OX Ethics & Compliance Tool

Anonymous reporting system

Complying with the law is important to us; which is why we systematically care for the task of adhering to both legal and internal regulations in our company, i.e. with so-called compliance. At the same time, we are aware that even the best compliance management cannot prevent individual breaches of rules. This, however, does not mean that we will accept such violations. Rather, we want to clarify any potential violations as much as possible, put a stop to them and learn from them for the future. This is the only way to improve our compliance management and reduce the likelihood of further compliance violations in the future.

We, therefore, support the submission of information on such compliance violations. Nonetheless, many reporters fear retaliation if they point out wrongdoings. For this reason, we have commissioned Grant Thornton AG Wirtschaftsprüfungsgesellschaft, to undertake receiving such information in the strictest confidence and follow up on it objectively with the requisite professional expertise. In parallel, it is prohibited in any way to sanction the person that reports in good faith. Reporters who act in good faith cannot be disadvantaged or subjected to retaliation in any way.

Reporting Channel OX Ethics & Compliance Tool

On the following page, you can access our OX Ethics & Compliance Tool, Grant Thornton's online-based reporting system.

https://open-xchange.gt-wbs.com

This system offers reporters the opportunity to confidentially report information on compliance violations, including anonymously if desired. At the same time, the E&C Tool opens the possibility of communication between the reporter and Grant Thornton, while guaranteeing the anonymity of the reporter.

This Tool does not utilize robots with automated response settings. Rather, each information is evaluated by qualified specialists and advised by a team of experts. Grant Thornton is committed to the objective and fair investigation of allegations of compliance violations. In addition, every reporter is regularly informed – as far as the processing of the submitted report permits - about the progress made in clarifying the facts he or she has reported.

Misuse of the OX Ethics and Compliance Tool

On the other hand, misuse of the E&C Tool will not be tolerated. We therefore point out that deliberately making untrue allegations about third parties may constitute a criminal offence or an issue that in and on itself constitutes a case under our Ethics & Compliance System.

Data Protection

As you all very well know, OX is committed to protecting personal information. In this subject matter, this not only means that the data subject rights of the reporter is being protected but also the rights of the alleged violater. We comply as usual with any and all appliccable data protection regulation.

Freedom from Seizure

OX is obliged to maintain confidentiality with regard to information received via the Channels. However, this information is generally not exempt from seizure, i.e. investigative or other authorities can seize this information and thus access it upon a corresponding court order. Further reporting possibilities

Independent of the Tool, our employees still have the option of contacting their supervisor, any other manager, the People or the Legal Team, a Board Member or the Ethics & Compliance Committee with information at any time.