Code of Conduct

focused on customer
- driven by innovations
TABLE OF CONTENT

Intent of the Code of Conduct 3

1. Introduction 4
1.1 Aim of the Code of Conduct of the BOS Group 4
1.2 Fundamentals 4

2. Human Rights, Work Conditions and Assets 5

2.1 Personal Responsibility 5
2.2 Protection against Discrimination 5
2.3 Fair Work Conditions 5
- Prohibition of Child Labor
- Prohibition of Forced Labor
- Freedom of Association and Right to Collective Negotiation
- Remuneration, Working Hours and Qualification
2.4 Health, safety and environmental protection at the workplace 6
2.5 Avoidance of Conflicts of Interest 7
2.6 Protection of Corporate Assets 7
2.7 Information Security and Data Protection 7

3. Interactions with Business Partners 8

3.1 Suppliers 8
3.2 Fair and Sustainable Competition 8
3.3 Conflict Minerals 9
3.4 Competition and Antitrust Law 9
3.5 Gifts and Benefits 9
3.6 Donations 9

4. Compliance with and Implementation of the Code of Conduct 10

4.1 Responsibility 10
4.2 Violations 10
4.3 Contact Point 11
4.4 Investigation and Reporting 11

5. Final Clause 12

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INTENT OF THE CODE OF CONDUCT

Ostfildern, February 2021

Dear Employees,

Based on the international activities of the BOS Group we have revised the Code
of Conduct and determined the basic rules and principles according to which we
would like to work together at BOS – today and in the future. The BOS code of
conduct is largely based on the ten principles of the United Nations Global
Compact (www.unglobalcompact.org), the UN guiding principles for business and
human rights, and the OECD guidelines for multinational enterprises.
It summarizes the high standards at BOS Group regarding our employees, our
environment and our external partners.

The Code of Conduct serves all of us whether it be for leadership or individual

employees as guideline in our daily work. It sets the bar for each of us and at the
same time shall help practice responsible behavior both externally towards our
business partners and the public as well as internally in the conduct with each
other. We also expect this responsible behavior from our business partners and
suppliers. Together we are responsible for the reputation of BOS.

Last but not least, the strict adherence to the “Code of Conduct” is a mandatory
component of the IATF 16949 certification, the successor of the ISO/TS 16949
certification and therefore required for every supplier within the automotive
industry.

Thus, we would like to ask you, esteemed colleagues to carefully observe the
Code of Conduct and to use it as a guideline for our daily behavior.

Stefan Grein
Chairman of the Board

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1. INTRODUCTION

1.1 Aim of the Code of Conduct of the BOS Group

It is our duty to conduct all business transaction ethically and legally sound with the
objective to create an environment of mutual trust both with our business partners
as well as with our colleagues internally. We see this as the foundation for long-
term prosperity and success.

The BOS Group is committed to respecting internationally recognized human

rights. We also expect our business partners to adhere to human rights, in
particular the UN Global Compact, and actively work towards compliance with and
implementation of these principles along the value chain.

1.2 Fundamentals

Our good reputation and the trust of our customers, employees and the public
depend largely on the behavior of each individual in this company. Each employee
is therefore equally responsible to adhere to the values and objectives of the
company and to act accordingly within the realm of their responsibilities.
Therefore, we need a proper set of rules and guidelines. This present Code of
Conduct summarizes the most important rules and guidelines that all BOS
employees worldwide should follow. The principles explained in this document
apply in interactions with all colleagues, customers, suppliers, business partners
and public bodies worldwide, at all locations and for all business units of the BOS
Group.

We expect that all employees, without exception, not only follow internal rules but
also obey the laws, avoid conflicts of interest protect BOS assets and uphold the
traditions and values of those countries that we have business dealings with.

We expect from our management personnel in their position as role models that
they not only communicate these rules but also lead by example and call on their
employees to follow. They are the first point of contact for all questions and
concerns related to the code.

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2. HUMAN RIGHTS, WORK CONDITIONS AND ASSETS

We are convinced that the sustainable success of our family business depends
greatly on a value-based corporate culture and every single employee contributes
an important part to the success of the company. We are taking our responsibility
very serious and pledge to respect the human rights of our employees. We aim to
exceed the minimum standards with our working conditions.

2.1 Personal Responsibility

We expect all employees of BOS Group to comply with legal requirements and
company guidelines, all managers are requested to assume a role model function.
The personal dignity of each individual must be respected and protected. All
executives are requested to prevent any violation of the code in their respective
units. Each employee must be explicitly advised of this code.

