Declaration of principle

STOOF International GmbH Policy Statement on Human Rights Strategy (“Policy Statement”)

The following policy statement on human rights strategy includes the legal requirements of the Supply Chain Due Diligence Act (LkSG) and the implementation of the LkSG within Stoof International GmbH.”

I. STOOF International GmbH’s commitment to respecting human and environmental rights

We, STOOF International GmbH (hereinafter referred to as STOOF), are aware of our corporate responsibility to respect human and environmental rights. We are therefore committed to respecting human and environmental rights in our own business activities and in our global supply and value chains and to providing access to remedy for those affected by human and environmental rights violations.

In doing so, we always base our corporate actions with regard to the observance of human rights and environmental due diligence obligations in particular on the following internationally valid and recognized principles and guidelines:

• Universal Declaration of Human Rights
• International Charter of Human Rights
• International Covenant on Civil and Political Rights
• International Covenant on Economic, Social and Cultural Rights
• ILO Declaration on Fundamental Principles and Rights at Work
• United Nations Guiding Principles on Business and Human Rights
• 10 principles of the UN Global Compact
• OECD Guidelines for Multinational Enterprises
• Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal
• Stockholm Convention on Persistent Organic Pollutants
• Minamata Convention on Mercury

The implementation of the human rights and environmental due diligence obligations is based on the above-mentioned national and international standards and framework conditions and is in line with the requirements of the LkSG. In addition to the Code of Conduct applicable to all persons belonging to STOOF and the Business Partner Code, which is binding for all business partners of STOOF, the Declaration of Principles sets out binding principles of conduct for respecting all human rights and environmental due diligence obligations regulated in the LkSG. It sets out STOOF’s corporate due diligence obligations to respect and comply with its human rights and environmental obligations towards its employees, business partners and other stakeholders along the entire supply chain.

We also expect our business partners to commit to respecting human and environmental rights, to establishing appropriate due diligence processes and to passing these expectations on to their own suppliers.

Compliance with the following human rights and environmental expectations within the meaning of the LkSG by our employees, business partners and suppliers are of essential importance to us:

• Prohibition of child labor and particularly harmful forms of work for children and adolescents
• Prohibition of slavery and forced labor
• Prohibition of unequal treatment and discrimination in the working environment in any form based on characteristics such as gender or gender identity, age, ethnic, cultural and social origin, descent and nationality, religion, belief or ideology, physical or mental disability, sexual orientation, family or marital status
• Respect for and compliance with the freedom of association, the freedom to form employee representative bodies and the right to collective bargaining
• Observance of and compliance with occupational health and safety obligations
• Prohibition of withholding an appropriate wage
• Prohibition of the unlawful appropriation of land, forests and waters whose
  the use of which secures the livelihood of people
• Prohibition of unlawful forced eviction
• Prohibition on hiring unreliable security personnel
• Prohibition of causing harmful soil change, water pollution, air pollution, harmful noise emissions or excessive water consumption that is likely to harm human health and impair or destroy access to natural resources (such as drinking water and food) and access to sanitary facilities
• Compliance with legal requirements regarding remuneration and working hours
• Compliance with the prohibition of violations of specific environmental obligations arising from the use, storage, transboundary movement or disposal of mercury (compounds), persistent organic substances or hazardous waste

II. Scope of application

This policy statement was adopted by the management of STOOF International GmbH and applies to STOOF’s entire own business area within the meaning of the LkSG. This includes STOOF based in Borkheide under and all companies in which STOOF has a direct or indirect shareholding of more than 50%. It applies without exception to all managers, members of management and all other employees of STOOF.

III. Responsibility, organization and risk management in accordance with Section 4 (1) LkSG

The overarching responsibility for respecting and upholding human rights and environmental due diligence in our direct business area and along our supply chains

lies with STOOF’s management. The management is directly responsible for specific monitoring.

Within the management there is a person responsible for monitoring risk management in accordance with Section 4 (3) LkSG. This applies to the segments

• Law
• Risk management
• Personnel
• Sustainability
• Purchasing

The following tasks:

• Monitoring of LkSG risk management
• Evaluation and assessment of the effect of necessary preventive/remedial measures

Monitoring is carried out on a regular basis; at least once a year, a report is submitted within the management team on activities, on ongoing risk management measures, identified risks, remedial measures and the implementation status of due diligence obligations.

