Compliance-Management-System

The appropriateness and effectiveness of the CMS is determined to a large extent by the compliance culture at ElringKlinger. The Management Board's clear commitment to compliance ("tone from the top") is of key importance when it comes to enshrining compliance within the ElringKlinger Group as a whole. Business at ElringKlinger is based on and guided by statutory requirements, internal standards, and regulations arising from the German Corporate Governance Code, as stated in the Declaration of Conformity issued by ElringKlinger.

Misconduct and compliance-related violations are sanctioned on a case-by-case basis by implementing the appropriate organizational, disciplinary, and legal (labor and, if applicable, criminal) measures. Civil law claims for damages are examined and asserted if necessary.

The CMS implemented within the ElringKlinger Group is geared towards compliance with statutory requirements, defined corporate codes and codes of conduct, and internal Group guidelines. The CMS is designed to prevent or minimize potential claims for damages, damage to the company's reputation, and legal sanctions against the ElringKlinger Group as well as personal liability on the part of employees and governing bodies of the ElringKlinger Group. In addition to this fundamental objective, the CMS is aimed at delivering legal certainty within the company and providing orientation for all ElringKlinger employees with regard to conduct that complies with defined rules.

The process of identifying and assessing compliance risks forms the basis for the development of an appropriate compliance program. Risks of legal and regulatory infringements within the ElringKlinger Group are analyzed, assessed, and managed as part of the Group-wide risk management process.

ElringKlinger AG's compliance program encompasses all guidelines initiated and issued by the compliance organization as well as measures implemented that are aimed at preventing breaches of regulations on the one hand and at identifying risks of compliance breaches in good time and clarifying and sanctioning them on the other. The compliance program of ElringKlinger AG essentially consists of the following elements:

• Code of conduct
• Guidelines and job/organizational instructions
• Process-integrated checks
• Organizational measures
• Training
• Process-independent checks/audits
• Confidential whistleblowing system