Status: 16.09.2025 (Version 2.0)

Code of Conduct for the employees of the Raan Group:

• I. Introduction
• II. Guide of one’s own behaviour control
• III. Contact
  • 1.  Contact points in the immediate environment (superior managers, the management, human resources department, legal department)
  • 2.  Compliance Officer
  • 3.  Confidential lawyer
• IV. Code of Conduct
  • 1.  Social responsibility
    • 1.1  Compliance with applicable law
    • 1.2  Whistleblower
    • 1.3  Human rights
    • 1.4  Environmental protection, health, occupational safety
    • 1.5  Legal certainty of our services
    • 1.6  Dealing with political institutions and authorities
  • 2.  Workplace
    • 2.1  Trust and respect
    • 2.2  Open contact
    • 2.3  Data protection
    • 2.4  Company assets
    • 2.5  Bias
  • 3.  Integrity
    • 3.1  Financial integrity and combating fraud
    • 3.2  Protection against corruption and bribery
    • 3.3  Gifts and invitations
    • 3.4  Antitrust law
  • 4.  IT and media
    • 4.1  Protection of intellectual property
    • 4.2  IT security and IT use
    • 4.3  Confidentiality and public relations

I. Introduction

This Code of Conduct is based on the principles and core values of our group of companies. It is intended to provide us with common guidelines for our decisions and our actions towards employees, business partners, government agencies, society and our environment. In addition to economic success, partnership, creativity and entrepreneurial spirit, the most important core values that characterise the Raan Group are social responsibility and ethical behaviour.

This Code of Conduct applies to all companies listed in the current organisational chart of the Raan Group, to all employees of the respective companies, and to the managers of the Raan Group in Germany and abroad. This guideline contains important binding rules on the topics of “Social Responsibility”, “Conduct in the Workplace”, “Financial Transactions and Reporting” and “Media and Technology”.

Violations of laws or legal regulations as well as of the rules of this Code of Conduct are not compatible with our values. They damage the reputation of our group of companies and can also have serious legal consequences.

The Raan Group values flat hierarchies. Delegation and entrepreneurial freedom make it possible to react flexibly and efficiently to market conditions and customer needs. Therefore, personal integrity and a sense of responsibility are indispensable qualities of our employees.

We all contribute to ensuring that the Raan Group of Companies is not only economically successful, but also acts at all times in accordance with its social responsibility and in compliance with the law.

II. Guide to controlling one’s own behaviour

We often have to decide during our professional activities whether a certain behaviour is appropriate or not.

These questions can help to make the right decision and should represent possible courses of action for those cases where I am not sure:

• Is my decision in line with applicable law and with the company’s internal rules?
• Contact persons for uncertainties are:
  • the legal department for all questions relating to legal issues
  • the Compliance Officer Dr Fritz Flanderka
  • Controlling, Finance, Accounting
  • my line manager
• Do I make the decision independently, free of my own interests and solely in the best interests of the company?
• Can my decision stand up to scrutiny by a third party?
• Does my decision uphold the company’s reputation for being law-abiding and socially responsible?

If you can answer all these questions in the affirmative, you can assume that the decision is justifiable. If this is not the case, be sure to seek expert advice before acting!

Suitable contact persons can be found in the following section.

III. Contact persons

1. Contact points in the company

If you have any questions about the Code of Conduct, you can always contact persons in your immediate environment to avoid violations. These are e.g.

• the superior manager,
• the management,
• Human Resources, Legal, Finance or IT departments, depending on the subject area.

2. Compliance officer

A compliance officer has been appointed for the Raan Group, whom employees and third parties can contact in confidence if they observe violations of the Code of Conduct – but especially illegal business practices – in the company.

Due to his position, the Compliance Officer was expressly obliged to treat the identity of whistleblowers confidentially, in addition to complying with the general duty of confidentiality. Only if he has the consent of the whistleblower may he name him.

3. Lawyer of confidence

In addition to the contact points within the company and the Compliance Officer, Prof. Dr. Stefan Siepelt is available to employees as an external lawyer of confidence and external reporting office for violations within the meaning of the Whistleblower Protection Act. If you have concrete, substantiated information about possible violations of the contents of our Code of Conduct as well as legal or official regulations (e.g. bribery offences, antitrust violations or the violation of accounting regulations) or suspect such violations, you can contact our lawyer of confidence using the following contact data:

Prof. Dr. Stefan Siepelt Phone: +49 221 55400-130  |  Mobile: +49 172 2862929
Email: stefan.siepelt@llr.de or whistleblower@raan-group.com

He protects your identity. It is expressly agreed with him that disclosure of your identity is waived unless you have expressly consented to such disclosure. Within the scope of his contractual relationship with the Raan Group of Companies, the lawyer of confidence is fully subject to the statutory professional duty of confidentiality. The lawyer of confidence is free of charge for all employees.

