsallee 74 • 40212 Düsseldorf

Tel. 0211 36 777 0

Mail boeltger@vbb.legal

The compliance hotline can be reached at the telephone number and email address provided by DENA.

14 Entry into force

This corporate constitution comes into force upon signature and is valid until revoked.