All employees and business partners of the DRÄXLMAIER Group are invoked to report violations of law in order to limit the consequences of actions that are neither tolerated by law nor by our internal regulations and values, and to avoid future misconduct.

Accordingly, we have set up an effective complaints procedure to report violations of our Code of Conduct or violations of law. Standardized and fast processes as well as confidential and professional processing of reports and complaints by internal experts form the foundation of this system.

The most important information on the rules of procedure is presented below in a clear and comprehensible manner and with the greatest possible transparency. In addition, the respective national laws shall apply, where further details on the complaints procedure and data protection are regulated.

What kind of information can our complaints procedure be used for?

The complaints procedure can be used to report all indications of possible violations of laws and/or regulations, including human rights, environmental or compliance risks and violations relating to your own business area and along the entire supply chain. You can of course also submit your report anonymously, which we will be processed without restriction and in accordance to this complaints procedure.

This includes in particular misconduct in connection with

• Bribery and corruption,
• Unfair competition, in particular antitrust agreements,
• Human rights violations,
• Environmental damage,
• Adverse effects on the health and safety of persons,
• Fraud, embezzlement, theft, misappropriation,
• Money laundering,
• Data protection and information security,
• Sexual harassment or discrimination,
• Conflicts of interest.

Which complaint channels can you use to submit complaints?

Employees of the DRÄXLMAIER Group can always contact their direct line manager, the HR organization on-site, the local employee representative body and complaint letterboxes with reports of misconduct.

All employees of the DRÄXLMAIER Group and external persons can also submit complaints via the following central complaint channels:

Via the internet-based complaint channel INTEGRITY LINE. This complaint channel can be used to submit complaints worldwide around the clock, free of charge and in all languages at DRÄXLMAIER locations.

By e-mail or telephone directly to the Compliance Department:
E-Mail: compliance-office@draexlmaier.com
Phone: +49 8741 47 6561

In person: for personal complaints, please make an appointment in advance via compliance-office@draexlmaier.com to be agreed.

It should be noted that information received via these central complaint channels will be processed by the Group Compliance Office of DRÄXLMAIER Group SE & Co. KG, Landshuter Straße 100, 84137 Vilsbiburg, Germany, which will ensure the further processing of this information on violations of rules by employees of the DRÄXLMAIER Group or business partners along the supply chain.

For reports or complaints within the scope of DIRECTIVE (EU) 2019/1937 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of October 23, 2019 (so-called Whistleblower Guideline) and the corresponding national regulations, the following applies:

The central complaint channels for all companies of the DRÄXLMAIER Group are only considered additional complaint channels with regard to complaints to the respective local companies. At the locations of the DRÄXLMAIER Group, employees and external persons have access to additional, local complaints channels for receiving and processing reports. Employees and external persons can also submit complaints with information to external complaints offices. The local and external complaints offices for the DRÄXLMAIER Group locations in the European Union can be found here.

How will my complaint be dealt with?

Regardless of which complaint channel is chosen, we treat all information confidentially. If you wish to remain anonymous, this is guaranteed in any case. However, we are required to comply with statutory obligations to provide information to authorities and statutory exceptions to the confidentiality requirement. The confidentiality of the identity of the person providing the information and the other persons named in the information is maintained throughout the entire process.

All information received via the complaint channels listed above (INTEGRITY LINE, Compliance Department, Compliance Officer) is processed by the Compliance Department (hereinafter referred to as the Complaints Office). The officers dealing with the complaint are impartial, independent in the performance of their duties and obliged to maintain confidentiality. They are also obliged to comply with data protection regulations and to ensure transparency and the rights of all data subjects.

In order to ensure efficient processing, it may be that your complaint is forwarded to another compliance office at DRÄXLMAIER for further processing. Disclosure will only take place with your prior consent. In this case, we will inform you in advance to which other compliance office we would like to forward your report and at which DRÄXLMAIER company this compliance office is located. The DRÄXLMAIER company to which the report is forwarded for further processing is then co-responsible for the further processing.

How am I protected as an informant?

The protection of informants against discrimination or punishment on the basis of complaints or information provided is an important part of our complaints procedure. Attempts at intimidation and reprisals against persons who report actual or suspected misconduct in good faith will not be tolerated.

If you have the impression that you are suffering intimidation or reprisals as a result of your report, please contact the Complaints Office; such intimidation or reprisals will also be examined in accordance with the above procedures and, if necessary, investigated further.

Insofar as informants are affected who are employees of a direct supplier, DRÄXLMAIER endeavors to make appropriate contractual arrangements with the supplier.

What happens when I have submitted my complaint?

Receipt of the notice

Once a complaint has been received, the receipt is documented internally and the person making the report receives a confirmation of receipt within one week.

Checking the notice

The Complaints Office will first check whether there is sufficient information to examine and investigate the reported facts. If this is not the case, the Complaints Office will, if possible, contact the informant to request further information. If neither sufficient information is available nor is it possible to make contact, the case will be closed.

Clarification of the facts

In principle, the Complaints Office will investigate the matter itself or forward it to the competent body, e.g. within the company, for investigation, while observing the principle of confidentiality and data protection. Information about the informant and the facts of the case will only be passed on to the extent that is absolutely necessary for the investigation and the implementation of measures.

If relevant and as far as possible in the case of anonymous complaints, the Complaints Office or the responsible compliance office will discuss the facts of the case with the informant and may ask for further information. If, after investigating and establishing the facts and discussing the results, the complaints office or the responsible body is convinced that there are no compliance-relevant violations at law or violations of human rights or environmental regulations in its own business area or at suppliers, the case will be closed.

Development of a solution

If, in the opinion of the Complaints Office or the responsible compliance office, the investigation confirms compliance-relevant violations at law or violations of human rights or environmental regulations in its own business area or at suppliers a proposal for further action (in particular preventive and remedial measures) is drawn up. Where possible and appropriate, the informant is involved in this process.

Implementation and follow-up

The company of the DRÄXLMAIER Group that is responsible for the identified violation is also responsible for implementing the proposed solution to remedy this violation. In addition, the Complaints Office or the other responsible body monitors the implementation of the proposed solution with the involvement of the company concerned.

Conclusion of the procedure

The informant will be notified about the conclusion of the complaints procedure, provided that contact can be made. The processing time is highly case-dependent and can therefore take anywhere from a few days to several months. However, we endeavor to complete the investigation in a timely manner.

Status 04/25