Any whistleblower who is acting in good faith shall be entitled to make report. Persons acting in good faith are covered by these Rules of Procedure. A whistleblower is acting in good faith if, at the time the report is made, the whistleblower believes that the information he or she has provided is true.

All violations of applicable law are relevant, in particular from the area of white-collar crime or violations of human rights-related and environmental obligations, and in particular those in accordance with Section 2 (2) and (3) of the German Supply Chain Compliance Obligations Act (Lieferkettensorgfaltspflichtengesetz). Violations of MAXIM Group’s internal regulations can also be reported.

However, if you have a question about your order, want to complain about a product, are dissatisfied with our performance or service, or have any other concerns, please use our usual contact options info@maxim-gruppe.de.

Please inform the Compliance-Ombudsperson,

• at which company or part of a company
• what
• when
• where
• with which participants

happened.

The Compliance Ombudsperson would also be interested to know which other persons – possibly not involved in the specific events – have knowledge and whether there are any relevant documents (e.g. e-mails, photos).

Before providing the information, please check carefully whether the information you provide is correct. In particular, you must not make any statements that you know to be false.

Please also inform the Compliance Ombudsperson how he can contact you in case of queries.

Making a report is free of charge for whistleblowers.

If you are not sure, please use phrases such as „I believe…“, „I think it is possible…“.

If you are uncertain about the presentation, the assessment and/or the course of action, you can talk to the Compliance Ombudsperson about the case beforehand – also anonymously – and free of charge.

Whistleblowers can remain anonymous. Whistleblowers can arrange with the Compliance Ombudsperson how he can contact them in case of queries if the whistleblower wishes to remain anonymous. Even in the case of an anonymous report, no false information may be transmitted. Whistleblowers may demand that Dr Dilling does not disclose any identity known to him to MAXIM Group.

Whistleblowers may ask the Compliance Ombudsperson to protect their identity and not to disclose their identity or any other information that may reveal their identity to MAXIM Group.

As a lawyer, Dr Johannes Dilling is a holder of professional secrecy and may not disclose the identity of a person providing information to third parties without incurring his criminal liability. Dr. Dilling has taken appropriate technical and organisational measures to protect the information he receives in such a way that third parties have no access to it.

The information that Dr. Dilling passes on to MAXIM Group is also treated confidentially and protected there. The persons responsible for processing the information at MAXIM Group are legally obliged to maintain confidentiality insofar as the violation of human rights and environmental obligations is reported. They are also contractually obliged to treat any information received, and in particular the identity of any whistleblower, confidentially. Furthermore, the persons responsible at MAXIM Group for processing the information are independent and not bound by instructions. In particular, they do not receive instructions from the company management regarding the content or the procedure, e.g. regarding the type and scope of the procedure or its termination. MAXIM Group ensures by organisational measures that only those persons who are responsible for processing the information have access to the information and the documents submitted with it.

Without the consent of the whistleblower, the identity of the whistleblower and any other information that may reveal the identity of the whistleblower may not be disclosed, even during internal investigations.

No, it is not.

On the one hand, the German Whistleblower Protection Act (HinSchG) provides for exceptions to confidentiality in Section 9 para. 2, which, for example, that the identity of a whistleblower may be disclosed to a law enforcement agency if the latter so requests. Explicit reference is made to Section 9 para. 2 HinSchG.

On the other hand, only those persons enjoy confidentiality protection who are acting in good faith, i.e. who do not intentionally or grossly negligently transmit false information. A whistleblower who intentionally or grossly negligently provides false information must expect that his or her identity will become known through a request for information from the data subject pursuant to Article 15 (1) of the General Data Protection Regulation and that the data subject will assert claims for damages.

Finally, neither Dr. Dilling nor MAXIM Group are protected against seizure, i.e. in the event of an official investigation, authorities may seize documents from which the identity of the person providing the information can be deduced.

Whistleblowers who fear that their identity will become known are therefore advised to make a report anonymously. Even in the case of an anonymous report, no false information may be transmitted.

If you are not sure, please use phrases such as „I think…“, „I think it is possible…“, „It could be that…„

No, professional discrimination and reprisals against whistleblowers are strictly prohibited. The MAXIM Group Supplier Code of Conduct and MAXIM Group’s supplier contracts also contain provisions that MAXIM Group’s suppliers must not take any reprisals if whistleblowers make a report. This also applies to threats and attempts of reprisals. Reprisals based on reports will not be tolerated. Whistleblowers are encouraged to report if they are subject to discrimination and reprisals by employees of MAXIM Group or by suppliers of MAXIM Group because they have made a report in good faith. MAXIM Group will respond to these employees or suppliers in an appropriate manner (e.g. by issuing a warning letter, holding a workshop, demanding compensation). Within the reporting procedure and also at the end of the reporting procedure, the Compliance Ombudsperson will enquire with the whistleblowers if they have been subject to reprisals by employees of MAXIM Group or by suppliers of MAXIM Group.

Even after the conclusion of the procedure, whistleblowers may report to the Compliance Ombudsperson if they have been subject to reprisals by employees of MAXIM Group or by suppliers of MAXIM Group.

The Compliance Ombudsperson is not an arbitration board for disputes. The client relationship exists only between the company and the Compliance Ombudsperson. Nevertheless, the Compliance Ombudsperson acts impartially and is not bound by instructions from MAXIM Group. As a lawyer, the Compliance Ombudsperson is already bound by law to secrecy.

