Any whistleblower who acts in good faith is entitled to provide information. Whistleblowers acting in good faith are covered by the protection scope of these procedural rules. Good faith exists if the whistleblower assumes at the time of reporting that the information they provide is true.

Relevant are all violations of applicable law, in particular in the area of economic crime or violations of human rights-related and environmental obligations, specifically those pursuant to Section 2 (2) and (3) of the Supply Chain Due Diligence Act. But violations of the internal regulations of the Fuchs Gruppe can also be reported.

However, if you have a question about your order, want to make a complaint about a product, are dissatisfied with our services or our service, or have another concern, please use our usual contact options.

Please inform the compliance officer,

• at which company or company division
• what
• when
• where
• with which participants

happened.

Also of interest to the compliance ombudsperson is which other persons – possibly not involved in the specific incidents – are aware of this and whether there are any documents (e.g., emails, photos) related to it.

Please carefully check before giving the notice whether the information you provide is also factually correct. In particular, you must not provide any information that you know to be false.

Please also inform the Compliance Ombudsperson how they can reach you in case of follow-up questions.

There are no costs for the person giving the notice when a notice is issued.

If you are unsure, please use phrases like “I believe…”, “I consider it possible…”

In case of uncertainties in the presentation, the assessment, and/or the procedure, you can first – also anonymously – and free of charge, discuss the case with the Compliance Ombudsperson.

At the request of the whistleblowers, their identity will remain anonymous. Whistleblowers can arrange with the Compliance Ombudsperson how they can be contacted for follow-up questions if they wish to remain anonymous. Even in the case of an anonymous report, no false information may be transmitted. Whistleblowers can demand from Attorney Dr. Dilling that he does not disclose an identity known to him to the Fuchs Gruppe.

Informants can demand from the Compliance Ombudsperson that he protects their identity and that he does not disclose their identity or other information that could reveal their identity to the Fuchs Group.

As a lawyer, Dr. Johannes Dilling is bound by professional secrecy and must not disclose the identity of a person providing a tip that is known to him to third parties without committing an offense. Dr. Dilling has taken appropriate technical and organizational measures to protect the tips he receives so that third parties cannot access them.

The information that Dr. Dilling passes on to the Fuchs Gruppe is also treated confidentially and protected there. The individuals at the Fuchs Gruppe responsible for processing the reports are legally obliged to maintain confidentiality to the extent that violations of human rights and environmental obligations are reported. They are also contractually obligated to treat incoming reports and, in particular, the identity of a reporting person confidentially. In addition, the individuals at the Fuchs Gruppe responsible for processing the reports are independent and not bound by instructions. In particular, they do not receive any content-related or procedural instructions from management or the works council regarding the conduct of a procedure, such as the type, scope of the procedure, or its termination. The Fuchs Gruppe organizationally ensures that only those persons who are responsible for processing the notifications can access the notifications and the documents submitted with them.

Without the consent of the reporting person, even in the internal processing of reports at the Fuchs Gruppe, the identity of the reporting person as well as circumstances that allow conclusions to be drawn about the identity of the reporting person may not be disclosed.

No, it´s not.

On the one hand, the Whistleblower Protection Act provides in § 9 para. 2 for exceptions to confidentiality, which, for example, allow the identity of a whistleblower to be disclosed to a law enforcement authority if it so requires. Reference is expressly made to § 9 para. 2 HinSchG.

On the other hand, only persons who are acting in good faith enjoy protection of confidentiality, that is, who do not knowingly or with gross negligence provide false information. A whistleblower who knowingly or with gross negligence provides false information must expect that their identity will become known through a request for information by the affected person in accordance with Art. 15 para. 1 GDPR, and that the affected person will assert claims for damages.

Finally, neither Dr. Dilling nor the Fuchs Group have protection against seizure, i.e., in the event of an official investigation, authorities are allowed to seize documents that reveal the identity of the reporting person.

Persons providing information who fear that their identity will be revealed are therefore advised to submit a report anonymously. Even in an anonymous report, no false information may be transmitted.

If you are not sure, this also applies here: Please use formulations such as ‘I believe…’, ‘I consider it possible…’, ‘It could be that…’.

