QSC AG

Governance Information • Jan 1, 2023

Code of Conduct for Business Partners of q.beyond¹

q.beyond is committed to a form of governance that is ecologically and socially responsible. For us, upholding honesty and integrity in all our business activities is a non-negotiable obligation; correct business practice is more important to us than short-term business success.

The principles of conduct formulated in q.beyond's Code of Conduct are based on our corporate values, codes of conduct, rules and guidelines, as well as on international frameworks, such as those promulgated by the United Nations or the OECD.

We also expect all our business partners, including all suppliers, service providers and advisors that are directly or indirectly integrated into the value chain involved in the performance of our services, to comply with the principles of business ethics and of social and ecological responsibility that are summarised in this Code of Conduct. In our opinion, these principles constitute the minimum standards governing our cooperation.

1. Compliance with laws, rules and legal regulations

Integrity of business dealings

The business partner shall comply will all relevant laws and legal regulations in those countries in which it operates and shall take suitable measures to ensure compliance with these laws and legal regulations. Should local legal regulations be less restrictive than the principles set out in this Code of Conduct, then we expect our business partners, as a minimum, to comply with the requirements of this Code of Conduct.

Antitrust and competition law

The business partner shall unreservedly comply with the norms of applicable antitrust and competition law and with other laws and regulations applicable to it, such as those relating to monopolies, unfair competition, restrictions on trade and competition and relationships to competitors and customers.

Anticorruption requirements

The business partner shall undertake to refrain from any form of corrupt conduct. No gratuities offering personal benefits, such as presents, bribes, payoffs or other cash payments or valuables may be paid, approved or offered to any persons, including civil servants, employees or representatives of state, public or international organisations or other third parties in the public or private sectors, or to q.beyond employees.

Money laundering and financing of terrorism

The business partner shall comply with relevant legal obligations to prevent money laundering and the financing of terrorism.

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¹ q.beyond AG including affiliated companies

2. Business information, data protection and intellectual property

The business partner shall be responsible for ensuring that all confidential business information or business secrets relating to q.beyond of which it gains awareness in connection with its business activities are treated with confidentiality and that it does not use such information in any unauthorised manner or disclose such information to third parties. Where necessary, we conclude bilateral confidentiality agreements which specify these obligations in greater detail.

The business partner shall comply with applicable data protection legislation and apply the relevant rules to ensure suitable security of information. If the business partner processes personal data of employees or customers of q.beyond, it shall conclude a data processing agreement with q.beyond if such agreement is required by applicable law.

The business partner shall respect intellectual property rights; any transfer of technology and expertise shall be executed in such a way that intellectual property rights and customer information are protected.

3. Human rights and fair working conditions

The business partner shall undertake to respect human rights and ensure healthy and fair working conditions in those areas it is able to influence.

The business partner shall adhere to the guiding principles set out in internationally recognised human rights conventions and standards and formulated, for example, by the United Nations. It shall take every reasonable effort to ensure that neither it nor any parties it commissions to perform services commit or are involved in any human rights abuses.

The business partner shall adhere to all applicable aspects of labour law, as well as to the fundamental conventions of the International Labour Organization (ILO). In accordance with local legislation, these include, but are not limited to:

• The prohibition of forced labour, including all forms of modern slavery, human trafficking and unethical recruitment practices.
• The prohibition of child labour.
• An integrative and cooperative environment without reprisals and free of violence and harassment.
• The rejection of all forms of discrimination, including, but not limited to, nationality, ethnicity, gender, disability, age, sexual identity or orientation, religion or worldview, social status or racially motivated discrimination. The personal dignity, private sphere and personal rights of every individual are respected.

• The remuneration paid to workers complies will all applicable laws governing remuneration. Adherence to statutory minimum standards relating to remuneration for work and social security benefits is ensured.

• Suitable working hours and adequate periods of rest in accordance with applicable laws and industry standards.