The operational implementation of the operational duties arising from the LkSG, namely the establishment of risk management, the performance of risk analyses and the introduction of preventive measures, is carried out by the person responsible within the LkSG management unit.

The specific remedial measures are presented by the buyers responsible for the respective risk suppliers to those responsible and assessed by them regarding their effectiveness. Once the measures have been approved by the management, they are implemented and documented by the responsible buyers and the respective implementation status is discussed by the management.

By defining the above responsibilities and accountabilities, risk management is anchored in all relevant areas and key business processes and the implementation and monitoring of human rights and environmental due diligence obligations is ensured by a risk management system that covers the risks in our own business area and along the supply chain and is subject to continuous further development.

Iv. Risk analysis according to § 5 para. 1 LkSG

We consider it part of our duty of care to be aware of potential and actual adverse human rights and environmental risks and impacts of our business activities on people along the entire supply and value chain. We therefore identify and assess the relevant

human rights and environmental issues and those potentially affected by our business activities and our business relationships. Identifying risks and potential impacts and deriving effective measures are core elements of implementing our human rights and environmental due diligence obligations.

When identifying and analyzing potential human rights and environmental risks, we focus first and foremost on corresponding risks in our own business area, in the business area of our relevant affiliated companies and at our direct suppliers. We proceed as follows using an online tool procured from an external service provider:

A variety of sources are used to determine an abstract risk for our direct suppliers based on the location and economic sector according to the NACE classification.

Based on the abstract risk value, a concrete risk analysis is carried out if necessary. Here, the specific sub-risks are queried with the help of suitable certificates, documents or self-disclosures from the supplier concerned.

If there are actual indications that a violation of a human rights or environmental due diligence obligation by an indirect supplier is possible, a risk analysis is also carried out in relation to the indirect supplier concerned. The procedure is similar to that for direct suppliers.

In our management process, we consider the findings of our risk analysis as well as human rights and environmental criticism from third parties and reported incidents. The analysis of human rights and environmental risks and impacts is updated annually and whenever there are significant changes to the company’s profile or business activities. The results of the analysis of human rights and environmental risks and impacts are continuously evaluated and integrated into our internal decision-making and business processes. They are thus incorporated into our corporate decision-making processes with regard to supplier selection, business partner management, our service provision processes and product responsibility and development. The risk analysis forms the basis for the identification of appropriate measures, for suitable preventive or corrective measures within our own operating processes and at our direct suppliers.

We also use the results of the risk analysis as a basis for creating and, where necessary, adapting internal regulations, processes and training to meet the changing requirements of our due diligence processes. Our risk management and analysis serve the goal of identifying, preventing, ending or at least minimizing human rights risks and violations of legal rights along the supply chains, insofar as ending them is not possible or would involve disproportionate effort. Risk analysis is seen as a continuous improvement process.

V. Identified potential risks and preventive measures in accordance with Section 6 (2-5) LkSG

The results of the risk analysis are updated and written down annually and recorded together with the main risks identified and the measures taken. These are properly documented and stored for a period of at least seven years in accordance with legal requirements.

In our view, potentially increased risks for our supply chain and respect for human and environmental rights could arise from transport and works service providers and temporary employment agencies, particularly in minimum wages. As a result, we focus on these service providers and companies, so that minimum wages are monitored preventively and the obligation to comply with minimum wage regulations is contractually agreed with them.

To fulfill our responsibility to respect human and environmental rights, we rely on a combination of different measures. The aim is to protect the (potentially) affected persons and to prevent or at least minimize adverse human and environmental impacts on them. We have established standardized processes for this purpose.

In order to avoid human rights and environmental risks and the violation of human and environmental rights in our own business area and at our direct suppliers as far as possible, we implement the following preventive measures in particular:

We have updated both the STOOF Code of Conduct and our Business Partner Code, as well as our General Terms and Conditions of Purchase (GTCP) about the LkSG and the human rights and environmental due diligence obligations set out in these and published them on the STOOF corporate website. The Code of Conduct and the Business Partner Code set out STOOF’s human rights and environmental expectations for all persons associated with STOOF International GmbH and its business partners.
Compliance with them and full compliance with the applicable laws by all persons associated with STOOF and our business partners, particularly our direct suppliers, are mandatory for us.

