KOSTAL Code of Conduct English

Honesty is the best policy. Zero tolerance for intolerance! Human rights are non-negotiable. CODE OF CONDUCT Lawful, compliant, responsible & fair behaviour CODE OF CONDUCT Behavior towards employees Code of Conduct With great power comes great responsibility. We are We are family. family. CODE OF CONDUCT Leading by example CODE OF CONDUCT Competition & antitrust law CODE OF CONDUCT CODE OF CONDUCT Vermeidung von Interessenskonflikten Avoiding conflicts of interest ···········I Sorry! Life has no undo button. Made with Love. All egos aside. CODE OF CONDUCT Confidentiality CODE OF CONDUCT Occupational health & safety & environmental protection CODE OF CONDUCT Products CODE OF CONDUCT

Content 1. Principles Lawful, compliant, responsible and fair behaviour Indications of possible irregularities Cooperation with authorities Leading by example Behaviour towards employees Responsibility towards society 2. Protection of relationships of trust Avoiding conflicts of interest Dealing with information Documents Company property Data protection and information security E-mail and Internet use Confidentiality 3. Shaping KOSTAL business relationships Conduct towards business partners and third parties Competition and antitrust law Supplier and customer relations Corruption and bribery Export and import control Money laundering Taxes, duties and customs Donations and sponsorship 12 12 15 15 15 16 17 21 21 22 22 22 24 24 25 28 28 28 30 31 32 32 32 32 6

4. Production and development Products Intellectual property and expertise Occupational health and safety and environmental protection 5. Scope of application 6. Reporting violations of the Code of Conduct, company policies or laws 38 38 39 40 44 48 7

Introduction KOSTAL is over 100 years old and in all these years we have been and continue to be sustainably very successful in what we have done and are doing. To continue this, it is essential that we abide by the law and act with integrity. It goes without saying that each and every one of us is committed to this. KOSTAL is aware of its social responsibility in all its global activities and sees this as a fundamental element of sustainable success. As a family-run business, we know how to preserve, develop and pass on a legacy for future generations. Sustainable business practices that protect the environment and resources, and put people first, are key to preserving our legacy – perhaps even more so today than in the past. This Code of Conduct shows you how we think and act at KOSTAL and which values guide us in all that we do. It forms the foundation on which all other guidelines are based. Acting ethically and with integrity enables KOSTAL to continue to build and maintain its excellent reputation in the industry, to attract and retain outstanding colleagues and to meet the high expectations placed on us by our customers, suppliers, partners and society. This Code of Conduct provides you with an understanding of how the company and you must act sustainably, today and in the future – wherever you are in the world. It shows what is expected of you, your colleagues and our business partners in the course of your work. Please read this Code of Conduct carefully and observe the principles of conduct it covers. Do not be afraid to ask if you are not quite sure how to interpret individual principles. Your supervisors and the Legal and Compliance Department will be happy to help you. Andreas Kostal Kai Knickmann Dr. Gregor Mark Schmeken Executive Director Managing Director Managing Director 8

KOSTAL CODE OF CONDUCT Principles 1. Principles Lawful, compliant, responsible and fair behaviour As a globally active group of companies, KOSTAL faces up to its social responsibility. KOSTAL employees always follow the principles of sustainable and responsible action, the applicable laws and the KOSTAL guidelines in their actions, measures, contracts and all processes. KOSTAL employees are honest and reliable towards our customers, the authorities and the public. Acting in a sustainable and future-oriented way is important to KOSTAL. As a group of companies, we are striving to achieve CO2 neutrality, we have implemented a programme that defines compliance with further important sustainability goals and we are working on their implementation. Sustainability is a high priority at KOSTAL and enjoys priority. All KOSTAL employees are therefore expected to act in accordance with these goals and to align their actions with them in the course of their work. KOSTAL pays the applicable taxes, duties and customs, complies with competition and antitrust law, does not engage in corruption, bribery or money laundering and ensures that its products are state of the art. Necessary official approvals are obtained, export control regulations are followed and the rights of third parties are respected. Should we fail to comply with these principles, we as a company or as employees would not only be threatened with business or personal disadvantages through loss of reputation, criminal prosecution, fines or claims for damages, we would also be acting contrary to KOSTAL values. Therefore, it is important for us to always act in accordance with these principles, even if this means having to accept business disadvantages in individual cases. Everyone in the company is responsible for ensuring that the laws and KOSTAL guidelines are adhered to in our work area. The working environment must be continuously checked from this point of view and for compliance with these principles. The managers and the Legal and Compliance Department are available at any time and in confidence to discuss and clarify possible uncertainties and must also be approached in such cases. If a potential or actual violation falls under the Whistleblower Protection Act (‘HinwSchG’), KOSTAL employees are completely free to report such a violation directly to an external reporting office within the meaning of §§ 19 ff. HinwSchG instead of internally. The KOSTAL Whistleblower Guidelines provide further assistance in this regard. 12

