CODE OF CONDUCT

FOREWORD BY THE MANAGEMENT

Since its foundation in 2003, MAW Maschinen und Anlagenbau Westhofen GmbH, Schwerte, has been a German manufacturer and service provider with a passion for the highest product quality, innovative strength, maximum performance, availability and customer-oriented service in all business areas.

Since the company was founded, the name MAW has been synonymous in national and international business dealings not only as a metalworking company, primarily in the plant and mechanical engineering of high-quality process equipment, but also for the values of a medium-sized company with a highly motivated workforce.

The company's success is also founded on compliance with the law, the maintenance of internal regulations and an all-encompassing respect for fundamental ethical values. Social responsibility towards our employees, business partners and the community is just as much a basic requirement as the protection of the environment and the conservation of natural resources in our daily thoughts and actions.

We are convinced that with this basic attitude, we are making and have made a contribution to the sustainable development of our company and thus continue to gain and maintain the trust of our employees, business partners and the community.

This Code of Conduct is intended to summarize the most important principles of our entrepreneurial activities and to serve as a model for our employees in their daily work with colleagues, customers, suppliers and competitors. It is the duty of every employee to read and understand this Code of Conduct and to implement it in their daily work.

Together we are responsible for acting with integrity and in accordance with the rules

58239 Schwerte, June 2023

MAW Maschinen und Anlagenbau Westhofen GmbH
Managing Director
Robin Pfennig

I. Declaration of principles

1. self-image of MAW
People are at the forefront of our business activities. We ensure that our actions are guided by strict legal conformity and ethical principles. We face up to our social and environmental responsibilities.

1.1 Sustainable development
This Code of Conduct is the basis for the sustainable development of our company in the present and in the future. The aim is to contribute to the preservation of an intact environment for future generations.

1.2 Human rights and non-discrimination
One of MAW's most important basic principles is respect for human rights, the protection of personal rights and respect for the privacy and individual sphere of others. Cooperation with people from different countries and cultures should be without distinction of ethnic, national and social origin. Age, skin color, language, gender, disability, religious, political, other beliefs and sexual identity should not be discriminated against. We do not tolerate discrimination or harassment based on these characteristics.

1.3 Compliance with regulations
Compliance with the applicable legal provisions within the scope of our national and international business activities is our top priority. This statement also applies to voluntary commitments, internal company guidelines and other regulations.

1.4 Value orientation
The foundations of our business and social conduct are based on trust, respect and tolerance. We expect this from all employees when dealing with our customers, suppliers and the quality of our products. The values set out in this mission statement should serve as a reminder of this and determine the direction of each individual's actions.

1.5 Environmental and social responsibility
We try to incorporate people's need for a clean and sustainable environment into our business and production processes. We are actively working to reduce environmental and climate pollution, conserve resources and recycle raw materials. We fulfill the resulting obligation and social responsibility towards our employees, business partners and the community in various areas.

2 Binding nature of the Code of Conduct and implementation
The values and principles set out in this Code of Conduct are in principle a matter of course in our day-to-day dealings with one another. It is therefore binding for all members of management and all employees.

2.1 Orientation guide
This Code of Conduct is intended to provide guidance for acting in accordance with the law and regulations, as well as for ethically and morally impeccable conduct in business dealings and towards colleagues. It is intended to support and promote day-to-day work.

2.2 Commitment
All managers at MAW are required to communicate the content and validity of this Code of Conduct to their assigned employees in a comprehensible manner and to encourage them to comply with the rules.

Any violation of this Code of Conduct will not be tolerated by the management of MAW, as disregarding the principles can lead to high economic damage and extensive loss of reputation. Each employee is responsible for compliance with all relevant laws, law-like regulations and other rules within his or her area of responsibility/activity. In the event of violations, employees must expect disciplinary measures and the assertion of claims for damages in addition to any official proceedings against them.

This Code of Conduct represents the minimum requirement for all MAW employees. If additional regulations are standardized and these are interpreted more strictly, you will not be restricted by the regulations listed in this Code. This Code serves as an internal code of conduct and does not establish any claims against third parties.

2.3 Supplementation by guidelines
If this Code is supplemented by internal guidelines on selected topics, these must be consistent with this Code.