In our procurement strategy, we assume that all of our direct suppliers accept our Business Partner Code, and the principles of conduct set out in it as the basis for legally compliant business cooperation.

This is done by incorporating our Business Partner Code into our contracts either by signing the contract document, through corresponding separate contractual assurances or via our GPC. As a further prevention tool, we use general and specific LkSG training courses to support and raise awareness among the people associated with STOOF who are particularly affected by compliance with and monitoring of the LkSG duty of care, in

particular all managers and all people involved in procurement and the complaints committee.

If necessary, we also offer our direct suppliers LkSG training courses tailored to their needs if risks arise, to familiarize them with the contents of our Business Partner Code and the STOOF principles of conduct and expectations contained therein and to reinforce these. In our Business Partner Code, we have also reserved audit and control rights, in particular the option to carry out ad hoc and risk-based audits of our suppliers’ compliance with and implementation of our human rights and environmental expectations to minimize the risk of human rights and environmental violations.

We also carry out risk-based audits within STOOF and investigate all indications of potential human and environmental rights violations.

VI. Remedial measures according to § 7 LkSG

If we as a company have directly caused a violation of human rights and environmental due diligence obligations, we work quickly to prevent the business activities that caused this or to make them compliant with human and environmental rights and work towards redress. If our employees behave in a way that is incompatible with human and environmental rights, appropriate sanctions are introduced. If we contribute to potential or actual human rights or environmental rights violations through our business activities or are indirectly associated with them, we endeavor to contribute to appropriate remediation and prompt redress by the responsible parties. If we have a well-founded suspicion or concrete indication of possible human or environmental rights violations in our company or along our upstream and downstream value chain, we investigate this carefully and consistently. We oblige our business partners to support us in clarifying the facts and to cooperate fully within a reasonable timeframe. Depending on the severity of the violation, we reserve the right to respond appropriately to our business partners, from requesting that the violation be remedied immediately to taking legal action and terminating the business relationship. Irrespective of this, we will work towards remedying the breach.

VII. Supply chain complaints procedure in accordance with Section 8 LkSG

STOOF has been operating the web-based whistleblower system ‘Intertek’ from APS internally since 2021. STOOF employees and external persons (third parties, business partners) can use this complaints procedure to report any misconduct, in particular (potential) serious violations of applicable laws and internal guidelines, including human rights and environmental risks and violations of human rights-related or environmental obligations. Since 01.01.2024, this web-based whistleblower system has also been a key component in fulfilling STOOF’s obligations under the Supply Chain Due Diligence Act about the establishment of a complaints procedure. Both our employees and external persons can use this system to submit information, in

particular anonymously. It can be accessed around the clock and is available to our employees and business partners as well as other third parties for reporting human rights and environmental risks and breaches of duty in the STOOF area and along the supply chain.

The supply chain complaints procedure is publicly accessible via the STOOF website and via a corresponding tab on the homepage at https://www.stoof-international.de/. Our external rules of procedure are also published there.

A central complaints committee has been set up at STOOF to process the reports received via the supply chain complaints procedure.

The implementation of the supply chain complaints procedure is monitored by the person responsible.

VIII. Effectiveness monitoring in relation to the measures taken and the supply chain complaints procedure

We review the effectiveness of our risk management, our due diligence processes and the associated measures to prevent and mitigate adverse human rights or environmental impacts once a year and on an ad hoc basis in the event of significant changes in the risk situation or specific indications of restrictions in complaints management. This includes reviewing the effectiveness of our
supply chain grievance procedure, our risk management and remedial measures as well as preventive measures.

IX. Documentation and reporting in accordance with § 10 LkSG

Our efforts and measures to fulfill the due diligence obligations arising from this declaration of principles and the LkSG are continuously documented within the company in accordance with the legal requirements.

Continuous further development of our human rights and environmental due diligence processes

Respecting human and environmental rights and implementing human rights and environmental due diligence in our operational processes is an important contribution for us to improving the human rights situation along the global supply and value chains. We accept this challenge and are committed to continuously reviewing our processes to ensure compliance with human rights and environmental due diligence obligations
and adapt them based on our findings and experience, the development of our business activities and any changes to the legal and statutory situation. Borkheide, 31.01.2024