Indications of possible irregularities Every KOSTAL employee is required to report possible or actual violations of the provisions of this Code of Conduct, KOSTAL guidelines or applicable laws through appropriate channels, whether through supervisors, the Legal and Compliance Department or the KOSTAL compliance hotline operated for us by a professional external company. It is better if you can give your name, but anonymous reporting is also possible. Any information will be treated in strict confidence. Any form of disadvantage or discrimination against KOSTAL employees who have made a report in good faith and not in an abusive manner is excluded and will not be tolerated, even in the event that the report later proves to be unfounded. Cooperation with authorities KOSTAL maintains a cooperative relationship with authorities and as KOSTAL employees we always cooperate fully with lawful investigations conducted by KOSTAL itself or by authorities. Of course, the legal rights of each individual, such as rights to testify and refuse to testify and other procedural rights, remain unaffected. Leading by example Managers are obliged to prevent violations of legal requirements, the Code of Conduct and all other applicable KOSTAL guidelines in their areas of responsibility and to monitor these regularly. They ensure that their employees are familiar with the Code of Conduct and all other KOSTAL guidelines, that their rules are adhered to and that disciplinary action is taken against anyone violating them, regardless of the employee‘s hierarchical position in the company. Managers act as role models for employees and inform them about the regulations of the Code of Conduct, discuss them with them and, together with the Legal and Compliance Department, are available as points of contact. They are in regular dialogue with their employees about compliance. 15

KOSTAL CODE OF CONDUCT Principles Human rights are non-negotiable. RESPONSIBILITY TOWARDS SOCIETY KOSTAL CODE OF CONDUCT Behaviour towards employees The personal dignity of each individual is protected and respected. Discrimination on the basis of age, gender, race, skin colour, social or ethnic origin, nationality or sexual orientation, religious or political conviction or other legally protected characteristics will not be tolerated, nor will any form of physical or psychological harassment or violence. Diversity and equal treatment are a matter of course at KOSTAL. Employees working for KOSTAL must have reached the minimum age required by law. All employees have a right to freedom of association and to have their interests represented by their elected representatives. KOSTAL respects the statutory minimum wage and complies with the nationally applicable labour laws without exception. Inappropriate behaviour must be reported to Human Resources or the Legal and Compliance Department. 16

Responsibility towards society KOSTAL bears considerable social responsibility as an employer and along the entire value chain. Sustainable management, fair and responsible dealings with each other within the company and with business partners, is a prerequisite for our sustainable and long-term success. KOSTAL complies with all protective laws, such as the German Due Diligence Act and the equivalent laws of the countries in which KOSTAL operates. KOSTAL expressly condemns and rejects the violation of human rights and any form of forced or child labour and modern slavery, expecting the same of all business partners, and ensures that human rights are fully respected. KOSTAL stands for fair working conditions along the entire supply chain and the internationally recognised standards of the International Labour Organisation (ILO) are binding for KOSTAL. KOSTAL is expressly committed to the principles of the UN Global Compact and acts in line with these principles. BEHAVIOR TOWARDS EMPLOYEES KOSTAL CODE OF CONDUCT Zero tolerance for intolerance! CODE OF CONDUCT Behavior towards employees 17

2. Protection of relationships of trust Avoiding conflicts of interest Secondary employment is generally not permitted and may only be taken up in exceptional cases and with KOSTAL‘s prior written consent. Employees are only permitted to hold a significant interest in competitors, suppliers or customers with the prior written consent of KOSTAL in individual cases. A significant interest exists if the employee can influence the business directly or indirectly. Business with companies in which a life partner or close family member has a share or is employed in a managerial capacity may also only be carried out with the prior written consent of KOSTAL. Approval can be refused if it cannot be ruled out that this relationship could influence the business relationship and there is a possibility of a conflict of interest. Conflicts of interest must be avoided. If a KOSTAL employee recognises that circumstances exist which could bring them into conflict with the interests of KOSTAL in the course of their work for KOSTAL, they must immediately inform their superior. The superior must then consult with the legal and compliance department and, if necessary, the human resources department to determine whether and to what extent a conflict of interest actually exists and how this conflict of interest can be resolved. 21