• Compliance with the freedom of association and with the right to membership of trade unions, to appeal to worker representation or to membership of works councils in accordance with applicable local laws.
• Safe and healthy working conditions. By establishing and applying suitable work safety systems, the necessary precautions are taken to avoid any accidents and damage to health that may arise in connection with the respective activity. Furthermore, employees are regularly informed about and trained on applicable health and safety standards and relevant measures.

4. Ecological responsibility

The business partner shall commit to assuming responsibility for protecting the environment and people and to taking all appropriate measures to conduct its business processes in a secure and responsible manner.

The business partner shall ensure compliance with national, sub-national, regional and local regulations applicable to it, as well as with any voluntary environmental agreements with the supervisory authorities that are applicable to it.

The establishment of an environmental management system in accordance with international standards such as EMAS or ISO 14001 is recommended.

5. Conflicts of interest

q.beyond and the business partner shall avoid all activities and situations which could give rise to a conflict between the private interests of any employee of q.beyond or the business partner and the business interests of q.beyond or the business partner. The business partner shall inform q.beyond immediately of any conflict of interest of which it gains awareness.

6. Due diligence in respect of supply chains and conflict minerals

The business partner shall perform due diligence processes, including suitable complaints mechanisms and reporting, to identify, prevent and minimise any risks of human rights abuses and negative environmental impacts in its supply chains.

The business partner shall comply with all laws applicable to it in respect of the due diligence conducted on its supply chain.

The business partner shall ensure that no products are delivered to q.beyond which contain metals whose base minerals or derivatives originate from a conflict region in which they contribute either directly or indirectly to financing or supporting armed groups.

7. Product integrity

The business partner shall develop, manufacture and supply products that meet the latest technological standards in respect of product integrity. The products shall satisfy all necessary requirements in respect of:

• Product safety to avoid any risks to people's health and environmental safety
• Product conformity in respect of compliance with the applicable legal and technical standards
• Product cybersecurity, i.e. protection against any unauthorised manipulation.

8. Business continuity

The business partner shall maintain suitable risk management, i.e. it shall continually identify and evaluate its business risks in order to minimise the impact of any disruptions or interruptions on the business relationship it maintains with q.beyond. The business partner shall implement appropriate risk minimisation measures and have regularly tested and reliable backup and continuity plans in place.

9. Complaints mechanism

q.beyond has implemented a whistleblowing system (https://qbeyond.integrityline.org). q.beyond thus provides all third parties and its own employees with the opportunity to report any suspected unlawful actions.

All business partners and all their employees are encouraged to report any breach or specific suspected breach of this Code of Conduct or of other legal requirements. Confidentiality is guaranteed and tip-offs may also be submitted anonymously.

In accordance with their own duties of care, business partners should also provide their own independent complaints mechanisms.

10. Compliance with Code of Conduct for Business Partners

q.beyond views the requirements stipulated in this Code of Conduct for Business Partners as being of material importance for the business relationship between q.beyond and the business partner. It nevertheless reserves the right to make amendments to this Code at any given time.

As a business partner of q.beyond, you consent to satisfying these principles of conduct. Furthermore, you undertake to require your employees, contractors and subcontractors to comply with these principles of conduct to the extent that they are involved in performing the services contractually agreed with us.

You acknowledge that compliance with this Code of Codex is factored into our regular evaluation of business partners and that q.beyond views such compliance as a prerequisite for initiating or maintaining longer-term business relationships.

Any misconduct or breaches of the required conduct or of legal requirements and guidelines may have severe consequences not only for the individual involved but for our entire company. We therefore do not tolerate any misconduct. Any breach of this Code of Conduct may therefore provide q.beyond with grounds and reason to terminate the respective business relationships, including all associated contractual arrangements.

Place/date First name and surname (in block capitals) Signature

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q.beyond AG Richard-Byrd-Straße 4 · 50829 Cologne info@qbeyond.de · www.qbeyond.de