2.2 Protections against Discrimination

We do not tolerate any disadvantage, harassment, sexual harassment or other

forms of discrimination against our employees based on race or ethnic affiliation,
gender, religion or view of the world, disability, age or sexual identity. As a
company operating worldwide we promote diversity within the company and
cooperation with employees and partners of different cultures, mindset or
nationalities and are convinced that successful collaboration is only possible with
mutual respect and appreciation of each individual.

2.3 Fair Work Conditions

We do not tolerate any form of forced or compulsory labor. In accordance with the
ILO core labor standards, we strictly reject the use of forced or unlawful
compulsory labor.

We do not tolerate any form of child labor. In accordance with the ILO core labor
standards, we comply with the minimum age for employment and strictly reject
child labor.

We recognize the right of all employees to form employee representations and to

engage in collective negotiations to regulate working conditions.

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2. HUMAN RIGHTS, WORK CONDITIONS AND ASSETS

Our culture is characterized by trusting and constructive collaboration with the

respective employee representations. The common goal is to maintain a
sustainable cooperation for the benefit of the company and the employees.

We compensate our employees fairly, both internally and externally. Where

available, the legally guaranteed minimum wages and standards are followed.

We comply with the applicable national working time regulations worldwide. In

addition, our working time regulations describe the applicable principles regarding
rest periods, free time, vacation and life balance as well as possible sabbaticals.

Professional development and qualification are based solely on the individual’s

personal performance, individual ability and personal suitability. We remunerate
our employees for their individual or collective performance in accordance with
local principles.

2.4 Health, safety and environmental protection at the workplace

We consistently comply with applicable occupational health and safety laws

worldwide.

We also set our own standards for improving occupational safety and reducing the
risk of accidents with our management system for environment, safety and health
at work (USGA), which includes the health and safety management system
according to ISO 45001 and the environmental management system according to
ISO 14001.

Thus, we are dedicated to complying with the highest occupational safety

requirements, regardless of whether lower requirements would be permissible in
each country.

We are all jointly responsible for protecting people and the environment. It is the
task of our employees to maintain their workplace in a tidy and safe condition, to
protect the environment and to use the available resources economically and
considerately. Any deviations must be reported to the manager.

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2. HUMAN RIGHTS, WORK CONDITIONS AND ASSETS

2.5 Avoidance of Conflicts of Interest

We ensure that the interest of the employees are in accordance with the interest of
the company. Therefore, each employee should avoid any situation that could lead
to a conflict between personal and corporate interests. These situations could
arise for example in case of activities
or joint ventures with other companies or business with friends or family members.
Any such business relations should be avoided and the respective supervisor
should be informed immediately. Any secondary work with pay needs to be
approved in writing by the respective supervisor and/or human resource
department.

2.6 Protection of Corporate Assets

We expect that our employees treat all tangible and intangible assets with respect.
These assets include among others, buildings, properties, vehicles, office
equipment as well as know-how, patents, innovations, technologies and other
valuable information for the BOS group that needs to be protected. Our innovations
and competences should be protected not only from theft, but also from imitation.

All facilities and equipment can only be used for private purposes with prior special
permission.

2.7 Information Security and Data Protection

We require our employees to handle sensitive information, innovations and

know-how confidentially and use them for business purposes only. They are the
foundation for our sustained success and may not be passed on to or made
available for third parties under any circumstances. The same applies to all
personal data on employees of BOS group.

We maintain high data protection standards to protect the privacy rights of our
employees and customers regarding the use of their personal data. Principally, we
are guided by German and European data protection standards in order to ensure
the best possible respect for personal rights worldwide. Our data protection
ensures that the use of personal data complies with the law and that the rights of
each individual are protected.

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3. INTERACTIONS WITH BUSINESS PARTNERS

We strive to be reliable partners, both in collaboration with our customers,

suppliers and business partners as well as within our company. Besides our
competence, innovative power and quality of our product this also requires
honest and transparent communication and that we keep our commitments and
contractual relationships.

3.1 Suppliers

Our suppliers are expected to respect human rights in the course of their business
activities. For BOS, the commitment of suppliers to fulfill their social responsibility
and in particular to comply with the ILO core labor standards is an indispensable
condition for lasting business relationships.

We have established a multi-stage risk management process to promote

compliance with social standards. Our general terms and conditions require
suppliers to respect human rights and to demand the same from their suppliers.

We review all offers of our suppliers in a fair and unbiased manner. Awarding the
business and execution of the order are strictly based on relevant factors. All
agreements are negotiated in full and unambiguously, any amendments or
modifications later on are duly documented. All employees have to comply with the
internal system of dual control, the so-called “four eyes principle or two-man rule”.

