Beiersdorf : Code of Conduct for Business Partners

Beiersdorf

PRINCIPLES FOR BUSINESS RELATIONS

CODE OF CONDUCT

VERSION 2023

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INTRODUCTION

At Beiersdorf we have been caring about skin since 1882. Our Sustainability Agenda CARE BEYOND SKIN is an integral part of our corporate strategy C.A.R.E.+ and guides our actions to deliver a positive impact on people, society and the environment.

This Code of Conduct for Business Partners ("Code of Conduct" or "CoC") represents the foundation for all cooperation between Beiersdorf and its Business Partners and replaces all previous versions of the Code of Conduct for Business Partners.

In this Code of Conduct, Beiersdorf defines the requirements that must be met by all of its global Business Partners including their affiliated companies. Such Partners are obliged to ensure that their subcontractors and suppliers along the supply chain also meet these requirements.

The cooperation between Beiersdorf and its Business Partners is based on a culture of trust, mutual respect, openness, a fair balance of reciprocal interests and equal opportunities. Both parties understand that complying with applicable laws and safeguarding social and environmental standards are the foundation for a lasting and successful cooperation.

As well as country specific statutes and official requirements, the following serve to reinforce and interpret the principles outlined below: the UN's Universal Declaration of Human Rights, the conventions of the International Labour Organisation (ILO), the OECD Guidelines for Multinational Enterprises, the principles of the UN Global Compact, and the general principles pertaining to Anti-Corruption and Competition Laws.

CONTENT

1  COMPLIANCE WITH LAWS	5
2  HUMAN RIGHTS AND
WORKING ENVIRONMENT	5
2.1 PROHIBITION OF CHILD LABOR	5

2.2 EXCLUSION OF HUMAN TRAFFICKING, FORCED LABOR

	AND DISCIPLINARY MEASURES	5
2.3	OCCUPATIONAL HEALTH AND SAFETY	6
2.4	DIVERSITY AND EQUAL OPPORTUNITIES	6
2.5	WORKING TIME	7
2.6	REMUNERATION	7

2.7 FREEDOM OF ASSOCIATION AND RIGHT TO

COLLECTIVE BARGAINING	8
2.8 LAND RIGHTS	8

3 ENVIRONMENTAL PROTECTION	9
3.1	INTRODUCTION	9
3.2	EMISSIONS	9
3.3	RESOURCE EFFICIENCY AND ENERGY CONSUMPTION	10
3.4	WASTE MANAGEMENT	10
3.5	HAZARDOUS SUBSTANCES	10
3.6	FOREST & BIODIVERSITY PROTECTION	11

4  BUSINESS INTEGRITY	11
4.1	ANTI-CORRUPTION	11
4.2	DATA PROTECTION	11
4.3	FREE COMPETITION	11
4.4	INTELLECTUAL PROPERTY	12

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4.5	INTERNATIONAL TRADE LAWS	12
4.6	MONEY LAUNDERING	12
4.7	TAXES	13

5 MANAGEMENT APPROACH	13
6  BREACHES OF THE
CODE OF CONDUCT	14
6.1	INDICATIONS OF BREACH OF THE CODE OF CONDUCT	14
6.2	REMEDYING A BREACH OF THE CODE OF CONDUCT	14
6.3	CONSEQUENCES OF A BREACH OF THE
	CODE OF CONDUCT	14
6.4. REPORTING A BREACH OF THE CODE OF CONDUCT	15
7  AMENDMENTS	15
REFERENCES	16

1  COMPLIANCE WITH LAWS

Business Partners shall comply with all applicable laws and regulations of the country in which the company has its registered office as well as of countries in which operations are managed or services provided.

2  HUMAN RIGHTS AND WORKING ENVIRONMENT

2.1 PROHIBITION OF CHILD LABOR

The exploitation of children and child labor is prohibited. The minimum working age is 15 years.Should national laws require a higher age,this shall apply instead.The Business Partner must ensure that proof-of-age documentation is in place for all employees and that the rights of young employees are protected in compliance with the applicable laws and regulations.

As a general rule, young persons under the age of 18 years shall not work at night for a period of at least twelve consecutive hours, including the interval between ten o'clock in the evening and six o'clock in the morning. The minimum age for admission to any type of employment or work that, by its nature or the circumstances in which it is carried out, is likely to jeopardize the health, safety or morals of young persons (e.g., hazardous work), shall not be less than 18 years.

2.2 EXCLUSION OF HUMAN TRAFFICKING, FORCED LABOR AND DISCIPLINARY MEASURES

Business Partners, including their labor agents / agencies, must adhere to regulations prohibiting human trafficking - in particular for the purpose of all forms of modern slavery and forced labor - and comply with all applicable local laws in the countries in which they operate. Forced or involuntary labor is prohibited. This applies especially to any form of

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forced labor exacted from a person under the threat of penalty (e.g., by withholding identification papers).