II. CONDUCT IN BUSINESS DEALINGS

1. requirement of fair competition, prohibition of cartels
A fundamental principle of the market economy is free, unrestricted and fair competition.

In accordance with our business policy, we base our competition exclusively on customer orientation, performance and the quality of our products. Employees whose behavior contravenes national and international rules of fair competition and antitrust regulations will not be tolerated.

1.1 Prohibited business activities
Actions that are anti-competitive and relevant under antitrust law must be refrained from.

The following are examples of actions that are prohibited:

Agreements and discussions with competitors about competitively sensitive information (prices, price components, techn. developments) in the context of trade fairs, association events, standardization events, etc. or their disclosure to competitors. Sharing projects, markets, territories or customers with competitors. The submission of sham bids in tenders or the agreement with competitors to waive competition. Unlawful exploitation of a dominant market position. Unfair preference or obstruction of suppliers in the competition for contracts.

1.2 Involvement of legal counsel
Competition-related issues are often difficult to assess; in such cases, the relevant specialist departments should be involved or external legal counsel should be consulted in consultation with the management.

2. prohibition of corruption
Bidding for contracts is based on our innovation, product quality, services and prices. The relationship with public officials and elected representatives is characterized by respect and compliance with the law. We outlaw and prohibit all forms of corruption.

2.1 Corruptibility and bribery
Within the scope of their activities, MAW employees are prohibited from demanding, accepting, obtaining or being promised benefits for themselves or third parties from business partners, their employees, intermediaries or other persons to which there is no legally enforceable entitlement ("bribery and corruption in business dealings").

MAW does not tolerate the unlawful offering or granting of advantages to business partners, their employees, officials or mandate holders, intermediaries or other persons in connection with the procurement, awarding, approval, execution or payment of contracts within or outside official procedures or other relationships with authorities and business partners.

Even the appearance of corrupt behavior must be avoided. Any inducements in dealings with MAW's business partners must be critically reviewed. This also applies in particular to

disproportionate hospitality expenses, unusual, disproportionate or such invitations that are not directly related to a business visit, gifts of money, value or in kind. Particular attention must be paid when dealing with elected officials, civil servants, employees of authorities or other public institutions with regard to the granting of benefits.

2.2 Consultants and intermediaries
Agreements with consultants, representatives or other intermediaries must be made in writing. Commissions and other remuneration must be in reasonable proportion to the verifiable consideration provided and must be based on customary rates of remuneration.

Agreements that are suitable for circumventing internal regulations or granting or obtaining inadmissible advantages are prohibited.

3. donations
Donations made by MAW in the context of social responsibility must be made strictly in accordance with applicable law.

Donations are voluntary contributions for which MAW does not expect or receive anything in return. Insofar as they are permissible, they should have a local connection. Donations must not create the appearance of influence or be capable of damaging the reputation of MAW or its employees. They must not be misused for the purposes of corruption.

Donations to political parties, party-like organizations, elected officials and office holders as well as candidates for mandates or offices are not permitted. The procedure and relevant amount limits are regulated by an internal committee of MAW in coordination with the management.

4. compliance with tax law, export control regulations and money laundering prohibitions
Strict compliance with national and, where applicable, international tax regulations, trade regulations and money laundering prohibitions is essential for MAW as an internationally active company.

4.1 Taxes
MAW is committed to complying with all national and, where applicable, international tax and customs laws and obligations in the countries in which we operate. MAW rejects any form of inadmissible circumvention of the relevant requirements as well as abuse of the tax system.

4.2 Export control and customs
National and international regulations that restrict or prohibit the import, export or domestic trade of goods, technologies or services are respected by MAW. Approval procedures resulting from foreign trade law and customs regulations are observed by MAW.

4.3 Money laundering
MAW takes the international fight against money laundering and the resulting legal obligations very seriously and supports them.

5 Selection of business partners
The selection of business partners (customers, suppliers, service providers, distributors, project partners, consultants, etc.) is target-oriented and based on objective criteria. Compliance with the values defined by MAW is taken as a basis and observed in business relationships.

5.1 Selection process
MAW business partners are evaluated and selected impartially on the basis of offers based on defined objective criteria. Preferential treatment or discrimination based on unobjective criteria is prohibited.

