RESPONSIBLE CONDUCT

Responsible conduct is viewed holistically at Klöckner & Co. For us, an integral part of our corporate culture is the rule-compliant behavior of our employees and business partners, which forms the basis for corporate responsibility. Adherence to internationally applicable rules and fair dealings with our business partners and competitors are among the most important and competitors are among the most

important principles of our company. In addition to consistent respect for human rights, compliance with the fundamental values and principles of our company is also of central importance to us. We have formulated these in our Code of Conduct. Compliance is the direct responsibility of each and every individual.

KEY FIGURES

0 <1% conflict minerals in our products
0 SDGs with particular relevance for us

TAKING RESPONSIBILITY

As an international Group with numerous supplier and customer relationships worldwide, Klöckner & Co aims to ensure integrity and responsibility both within the Company and in interactions with business partners, as well as to establish responsible relationships. Klöckner & Co expects employees at all levels of the Company, regardless of their hierarchical position, to comply with prevailing competition rules and antitrust laws. The Management Board has unequivocally expressed in its "Tone from the Top" that antitrust violations and corruption are not tolerated at Klöckner & Co and any infringements are systematically pursued.

In this regard, it is a fundamental principle of Klöckner & Co that our employees act in accordance with the applicable competition law. We are committed to free competition and to the recommendations of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions of December 17, 1997. In addition, Klöckner & Co strives to comply with all anti-corruption laws of the countries in which we do business, including the UK Bribery Act and the US Foreign Corrupt Practices Act.

The Groupwide Code of Conduct and the Group's internal policies and procedures, e.g. on compliance with antitrust regulations, the involvement of intermediaries, money laundering prevention, export controls and combating corruption in business transactions, serve as a reference and guide for our employees. A Groupwide training program, which is mandatory for all employees of the Group, raises awareness of our Code of Conduct.

The training program is divided into various modules appropriate to the target group, which are updated at regular intervals by refresher training courses. The assignment and success monitoring of mandatory training courses is carried out in an IT-supported learning management system. We expect our external business partners to observe the ethical values and principles of our Code of Conduct or Supplier Code of Conduct or an equivalent code of conduct of their own and to implement them effectively in their organization.

Klöckner & Co SE and its country organizations pay attention to ethically correct and compliant behavior in business dealings. As stated in our Code of Conduct and moreover in our Group human rights policy, Klöckner & Co does not tolerate any violation of the principles set out in them under any circumstances. Alongside observance of laws and human rights, these principles include the prohibition of child labor and ensuring workforce health and safety, as well as compliance with the statutory minimum wage and working hours. This concerns both our own Company and all upstream parts of our value chain. We expect everyone in our supply chain to follow the same principles. In order to

clearly convey this expectations, we introduced a Group-wide Supplier Code of Conduct in fiscal year 2018. By recognizing our Supplier Code of Conduct, suppliers commit to compliance with applicable laws, to sustainability and to the ethical values of Klöckner & Co. If the supplier has established its own equivalent Code of Conduct in its company, an equivalence check will be performed by the Corporate Compliance Office. If this check reveals serious deviations in the above-mentioned areas and the supplier refuses to recognize our Supplier Code of Conduct, he will be consistently blocked from further purchasing.

Klöckner & Co pays particular attention to the prudent and responsible procurement of products. For example, a key objective in the procurement process is to ensure that the minerals contained in our products do not originate from conflict countries. The company ensures the fulfillment of due diligence requirements in the supply chain for raw materials from conflict and high-risk areas and the restriction of the use of certain hazardous substances in electrical and electronic equipment. Dual-use goods and the relevant foreign trade regulations are monitored centrally through systemic controls in the IT systems. Of particular interest are conflict minerals such as columbite-tantalite (coltan), cassiterite (tinstone), gold, wolframite and their derivatives, which include tantalum, tin and tungsten.

In fiscal 2021, the annual review of our product portfolio revealed that < 1% of our products may contain tantalum, tin or tungsten. Should our customers require proof of this, we use the Responsible Minerals Initiative's "Conflict Minerals Reporting Template" for all relevant suppliers to systematically query the origin of conflict minerals. We expect suppliers to work with their suppliers to trace conflict minerals back to at least the smelter and to commit to standard reporting processes. We also expect our suppliers to retain appropriate evidence for five years and to provide it to Klöckner & Co upon request. If a supplier fails to provide proof of the origin of conflict minerals, he will be systematically blocked from further purchases. The same applies if the supplier does not commit to the above principles regarding the origin of conflict minerals.