The service of an employee must be given willingly. Business Partners shall provide their employees with written employment contracts that shall comply with national regulations. Employees have the right to terminate their employment contracts after giving a reasonable notice period. The Business Partner must not engage in, support or allow any form of physical or psychological punishment, torture, inhumane or degrading treatment, mental or physical coercion, verbal abuse, harassment or threat.

2.3 OCCUPATIONAL HEALTH AND SAFETY

The Business Partner must, above all, be compliant with all applicable laws and regulations and maintain a proper Safety and Health management system that, together with all employees, works to prevent work-related illnesses and injuries.

It is expected that the management system is based on internationally recognized standards (e.g., ISO 45001) and that it fulfills the applicable requirements of the ILO Conventions; these include providing suitable working conditions that are safe and healthy for workers, being well-prepared for emergency situations, ensuring that employees receive adequate safety and health training and being equipped to promote a continual improvement process.

2.4 DIVERSITY AND EQUAL OPPORTUNITIES

All employees shall have the right to equal treatment, social benefits and equal op- portunities. Any discrimination on the grounds of gender, color, race, age, religion or ideology, social class or origin, ethnic and national origin, caste, disablement, marital or family status, pregnancy and physical characteristics, membership of employee organizations including unions, political opinion, sexual orientation or any other personal characteristics, are prohibited.

This applies to employment, wages, access to further training, promotion, the ending of the employment relationship or retirement, among other things. Any form of harassment of employees must not be tolerated by the Business Partner.

2.5 WORKING TIME

Working hours shall comply with the applicable laws and the current industry stand- ards; the more strict regulation shall apply. Weekly working hours should not regularly exceed 48 hours, in compliance with the applicable laws and regulations.

Overtime must be worked on a voluntary basis and may not amount to more than 12 hours per week. Every employee shall have the right to at least one free day (twenty-four consecutive hours) after six successive workdays.

Adequate vacation entitlement and maternity leave shall be provided, taking into account local statutory requirements.

2.6 REMUNERATION

Remuneration for regular working hours and overtime must comply with the applicable laws or the current industry standards; the more strict regulation shall apply. Local minimum wages must be adhered to. Insofar as these are not sufficient to cover living expenses, the Business Partner is obliged to pay remuneration that covers basic needs and living expenses. Remuneration and benefits must be based on job performance in a non-discriminatory manner and compensation has to be reviewed on a regular basis.

Unauthorized deductions or deductions in remuneration as a disciplinary measure are forbidden. Employees must receive all compensation as specified in law. The Business Partner must ensure that its employees receive transparent, detailed and regular information on the calculation of their remuneration. Remuneration must be paid on time, at regular intervals (at least monthly) and in accordance with the applicable laws and regulations.

Business Partners, labor agents / agencies or any other third party associated with recruitment must not require workers to pay recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, the money must be repaid. Those fees can include legal fees, passport and visa processing, medical exams, training and personal protective equipment.

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2.7 FREEDOM OF ASSOCIATION AND RIGHT TO COLLECTIVE BARGAINING

In compliance with the applicable laws, the Business Partner must respect the right of the employees to establish organizations of their choice, to join them, to attend meetings and to conduct collective negotiations.

In situations where the rights to freedom of association and collective negotiations are limited by law, other opportunities must be granted for the independent and free union of the employees for collective negotiation.

The Business Partner must protect employee representatives against discrimination and ensure that they are able to fulfil their mission without fear of reprisal, interference, intimidation or harassment. Furthermore, the Business Partner must be granted free access to the workplaces of their colleagues in order to ensure that they are able to exercise their rights in a lawful manner.

2.8 LAND RIGHTS

Business Partners must respect land, forest and water rights of the people and communities affected by their operations and sourcing practices. All negotiations with regard to their property or land, including the use of and transfers of it, must adhere to the principles of free, prior and informed consent, contract transparency and disclosure.

Business Partners must not engage in any form of land-grabbing. All required environmental permits, approvals and registrations must be obtained, maintained and kept.

3  ENVIRONMENTAL PROTECTION

3.1 INTRODUCTION

Responsibility for the protection of human life and the environment is to be ensured by means of preventive actions and the application of environmentally friendly measures.

The Business Partner must comply with all applicable laws and local regulations concerning environmental impacts and protection, e.g., but not limited to energy, Greenhouse Gas (GHG) emissions, waste and water.

The Business Partner should aim to continuously reduce any kind of negative environmental impact of products and services and to source in a responsible and sustainable manner. Causing harmful soil change, water pollution, air pollution, harmful noise emission or excessive water consumption that impacts natural bases for food, denies local access to clean drinking water or sanitary facilities or harms the health of a person must be avoided. Environmental awareness and training within the company have to be actively promoted.

The Business Partner shall be willing to enter into dialogue with Beiersdorf regarding the joint advancement of sustainability performance and share non-confidential environmental impact data if available.

3.2 EMISSIONS

Business Partners should monitor, track and document their emissions to air, water and soil from their facilities, as well as the wastewater generated by their operations in order to identify and improve aspects that they can control and influence. Targets to minimize greenhouse gas emissions should be set.

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