5.2 Business Partner Code of Conduct
MAW expects its business partners to respect and act in accordance with principles such as respect for people and the environment, strict compliance with the law, the prohibition of corruption and integrity in competition. In individual cases, this can be done by providing evidence of a comprehensive code of conduct that has been reviewed in advance.

6 Documentation and reporting
Business transactions must be correctly documented and reported.

All business transactions to be documented in accordance with internal or external regulations must be recorded at MAW accurately, comprehensively, promptly and in the designated place. The documentation must be in the appropriate form and must be stored in accordance with legal and internal requirements and deadlines. All employees are obliged to provide truthful, complete verbal and written reports within the specified framework. Compliance with data protection (GDPR) in the context of reporting and documentation must be ensured.

III. EMPLOYEES AND MANAGEMENT CULTURE

1. management culture
MAW's corporate success is primarily based on reliable and committed employees, both active employees and former employees who have been with the company for decades.

MAW bears great responsibility for its employees. Fair treatment of one another, shared values, the promotion of performance and personal responsibility are all part of MAW's management culture.

Innovations are the result of people who carry out their tasks with commitment and passion. We give our employees the opportunity to contribute creativity as a team or individually and to take on personal responsibility so that potential can be fully exploited.

We are open-minded and fair in our dealings with one another. Problems, conflicts and undesirable developments can be addressed openly. We support this through flat hierarchies.

Our managers should set an example through their exemplary personal behavior and actively support the implementation of these guidelines. Interactions with employees should be respectful and based on responsibility. The interests of employees should be taken into account.

2. fair working conditions and occupational safety
MAW is committed to fair working conditions and high occupational safety standards.

2.1 Working environment
We respect appropriate working conditions for our employees that comply with the relevant legal requirements. MAW adheres to labor law requirements and offers fair remuneration. We respect the legal representation of our employees' interests.

The outlawing of any form of forced, slave or child labor is a matter of course for MAW.

2.2 Health and safety
We respect the health of our employees as the most valuable human asset by ensuring safety in the workplace. We comply with the relevant regulations on health protection, occupational safety, fire protection and environmental protection. We always strive to improve and implement the applicable regulations for processes and systems through authorized persons or groups in our daily work. The aim is to reduce the risks to the health, safety and environment for our employees.

3. avoidance of conflicts of interest
It is important to MAW that employees do not enter into conflicts of interest or loyalty with the company.

Potential personal conflicts of an employee with the interests of MAW must be disclosed immediately to the HR department and/or management.

3.1 Private orders from employees to business partners of Arias
No employee may place private orders with suppliers or service providers of MAW if he or she is seeking an unlawful advantage in relation to the business relationship.

3.2 Social commitment of employees
MAW values the social, civic, civic or charitable commitment of its employees. However, this must always be done in such a way that conflicts with the interests of MAW are excluded.

4 Confidentiality, data protection and information security
The handling of business information is a principle of confidentiality at MAW. Data protection and security of sensitive and personal data is carried out in accordance with legal regulations.

4.1 Confidentiality regarding business secrets
The duty of confidentiality applies to every employee with regard to internal matters of MAW vis-à-vis third parties, insofar as the information/data has not previously been lawfully published.

This applies in particular to trade and business secrets of any kind, as well as personal data. The use of information obtained for business purposes in the private sphere is prohibited. The duty of confidentiality continues to apply permanently after termination of the employment relationship.

4.2 Protection of personal data
MAW attaches great importance to the observance of personal rights and data protection, in particular the correct handling of personal data of employees, customers, suppliers and other and business partners. When collecting, processing and using data and personal data, MAW employees are obliged to comply with the relevant data protection regulations and internal guidelines.

4.3 Secure exchange of information
MAW's national and international business activities also require the electronic exchange of information and data. MAW is aware of the associated risks and endeavors to secure and protect business data from unauthorized access by third parties. The measures are regulated in detail in the internal data protection manual and in MAW's IT guidelines.

5 Careful handling of company property
MAW's company property must be protected. Under this guideline, MAW requires all employees to handle all tangible and intangible assets carefully and appropriately. This includes real estate, office equipment, operating resources, products, financial resources, information systems, software, but also property rights (e.g. patents, trademarks, etc.).

Damage must be reported immediately. Theft and unauthorized private use of company property is prohibited and will be punished accordingly. This means that violations of the law can be prosecuted under criminal and civil law and have consequences under labor law.