As a company with a long tradition, Klöckner & Co also considers it its duty to contribute to the well-being of society. We are committed to the principles of the "Davos Manifesto" of the World Economic Forum. In addition, active involvement in the immediate vicinity of our company headquarters and branches is important to us and is a factor that creates identity for our company.

According to the principles of the "Davos Manifesto", the universal task of a company in the fourth industrial revolution consists of three principles. We are committed to the principles of the "Davos Manifesto" and regard them as a guideline for our corporate actions.

  • The purpose of a company is to engage all its stakeholders in shared and sustained value creation.
  • A company is more than an economic unit generating wealth.
  • A company that has a multinational scope of acts itself as a stakeholder – together with governments and civil society – of our global future.

It is possible to anonymously report indications of possible compliance violations to the Corporate Compliance Office. Employees and third parties can report possible violations of our Code of Conduct on the platform's homepage or via the company's website. In addition, a 24/7 telephone hotline is available free of charge worldwide.

Klöckner & Co operates in 13 countries worldwide, maintains around 140 locations and provides jobs for around 7,200 people. This gives rise not only to a responsibility for our employees, but also for the respective regional environment of our company headquarters and our branches. We are therefore committed to the communities in which our sites are located, thus playing our

part in solving social challenges. social challenges. For more than ten years now, our corporate headquarters has been focusing on community work in Duisburg-Marxloh, which is characterized by a high proportion of residents with an immigrant background. We cooperate with schools, children's and youth facilities, and regional foundations.

UN SUSTAINABLE DEVELOPMENT GOALS

The United Nations 2030 Agenda for Sustainable Development lays the foundation for shaping global economic progress in harmony with social justice and within the Earth’s ecological limits. At its core are 17 Sustainable Development Goals (SDGs). We support the 2030 Agenda for Sustainable Development and the 17 Sustainable Development Goals. The goals defined by the United Nations are on an equal footing and are mutually dependent – but in the context of our business activities, some of the goals and indicators have particular relevance for our economic activities.

For these goals, we see special responsibility and opportunities for influence, which vary depending on the goal. We take into account the positive impact that Klöckner & Co has on the achievement of the goals. We support the goals by continuously improving our business processes and services while reducing the impacts of our operations. Our action areas for sustainability are reflective of the high relevance that the pursuit of these specific goals has for us. We evaluate our action areas on a regular basis, taking into account the views of internal and external stakeholders as well as the impact of our actions on the environment and society.

An important prerequisite for our success and sustainable development is the safety and well-being of our employees and business partners. With our Group-wide “Safety 1st” program, we aim to protect our employees, provide safe working conditions and minimize health risks. Klöckner & Co stands for safe, fair and clean labor standards and processes. For this reason, we use the lost time

injury frequency (LTIF) indicator as a non-financial performance indicator. As a Group operating globally, we pay special attention to respect for human rights as well as social and ecological aspects in our worldwide supply chains. We only work with partners who demonstrate equivalence with our requirements and demand the same from their suppliers.

Klöckner & Co is committed to providing an appreciative and prejudice-free working environment. We leverage different ways of thinking, experiences, perspectives and lifestyles for innovative strength and the Company’s long-term success. We want to drive sustainable economic growth through diversity and the efficient use of resources. In terms of equal opportunity, the inclusion of women in specialist and management positions is an important concern for us as

well. We have set our sights on increasing the number of women in management roles throughout the Group. We promote reasonable and fair labor and social standards. In addition, we assume social responsibility – for example through monetary and in-kind donations, knowledge transfer and the personal engagement of our employees.

As a pioneer in the industry and one of the few players in our sector, Klöckner & Co has signed up to the Science Based Targets initiative (SBTi) “Business Ambition for 1.5°C” campaign, the world’s most ambitious and significant framework for emissions reduction. The initiative has recognized our near-term emission reduction targets for 2030 as science-based targets. Additionally, we plan to reduce all directly controllable carbon emissions to net zero by as early as 2040.

The sustainable strategic orientation of our business makes us pioneers in our industry and means we can actively drive the green transformation of the economy and society. We are committed to reducing the environmental impact of our own business activities and increasingly establishing elements of the circular economy. We are also involved in climate change mitigation projects in countries where we do not do business.

YOUR CONTACT

Felix Schmitz

Head of Investor Relations|Head of Strategic Sustainability

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Felix Schmitz

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