IV. Code of Conduct

1. Social responsibility

1.1 Compliance with applicable law

Compliance with all applicable laws and legal regulations at local, national and international level is a matter of course for us, as this is the only way to ensure our entrepreneurial success.

In this respect, it is essential that our managers know the laws, regulations and internal rules applicable to their respective areas. If there are conflicting requirements due to different legal systems or customs in different countries, the stricter regulations are to be applied as a matter of principle. In case of doubt, please consult the contact persons listed under section III. Any violation of laws or binding regulations can have serious consequences such as criminal prosecution, damages or damage to reputation.

1.2 Whistleblower

We would like to be informed about illegal behaviour in our company in order to be able to clarify and stop such behaviour. Therefore, we encourage everyone – whether employees, former colleagues, our customers, our suppliers or third parties – to inform us of any violations of the law.

All whistleblowers are assured of confidentiality. Employees should first contact their superior manager. We understand that this may not be appropriate in all cases. For this reason, anyone can also contact the Compliance Officer, Dr Fritz Flanderka, directly internally or, alternatively, our external reporting office set up for this purpose via Prof. Dr Siepelt. The exact contact details can be found under point III. 3.

We ask for your understanding that the whistleblower portal should only be used to report violations of laws, guidelines or our Code of Conduct. General complaints as well as product and warranty enquiries will not be processed.

1.3 Human rights

Respect for the personal dignity, privacy and personal rights of our colleagues, clientele, our supplying companies and others with whom we are in contact is a matter of course for us.

We reject any form of forced labour and child labour. Laws and rules for the protection of human rights, for fair working conditions, statutory minimum wages and other labour law provisions are obligatory for us.

We do not tolerate exploitation or discrimination of persons on the basis of their age, gender, religion, health or origin.

1.4 Environmental protection, health, occupational safety

As a group of companies in the field of environmental and waste management, the use and procurement of natural resources is a priority for us in the provision of our services. We use energy, water, materials and land responsibly.

We ensure a healthy and hazard-free working environment for our employees.

1.5 Legal compliance of our services

For our customers, we want to work together as partners in the long term and in a spirit of trust. Compliance with the applicable laws in relation to our services – especially in the area of environmental and waste management – is of crucial importance to us. Our customers must be able to rely on us to provide services for them that are fully compliant with the relevant laws and regulations.

1.6 Dealing with political institutions and authorities

Especially in a strictly regulated environment, such as environmental and waste management, it is of great importance to always act honestly, transparently and in compliance with the law when dealing with governments and authorities. We adhere to these principles at all times, e.g. in contacts with authorities or in political advocacy. Responses to official enquiries must be coordinated with the superior manager and, if necessary, with the legal department.

In the event of antitrust or competition law enquiries, all employees are required to pass these on to the legal department.

2. Workplace

2.1 Trust and respect

In our group of companies, we live and support a working environment that is characterised by respect and tolerance. The value and dignity of each individual is recognised. Polite, honest and appreciative interaction between employees is a matter of course for us.

Discriminatory behaviour towards employees, customers or contractors is not tolerated in our company. Especially when it comes to personnel-related decisions such as hiring, promotions or disciplinary measures, we attach importance to non-discriminatory decision-making.

Any verbal or physical behaviour that violates the dignity of a person is inadmissible.

2.2 Open and trusting interaction

For us, an open working atmosphere is of particular importance. Employees should also be able to address critical issues. It is important to us to counteract possible grievances through open cooperation and flat hierarchies and, if possible, to prevent them from arising in the first place. In this way, unacceptable behaviour such as violations of the law or ethical principles can be recognised and stopped at an early stage and occur less frequently in the long term.

Employees who report such incidents in good faith must not be intimidated or pressured. “Good faith” means that the employee is convinced of the truth of his or her account – regardless of whether a subsequent investigation confirms this.

If employees do not wish to go through their respective superior manager, they can contact the Compliance Officer.

2.3 Data protection

Personal data of our employees and our clientele are subject to strict confidentiality in our company and are processed with the utmost care.

The collection, storage, processing or transfer of personal data shall be carried out in compliance with all applicable regulations and statutory provisions.

Any queries can be clarified via the legal department and, if necessary, with the data protection officer.

2.4 Company assets

Responsible handling of company property of any kind, such as work equipment (e.g. computers, telephones, paper, furniture), licences or business assets is essential for us.

