Code of Conduct for Suppliers of AGILOX Services GmbH, AGILOX Systems GmbH & AGILOX Holding

Status: July 2026

The Code of Conduct for suppliers are additionally available for download as PDF here.

1. Purpose / Scope

This Code of Conduct for Suppliers (“Supplier Code”) defines the requirements for all AGILOX suppliers with regard to relevant social and environmental aspects such as human rights, working conditions, environmental protection, and ethical business conduct. The supplier’s acceptance of this Supplier Code serves as a binding basis for the business relationship. If the supplier engages subcontractors in the provision of services, the supplier undertakes to contractually pass on the principles of this Supplier Code and, to the extent possible and reasonable, to ensure that the requirements are complied with throughout the entire value chain. To ensure this, the supplier must also implement appropriate and risk-based control measures.

This document applies to the following entities of the AGILOX Group:

• AGILOX Holding
• AGILOX Services GmbH
• AGILOX System GmbH

For the sake of better readability, the simultaneous use of masculine and feminine forms. All references to persons apply equally to both genders. The employer reserves the right to amend, supplement, or dispense with them entirely. The most recent valid version is listed and linked in the document matrix; versions stored elsewhere or printed versions may be outdated and no longer valid. All copyrights and property rights to this document are held by the AGILOX Group. Any use, reproduction, modification, or distribution requires the prior written consent of the rights holder.

2. Social Responsibility and Human Rights

Our suppliers commit to unequivocally respecting and observing human rights as fundamental values, based on the European Convention on Human Rights and the Charter of the United Nations. To protect their employees, our suppliers undertake to comply with all laws and regulations concerning health and safety in the workplace, guided by the fundamental principles of the conventions of the International Labor Organization (“ILO Conventions”).

2.1 Prohibition of Forced Labor

Suppliers must take appropriate and reasonable measures to prevent debt bondage, forced and compulsory labor, as well as any form of modern slavery and human trafficking within their own business operations and/or along the supply chain. Business partners must ensure that employment relationships are based on voluntary participation and that employees can terminate them of their own free will and with reasonable notice. Furthermore, no unacceptable treatment of workers, such as psychological abuse, sexual harassment, or humiliation, may take place. The hiring or use of security personnel is prohibited if, during their deployment, individuals are treated in an inhumane or degrading manner, are injured, or if their freedom of association is thereby impaired.

2.2 Prohibition of Child Labor

Child labor must not be used at any stage of the value chain. Suppliers are required to comply with the recommendations set forth in the ILO Conventions regarding the minimum age for the employment of children. Accordingly, the age must not be lower than the age at which compulsory schooling ends under the law of the place of employment and, in any case, must not be under 15 years. Young workers under the age of 18 may not be employed in work that is harmful to the health, safety, or morals of children.

2.3 Fair Compensation and Working Hours

Compensation for regular working hours and overtime must meet the national statutory minimum wage or the minimum standards customary in the industry, whichever is higher. Employees must be provided with all benefits required by law. Wage deductions as disciplinary measures are not permitted. The supplier must ensure that employees receive clear, detailed, and regular written information regarding the composition of their compensation. Working hours must comply with applicable laws or industry standards. Overtime is permitted only if worked on a voluntary basis.

2.4 Freedom of Association

Suppliers’ employees must have the freedom to decide, without threat or intimidation, to form associations, join a union, appoint employee representatives, and stand for election to such positions. Employees must not be discriminated against on the basis of forming, joining, or being a member of such an organization.

2.5 Prohibition of Discrimination and Harassment

Our suppliers ensure that any form of discrimination, intimidation, harassment, or unjustified disadvantage against their employees in the workplace is prohibited. In particular, unequal treatment based on, for example, ethnic or social origin, skin color, gender, nationality, language, religion, physical or mental disabilities, gender identity, sexual orientation, health status, age, marital status, or pregnancy/parenthood is prohibited, unless such treatment is objectively justified by the requirements of the job. Unequal treatment includes, in particular, the payment of unequal compensation for work of equal value.

2.6 Occupational Health and Safety

Our suppliers comply with the applicable labor, occupational health and safety, and fire safety laws to ensure a safe and healthy work environment. By establishing and implementing appropriate occupational safety systems, necessary preventive measures are taken against accidents and health hazards that may arise in connection with the work performed. Excessive physical or mental fatigue must be prevented through appropriate measures. In addition, employees are regularly informed about the applicable health and safety standards and safety measures and receive appropriate training.

2.7 Preservation of Natural Resources

Our suppliers must not, in violation of the law and/or other legitimate rights, deprive communities of land, forests, or water bodies whose use ensures people’s livelihoods. Suppliers must refrain from causing harmful soil degradation, water and air pollution, noise emissions, and excessive water consumption if this could significantly impair the natural resources essential for food and drinking water or human health.

2.8 Handling of Conflict Minerals

For the conflict minerals tin, tungsten, tantalum, and gold, as well as for other critical raw materials from conflict-affected and high-risk areas such as cobalt, our suppliers establish processes in accordance with the guidelines of the Organization for Economic Cooperation and Development (Organization for Economic Cooperation and Development) regarding the fulfillment of due diligence obligations to promote responsible supply chains for minerals from conflict-affected and high-risk areas, and we expect the same from their subcontractors.