The Compliance Ombudsperson will inform you within 24 hours that the report has been received. The Compliance Ombudsperson clarifies the facts of the case with the whistleblower, what expectations the whistleblower has with regard to possible preventive or remedial measures and checks whether the report falls within the scope of application of these rules of procedure, in particular whether there could be a breach of duty related to human rights or the environment within the meaning Section 2 (2) and (3) of the German Supply Chain Compliance Obligations Act (Lieferkettensorgfaltspflichtengesetz). If, in the view of the Compliance Ombudsperson, there is no relevant violation, he will give reasons for this to the whistleblower.

However, if a relevant violation appears possible, the Compliance Ombudsperson will process the report and pass it on confidentially to the respective contact person responsible for the areas of business, labour and human rights or environment at MAXIM Group. The respective contact person decides together with the management of MAXIM Group on how to deal with the report. If there are sufficiently concrete grounds for suspicion of legal or policy violations, these are investigated internally in order to clarify and remedy possible misconduct. This is also done confidentially and discreetly in order to protect the interests of the whistleblowers and the persons concerned by the report. No later than three months after the report, the whistleblower receives feedback from the Compliance Ombudsperson as to whether the reported violation could be established. If this is the case, the violation will be remedied. The expectations of the whistleblower will be taken into account. The whistleblower is encouraged to report it if he/she feels that the remedial action taken is not sufficient.

You can contact the Compliance Ombudsperson by any conceivable means (telephone, mail, fax, post or via the whistleblower system www.safewhistle.info). The Compliance Ombudsperson is also available for personal meetings with whistleblowers, if desired also by way of audio-visual transmission. If you want encrypted communication, you can also use the messenger services Signal and Threema to contact the Compliance Ombudsperson. It is also possible to send encrypted e-mails to the Compliance Ombudsperson via Protonmail to the following address:

RADilling@protonmail.com

The contact details are as follows

Rechtsanwalt Dr. Johannes Dilling

Landgrafenstraße 49

D-50931 Köln/Cologne

Germany

Telefon: +49 (0) 221 933 107 40

Handy: +49 (0) 163 347 6111

Fax: +49 (0) 221 933 107 42

www.ra-dilling.de

www.safewhistle.info

Threema-ID: 3PX6278J

E-Mail: info@ra-dilling.de; RADilling@protonmail.com

Via the whistleblower portal www.safewhistle.info, the messenger services to be found there, by e-mail and by post, whistleblowers can report violations in a language of their choice.

Likewise, whistleblowers may request that an interpreter with a special obligation of confidentiality joins personal meetings with the Compliance Ombudsperson and that this interpreter is able to translate from and into the national language of the whistleblower.

At the special request of a whistleblower, MAXIM Group will provide ats its costs a Compliance Ombudswoman as a contact person in individual cases.

Whistleblowers may also choose to report information about violations to external reporting offices.

1. Bundesamt für Justiz (Federal Office of Justice)

The main external reporting office is the

Bundesamt für Justiz

Adenauerallee 99 – 103

D-53113 Bonn

Germany

Information on the notification procedure at the Federal Office of Justice, to which reference is made in accordance with Section 24 (4) sentences 1, 2 HinSchG, can be found here:

https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes.html

The online registration procedure can be found under the following link:

https://www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html

2. Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin; Federal Financial Supervisory Authority)

The competent external reporting office for reports pursuant to Section 21 No. 1 and No. 2 HinSchG is

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)

Graurheindorfer Straße 108

D-53117 Bonn

Germany.

Information on the notification procedure at the Federal Financial Supervisory Authority, to which reference is made pursuant to Section 24 par. 4 sentences 1, 2 HinSchG, can be found here:

https://www.bafin.de/DE/DieBaFin/Hinweisgeberstelle/hinweisgeberstelle_node.html

https://www.bafin.de/DE/DieBaFin/Hinweisgeberstelle/2_Anonyme_Hinweisabgabe/AnonymeHinweiserteilung_node.html

The online registration procedure can be found under the following link:

https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=2BaF6&c=-1&language=ger

3. Bundeskartellamt (Federal Cartel Office)

The competent external reporting office for reports pursuant to Section 22 (1) HinSchG is

Bundeskartellamt

Kaiser-Friedrich-Straße 16

D-53113 Bonn

Germany

Infringements can be reported at any time, irrespective of the outcome of proceedings via an internal report.

Information on the notification procedure at the Federal Cartel Office, to which reference is made pursuant to Section 24 (4) sentence 1, 2 HinSchG, can be found here:

https://www.bundeskartellamt.de/DE/Aufgaben/Kartelle/HinschG/HinschG.html

The online registration procedure can be found under the following link:

https://www.bkms-system.net/bkwebanon/report/channels?id=bkarta&language=ger

4. European Anti-Fraud Office

You can also report – anonymously if you wish – possible cases of fraud or other serious irregularities with a potentially negative impact on EU funds to the European Anti-Fraud Office (OLAF):

Europäische Kommission

Europäisches Amt für Betrugsbekämpfung (OLAF)

BE-1049 Bruxelles

Belgium

Information on the notification procedure at the European Anti-Fraud Office, to which reference is made pursuant to Section 24 par. 4 sentences 1, 2 HinSchG, as well as the online registration procedure can be found here:

https://anti-fraud.ec.europa.eu/index_de