The use of company assets shall be exclusively for the intended business purposes. Misuse for other purposes is not permitted.

2.5 Bias

If an employee has to make a decision that benefits the company but conflicts with his or her personal interests, whether professional, private or financial, this can lead to bias in the decision-making process.

In the event of bias, the person concerned is obliged to inform the superior manager or the management about it in order to be able to bring about a clarification at short notice.

3. Integrity

3.1 Financial integrity and combating fraud

In our business, all business transactions and records must be accurate and proper. Theft, fraud, embezzlement, money laundering or terrorist financing are not permitted. Since the wording and treatment of such offences vary from country to country, employees who are confronted with such matters should consult the Legal Department or the Compliance Officer.

Confidential information or business secrets may not be disclosed. All business transactions, assets and liabilities are documented in compliance with financial reporting rules. Proper documentation and retention of business records require accuracy and accountability. Financial accounting records must not contain any false or misleading information.

3.2 Protection against corruption and bribery

Corruption, bribery or bribes are inadmissible. Bribery or corruptibility in business transactions occurs when an employee of a company is offered, promised or granted advantages by a third party in order to favour him or her in an anti-competitive manner. Conversely, the offence is fulfilled if the employee asks for these advantages. Here, too, such facts are formulated and treated differently from country to country and persons confronted with such a situation should definitely consult the legal department or the compliance officer.

3.3 Gifts and invitations

Our business decisions are made freely and independently of gifts and invitations. If, nevertheless, the acceptance of a gift or an invitation or the handing over of a gift or the issuing of an invitation should be necessary in the course of a business activity, this is only permissible if it does not violate applicable law or internal company guidelines and does not exceed a value appropriate to the purpose.

Gifts or invitations that are decided by the company and approved by the management can be given or extended according to internal instructions (e.g. Christmas gifts, greeting cards, company events). Further information on questions regarding gifts and invitations can be found in the gift policy.

3.4 Antitrust law

Almost all countries prohibit relationships and agreements with competitors, distributors, traders and suppliers that unfairly distort competition. This applies especially to price fixing, division of sales territories or customer relations, anti-competitive boycotts and other unfair methods of competition. The naming of these various cases is exemplary of many other antitrust regulations. Observing fair competition and the relevant laws and rules is obligatory for us.

The matter is extremely complex and multi-layered. Therefore, antitrust issues should always be clarified with the legal department, if possible first in personal contact.

4. IT and media

4.1 Protection of intellectual property

The protection of intellectual property of any kind is obligatory for us, whether it was produced by our company or by a third party. Intellectual property is any product of intellectual work, regardless of commercial value, such as documentation, graphic work and software. Legal protection for intellectual property is provided by copyright law, trademark law and patent law, among others. Intellectual property can also be protected as a trade secret.

As the legal regulations may also vary from country to country, employees who are confronted with such matters are advised to consult the legal department in case of doubt.

4.2 IT security and IT use

We use IT systems and process data for our business activities.

Appropriate security measures are necessary to protect intellectual property and personal data (passwords, licensed software, appropriate and approved technologies).

There can be serious consequences such as data loss, theft of personal data or copyright infringement if necessary security measures are not observed.

Digital information can be easily duplicated, spread quickly and is almost indestructible. That is why we treat e-mails, e-mail attachments, downloaded files and other digital information very carefully.

The IT systems and devices provided by the company shall be used exclusively for official purposes. The security of the IT systems must be observed by all employees and actively protected against internal and external misuse or threats (such as misuse of passwords, downloading of inappropriate or unauthorised content from the Internet).

The IT department is available for questions and problems.

4.3 Confidentiality and publicity

Confidential information may only be used for the purpose intended for it within the company and the companies affiliated with the company within the meaning of §§ 15 ff. AktG and only distributed to the intended recipients. Furthermore, it may neither be disseminated internally nor published externally.

Confidential information may include contracts, financial data, personnel information, records, research, reports, creative works, intellectual property, business or product plans. It does not matter whether it is in paper, digital or other form.

The publication of confidential information or its disclosure to unauthorised third parties constitute breaches of confidentiality, but may also be violations of antitrust and/or competition law. In addition, so-called confidentiality agreements are often concluded prior to the exchange of confidential information.

Employees who, due to their position, constantly deal with confidential information (areas such as finance, law, human resources, corporate development or similar) must pay particular attention to the observance of confidentiality. This applies in particular to internal exchanges. This confidential information must also be treated internally as if communicating with external third parties.

Press enquiries may only be answered by the management and the corporate communications department. Press enquiries received elsewhere in the company must be passed on to the management or the corporate communications department as soon as possible.