3. Environmental Responsibility

Climate change and environmental degradation are among the greatest challenges of our time. For AGILOX, therefore, acting in a sustainable and resource-efficient manner is an integral part of our corporate culture. Compliance with generally accepted standards and laws in this area—as well as with regard to animal welfare, species diversity, and biodiversity—is a fundamental requirement in our business relationships. Our suppliers commit to complying with all applicable environmental laws, regulations, and standards, as well as to operating an efficient system for identifying and eliminating potential environmental hazards. This system includes, in particular, the following measures:

• Identifying and minimizing negative impacts on the environment;
• Measures to reduce environmental emissions and waste generation;
• Measures to reduce interference with existing ecosystems;
• Measures for the efficient and responsible use of resources (especially energy, water, and raw materials);
• Measures to prevent accidents, harm to health, and environmental damage;
• Preparation for and response to emergency situations;
• Use of renewable resources (to the extent possible);
• Ongoing review and continuous improvement of our own environmental management system.

4. Integrity and Ethical Business Conduct

We expect our suppliers to act not only in a sustainable, socially responsible, and environmentally conscious manner when providing services, but also, of course, to always act in an ethically and legally sound manner. Even the mere appearance of unethical behavior must be strictly avoided.

4.1 Compliance with Laws

Our suppliers must familiarize themselves with the laws, regulations, and rules of the countries in which they conduct business and comply with them without exception

4.2 Integrity

Our suppliers must act with integrity at all times and take appropriate and reasonable measures to remedy any identified violations. Any form of bribery, money laundering, extortion, and corruption—including so-called “facilitation payments” (payments made to expedite routine business transactions)—must be strictly prohibited. Suppliers must ensure that their employees, subcontractors, or representatives do not grant, offer, or accept bribes, kickbacks, improper donations, or other improper payments from public officials or other third parties. Procedures for monitoring and enforcing statutory prohibitions must be implemented to ensure compliance with anti-corruption laws.

4.3 Avoiding Conflicts of Interest

Suppliers shall make their decisions solely on the basis of objective criteria and shall not allow themselves to be influenced by irrelevant interests or relationships.

4.4 Free Competition

Our suppliers shall uphold fair and free competition and comply with applicable competition and antitrust laws. In particular, they must not enter into anti-competitive agreements or arrangements with competitors, suppliers, customers, or other third parties, and must not abuse any potential dominant market position. Suppliers shall ensure that, within the scope of their business activities, there is no exchange of information sensitive under competition law, nor any other conduct that unlawfully restricts or may restrict competition.

4.5 Import and Export Controls

Our suppliers strictly ensure compliance with all applicable laws governing the import and export of goods, services, and information. The applicable sanctions and embargo lists must also be observed. Business partners must ensure that all taxes, duties, and license fees levied in connection with the extraction, trade, and export of minerals in conflict and high-risk areas are paid in accordance with applicable law.

4.6 Data Protection

Our suppliers must comply with data protection and information security laws and regulatory requirements when collecting, storing, processing, transmitting, and disclosing sensitive information. Intellectual Property Rights Intellectual property rights must be respected. Transfers of technology and know-how must be conducted in a manner that protects intellectual property rights and customer information.

5. Supplier Responsibilities

We expect our suppliers to identify all relevant risks within their own supply chain and address them through appropriate and suitable measures to prevent violations of legal provisions as well as the standards and regulations set forth in this Supplier Code of Conduct. If a non-compliance is detected or a suspected case arises, we expect the affected supplier to immediately inform us of the identified violations, suspected cases, or risks, as well as the corrective actions taken.

5.1 Monitoring Compliance

AGILOX reserves the right to verify compliance with the standards of conduct in the supply chain using appropriate means. The verification may be conducted through supplier self-reports or through risk-based audits at the suppliers’ production sites, whereby the latter may only be conducted after prior notice and in the presence of representatives of the supplier. The verification procedures shall be conducted in accordance with applicable data protection laws. The verification shall not result in disproportionate restrictions on the suppliers’ business activities or in breaches of confidentiality agreements with third parties. Suppliers are obligated to assist AGILOX to a reasonable extent in conducting the audit procedures and to bear their own costs associated with the audit. AGILOX shall also bear its own costs or the costs of the third party it engages.

5.2 Consequences

Compliance with the Supplier Code by its suppliers and subcontractors is an essential component of every business relationship for AGILOX. In the event of violations of the principles set forth in the Supplier Code, AGILOX expects its suppliers and subcontractors to take appropriate measures without delay to prevent similar violations from occurring in the future on a lasting basis. A lack of willingness to cooperate in ending the misconduct or remedying any resulting consequences within a reasonable period of time, or the severity of the violation[1] itself, may also constitute grounds for early termination of the business relationship.

6. Supplier Declaration

This Supplier Code of Conduct is an integral part of the contractual relationship with the supplier. By signing this document, the supplier agrees to the obligations and requirements set forth in this Supplier Code of Conduct as an integral part of the business relationship and expressly undertakes, in particular, to

• always act responsibly and ethically and to comply with the obligations and requirements of this Supplier Code as minimum standards;
• to communicate the principles and guidelines of this Supplier Code to its upstream suppliers along the value chain in an appropriate manner and to require them to comply;
• to communicate the contents of this Supplier Code to its own employees as well as to agents and subcontractors in a manner understandable to the respective target group, to insist on compliance with due diligence, and to take all necessary measures to implement the requirements.

In cases where AGILOX has agreed with the supplier on individual contractual obligations that deviate from these principles, such individual contractual obligations shall take precedence.

[1] In particular, serious violations of the Supplier Code of Conduct include human rights violations, child labor, cases of corruption, serious violations of worker protection laws, and gross violations of environmental protection laws.