Dealing with information Documents rnal and external documents of any kind, such as customer and sales documents, technical documents, financial documents, expense reports, and time tracking documents, must be accurate and truthful and correctly reflect the corresponding transaction. The principles of proper accounting and reporting must be adhered to, and data collection and other records must be complete, correct, timely, and system-compatible. Legal retention or deletion periods are observed and the locally applicable deadlines are adhered to (such as the 10-year period for tax documents in Germany). Other documents are subject to a retention or deletion period determined by KOSTAL. Company property The proper use and protection of company property is the responsibility of each employee. Company property provided may only be used for business purposes and must be handled with care and in accordance with the guidelines applicable to it. 22

KOSTAL CODE OF CONDUCT Protection of relationships of trust ···········I CODE OF CONDUCT Confidentiality CONFIDENTIALITY KOSTAL CODE OF CONDUCT Data protection and information security The protection of privacy, the protection of personal data and the security of all business information are carried out in compliance with legal requirements. Data is protected against unauthorised access and loss, whereby a risk-appropriate standard is maintained that is technically and organisationally oriented to the relevant state of the art. Compliance with data protection and information security requirements is ensured at all times in all business processes. Questions in this regard will be answered by the Legal and Compliance Department as well as the Data Protection Officer. The KOSTAL data protection guidelines contain further explanations and help. E-mail and Internet use Even if many e-mails have a rather informal character, every e-mail sent constitutes a business document and must be treated accordingly. E-mails must comply with the KOSTAL business principles. E-mails and the Internet may only be used for official purposes. 24

KOSTAL CODE OF CONDUCT Shaping KOSTAL business relationships 3. Shaping KOSTAL business relationships Conduct towards business partners and third parties Competition and antitrust law Our customers value working with us because of our competitive products, technologies and prices as well as our reliability, but not because we behave dishonestly. At the same time, we are in competition with many other companies and customers. Compliance with the rules of free and fair competition within the framework of legal regulations is an integral part of our actions and our self-image. This means that competitors are not permitted, either directly or indirectly, to divide up territories or customers, to collude or exchange information on prices, their components or other competitive parameters, supply relationships and their conditions, existing or future production capacities or supply behaviour. This also applies to exchanging information on market strategies or participation strategies. Written contracts or verbal agreements on this or tacit, coordinated parallel behaviour are generally not permitted. Agreements or information on research and development projects are only exchanged within a strictly limited and legally permissible framework and always require the involvement of the Legal and Compliance Department. Customers and buyers determine their resale prices independently and without influence from KOSTAL. The respective national competition and antitrust laws are fully observed. A strong market position is not abused, for example to enforce price discrimination or refusal to supply. For further information, please refer to the corresponding KOSTAL policy. 28

KOSTAL CODE OF CONDUCT Shaping KOSTAL business relationships Supplier and customer relations Agreements with suppliers and customers are fully and clearly documented, including subsequent changes and amendments. The internal control rules are complied with. Suppliers are selected only on a competitive basis, taking into account price, quality, performance and suitability with regard to the products and services offered. All suppliers and customers must complete a thorough and risk-appropriate business partner check before a business relationship is established. In particular, it must be determined whether the business partner is able to guarantee compliance with the applicable laws. The KOSTAL Code of Conduct for Suppliers and Business Partners contains further regulations. Hard to get. Not just playing. 30 CORRUPTION & BRIBERY KOSTAL CODE OF CONDUCT

SUPPLIER & CUSTOMER RELATIONS KOSTAL CODE OF CONDUCT Proof of Concept. CODE OF CONDUCT Supplier & customer relations Corruption and bribery KOSTAL does not tolerate any form of corruption or active or passive bribery. Such conduct by employees or business partners is punishable by law and leads to distortions of competition as well as financial and reputational damage for KOSTAL. Donations to public officials or persons equivalent to them are not permitted. Even the mere appearance of influence must be avoided. KOSTAL employees may also not accept benefits from public officials. No benefits shall be offered or granted to public officials for performing or expediting official acts – regardless of whether there is a claim to the performance of the official act or whether the public official violates their official duties through their actions. In business dealings with customers, suppliers and other third parties, any form of corruption or bribery or other unfair influence on business decisions is not permitted, for example in connection with agreements on the procurement, award, delivery, processing and payment of orders. Services which may be assumed to be intended in whole or in part for the payment of bribes may neither be agreed upon nor provided. If representatives or other intermediaries are commissioned by KOSTAL to obtain orders or approvals for KOSTAL, they shall be obliged in writing to act in accordance with the law and to refrain from bribing or granting advantages or accepting bribes. In the event of a violation, it must be possible to terminate the relationship with this person without notice. 31