No, professional disadvantages and reprisals directed against whistleblowers are strictly prohibited. The Fuchs Gruppe Supplier Code also contains regulations that prohibit suppliers of the Fuchs Gruppe from taking reprisals when whistleblowers make a report. This also applies to the threat or attempt to carry out reprisals. Retaliatory measures due to reports will not be tolerated. Whistleblowers are encouraged to report if they are subjected to disadvantages and reprisals by Fuchs Gruppe employees or suppliers because they made a report in good faith. The Fuchs Group will respond appropriately to these employees or suppliers (e.g., warning, conducting a workshop, demanding compensation).

As part of the reporting procedure and also upon completion of the reporting procedure, the compliance ombudsperson will inquire with the reporting persons whether they have been subjected to reprisals by employees of the Fuchs Gruppe or by suppliers of the Fuchs Gruppe as a result of the report.

Auch nach Abschluss des Verfahrens können hinweisgebende Personen der Compliance-Ombudsperson es melden, sollten sie infolge des Hinweises seitens Mitarbeitender der Fuchs Gruppe oder seitens Lieferanten der Fuchs Gruppe Repressalien ausgesetzt sein.

The compliance officer is not a mediation body for disputes. The mandate relationship exists only between the company and the compliance officer. Nevertheless, the compliance officer acts impartially and is not bound by instructions from the Fuchs Gruppe. As a lawyer, the compliance officer is already legally obligated to maintain confidentiality.

The compliance ombudsperson will give you feedback within 24 hours to confirm that the report has been received. The compliance ombudsperson clarifies with the reporting person the facts of the case, what expectations the reporting person has regarding possible prevention or remedial measures, and examines whether the report falls within the scope of the complaint procedure, in particular whether there could be a human rights or environmental duty violation within the meaning of Section 2 (2) and (3) of the Supply Chain Due Diligence Act. If, from the perspective of the compliance ombudsperson, no relevant violation exists, they will explain this to the reporting person. If, on the other hand, a relevant violation appears possible, the compliance ombudsperson will prepare the report and forward it confidentially to the compliance officer of the Fuchs Gruppe. The compliance officer of the Fuchs Gruppe decides, together with company management if necessary, how to handle this report. If there are sufficiently concrete suspicions of legal or policy violations, these are investigated internally in order to clarify and remedy any potential misconduct. This also usually takes place confidentially and discreetly in order to protect the interests of the reporting person and of the individuals affected by the report. No later than three months after the report is made, the reporting person receives feedback from the compliance ombudsperson on whether the reported violation could be established. If this is the case, the violation is remedied. In doing so, the expectations of the reporting person are taken into account. The reporting person is encouraged to report again if, in their opinion, the remedial measures taken are insufficient.

You can contact the Compliance Ombudsperson in any conceivable way (phone, email, fax, mail, or via the whistleblower system www.safewhistle.info). The Compliance Ombudsperson is also available for personal meetings with whistleblowers, if desired, also via audio-visual transmission. If you wish for encrypted communication, you can also use the messaging services Signal and Threema to reach the Compliance Ombudsperson. It is also possible to send encrypted emails to the Compliance Ombudsperson via ProtonMail at the following address:

RADilling@protonmail.com

The contact details are as follows:

Dr Johannes Dilling, Solicitor

Landgrafenstraße 49

50931 Köln

Phone: +49 (0) 221 933 107 40

Mobile: +49 (0) 163 347 6111

Fax: +49 (0) 221 933 107 42

www.ra-dilling.de

www.safewhistle.info

Threema-ID: 3PX6278J

E-Mail: info@ra-dilling.de; RADilling@protonmail.com

Through the whistleblower portal www.safewhistle.info, the messenger services stored there, by email, and by postal mail, whistleblowers can report violations in a language of their choice stored there.

Likewise, reporting persons can request from the Compliance Ombudsperson that, during a personal meeting with the Compliance Ombudsperson, an interpreter who is specially obligated to confidentiality and can translate from and into the reporting person’s national language participates at the expense of the Fuchs Group.

At the special request of a reporting person, the Fuchs Group provides, at its own expense, a compliance ombudswoman as a contact person in individual cases.