3.2 Fair and Sustainable Competition

We follow the rules of fair and sustainable competition and support the idea of free
markets and fair trade. Any unfair practices are prohibited.

Our economic and financial activities are monitored internally on an ongoing basis
and are subject to the control of auditing firms and the respective banking and
financial supervisory authorities.

We adhere to the various rules of foreign trade, tax and customs law in our global
activities, comply with mandatory economic sanctions at all times and are aware of
our social responsibility in fulfilling our tax and customs obligations.

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3. INTERACTIONS WITH BUSINESS PARTNERS

3.3 Conflict Minerals

Transparent documentation of the supply chain for “conflict minerals” requires

special diligence that we exercise in accordance with the US American law “Dodd-
Frank Act, Section 1502”.

3.4 Competition and Antitrust Law

We expect every employee to adhere without exception to the idea of fair

competition and trade rules of all countries that BOS operates in. This also
includes business in countries against which economic sanctions have been
imposed. It is therefore inadmissible to engage in agreements with the competition
that could sway the competition.
The same applies to exchanging information regarding price, conditions,
capacities, market shares, margins, cost as well as offer details.

3.5 Gifts and Benefits

We will not tolerate any type of corruption, bribery, extortion or embezzlement. All
our activities are carried out with responsibility and honesty. Any employee that
should be influenced by unethical behavior from customers or suppliers or vice
versa will be held responsible and disciplined. There may be no benefits connected
in any way to requesting and receiving of services and materials.

Our employees are not allowed to accept reward or gifts related to their
professional activities. If employees are offered rewards or gifts in relation to their
professional activities, they have to inform the employer immediately. Monetary
gifts can never be accepted.

3.6 Donations

Various organizations and institutions are approaching us for donations. Any

donation is subject to approval by upper management. The recipient and purpose
of such donation must be known and conceivable. The principle of selfless action
applies.

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4. COMPLIANCE WITH AND IMPLEMENTATION OF
THE CODE OF CONDUCT

Our code of conduct is communicated to all employees. We expect all BOS

employees to comply with legal regulations and company guidelines and to align
their professional actions accordingly.

4.1 Responsibility

Our managers are obliged to inform their employees about the content and
significance of this code of conduct and to advise and support them in complying
with it in their daily activities.

Every employee of the BOS Group is required to comply with our code of conduct
and to make its principles the binding standard in the daily performance of duties.
For this purpose, it is necessary to actively and continuously inform oneself about
the existing requirements and to participate in the offered trainings.

4.2 Violations

Any violation can lead to severe consequences for the whole company and
depending on the seriousness lead to labor law or criminal persecution.

However, we trust that all our employees make the right decisions and report any
violations to the respective superior to resolve them locally in constructive
discussion. Never-the-less there may be circumstances – especially, if it is related
to illegal business practices – to address the situation outside the immediate work
environment. The following points of contact are available to employees and third
parties:

 Your manager
 Upper management
 Your Human Resource or Finance and Controlling Department or where
applicable your employee representative
 The contact person mentioned in the BOS Code of Conduct

Employees that report in good faith on any real or perceived misconduct, may not
be discriminated against. BOS will treat the identity of the employee – according to
the so-called whistle blowing process – confidentially whenever possible and
legally permissible.

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4. COMPLIANCE WITH AND IMPLEMENTATION OF
THE CODE OF CONDUCT

4.3 Contact Point

If you cannot voice your concerns, hints or complaints locally or you do not receive
proper support, you can always contact the Director of Human Resources
International by phone: +49-711-9360-1346 and/or by email under
[email protected] or directly contact the Managing Director.

Point of Contact:
Director Human Resources International
BOS GmbH & Co. KG
Ernst-Heinkel-Str. 2
73760 Ostfildern
Germany

Phone: +49 (0) 711 9360-1346

Email: [email protected]
www.bos.de

4.4 Investigation and Reporting

Reported issues are investigated and the necessary steps are taken.
Violations of the principles described in this code of conduct by employees may
lead to consequences under labor law in accordance with local legislation.

Any investigation regarding violations of the code of conduct will be conducted

with the utmost confidentiality, protection of the reporting party and consideration
of data privacy laws.

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 02/2021
5. FINAL CLAUSE

The Code of Conduct of the BOS Group is effective from the day of its signing. No
individual claims or claims of third parties may be derived from it. Only the German
version of this code of conduct is binging.

BOS Automotive Products, Inc. . Sales & Engineering Office

2956 Waterview Dr. . Rochester Hills, Michigan 48309 . U.S.A.
Tel. +1 248 267 4 715 . Fax +1 248 267 4 762 . [email protected] . www.bos.de

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