KOSTAL CODE OF CONDUCT Shaping KOSTAL business relationships The giving or acceptance of gifts or other benefits is only permitted if they have negligible financial value (e.g. promotional pens or promotional mugs). Business invitations may only be extended or accepted in an appropriate setting. Any form of extravagance is not permitted. For further information, please refer to the relevant KOSTAL guidelines, such as the KOSTAL Anti-Corruption Guideline and the KOSTAL Gifts Guideline. Export and import control KOSTAL complies with applicable export and import laws, such as sanctions, embargoes and other laws, regulations and government orders or policies. These laws are extensive and can be difficult to apply due to KOSTAL‘s global operations. The Legal and Compliance Department is available to answer questions on this matter. Money laundering KOSTAL is subject to certain obligations under national anti-money laundering laws that may apply or have an impact internationally. Therefore, all questionable or dubious financial transactions must be reviewed and clarified, whilst all business relationships must be continuously monitored. Taxes, duties and customs As a globally active group of companies, KOSTAL is obliged to pay various types of taxes, duties and customs. These taxes, duties and customs are calculated correctly and paid on time. Donations and sponsorship The management of the respective KOSTAL company decides in a transparent manner and on the basis of the relevant laws and after consultation with and prior approval of the legal and compliance department on whether donations of money or in kind or sponsoring to promote education, science, culture or for social and charitable purposes are granted. If a donation is approved, it must be documented appropriately and recorded correctly in the accounts. For further information, please refer to the relevant KOSTAL guideline. The above principles apply accordingly to the granting of sponsorship. Further details are regulated by the KOSTAL Donations and Sponsoring Guidelines. 32

Whistleblowing KOSTAL has set up a whistle-blower system (pursuant to the German “Hinweisgeberschutzgesetz”, the applicable European regulation and other relevant laws applicable in other countries) that enables employees and other persons to inform KOSTAL of potential or actual violations of legal provisions, including human rights and environmental risks at KOSTAL and in its supply chains. Further information is available here: www.kostal.com/de-de/verantwortung/code-of-conduct/compliance- verstoss-melden/. KOSTAL expects its suppliers to either set up an appropriate whistleblowing system or to inform their employees in the most effective way possible about the possibility of using KOSTAL‘s whistleblowing system. 35

KOSTAL CODE OF CONDUCT Production & development Occupational health and safety and environmental protection Safety and health protection form an essential part of our responsibility and activities. Therefore, all applicable, relevant regulations and work instructions must be followed without restriction and the legally required protective equipment must be used in each case. Economic activity and environmental protection are interdependent and form the basis of sustainable and resource-conserving value creation. In this way, KOSTAL makes a significant contribution along the supply chain to the sustainable use of resources (including conflict minerals) for environmental and climate protection. KOSTAL conserves resources by continuously adapting the production, quality and performance of its products with a view to their environmental compatibility and by reducing the consumption of energy, water and raw and operating materials, whilst using renewable energies wherever possible. 40

KOSTAL CODE OF CONDUCT Reporting violations 6. Reporting violations of the Code of Conduct, company policies or laws KOSTAL requires all employees to report potential and actual violations in good faith. This can be done through the supervisors or their superiors. The Human Resources Department and the Legal and Compliance Department are also available for this purpose. KOSTAL maintains an independent compliance hotline through which possible violations can also be reported. Although it is preferable for a name to be given for easier communication and clarification of the facts, this is voluntary and there is always the option to remain anonymous. If such a potential or actual violation falls under the Whistleblower Protection Act (‘WPA’), employees are completely free to report such a violation directly to an external reporting office within the meaning of §§ 19 et seq. WPA instead of internally. Employees who report potential or actual violations impartially and in good faith are fully protected from reprisals, discrimination or disciplinary action, even if the report is subsequently found to be unjustified. Every report is taken seriously, treated in strict confidence and processed. KOSTAL will not tolerate any form of discrimination against employees who report possible or existing violations in good faith. Contact information E-Mail: compliance@kostal.com Speak Up Company code for registration: 108466 Chief Compliance Officer: Internet: Sebastian Petrausch www.kostal.com/en-gb/ verantwortung/code-of-conduct/ report-compliance-violation/ Compliance contact of the KOSTAL Group 48

KOSTAL Group The KOSTAL Group is an internationally operating family business with headquarters in Germany that specialises in the development and production of electronic and mechatronic products for the automotive industry and industrial applications. The company was founded in 1912 by Leopold Kostal. Today, the group comprises several business areas, including automotive electrics, connector systems, industrial electronics, photovoltaic inverters, charging technology and test systems. KOSTAL Automobil Elektrik KOSTAL KOSTAL Connectors Performance / comfort electronics and driving / comfort controls elements for vehicles Connector systems for the automotive industry KOSTAL Industrie Elektrik Control and power electronics electronics, drive controllers and inverters for photovoltaic systems Compleo Charging technology for electromobility SOMA Industrial solutions for testing technology & automation, dosing technology and worker assistance 55