Sustainability policy for suppliers

For the Zeller Gmelin Group, sustainability is an essential component of success- and values-oriented corporate management. The scarcity of resources and our responsibility toward future generations are a particular focus.

The Zeller+Gmelin Group is committed to the principles of responsible and lawful conduct and calls on its suppliers to also respect the following principles, to take them into account in their corporate policy and to pass them on in their own supply chain.

The following policy sets forth the minimum requirements for all suppliers with regard to sustainability. These requirements are based on fundamental principles of economic, environmental, and social responsibility.

Business ethics and compliance

Binding obligations, such as applicable laws at the local, national, and international levels, must always be complied with. Zeller Gmelin expects its suppliers to comply with all applicable laws and regulations regarding corruption, bribery, fraud, and prohibited business practices.

Combating bribery:

The supplier shall ensure that its employees and subcontractors do not offer, promise, or grant any benefits to Zeller Gmelin employees with the intent of securing a contract or other preferential treatment in business dealings. Invitations and gifts to Zeller Gmelin employees or their close associates may only be given if they are of negligible financial value and are in accordance with customary business practices. Likewise, the supplier shall not solicit any inappropriate benefits from Zeller Gmelin employees.

Fair competition:

Zeller Gmelin expects its supplier to compete fairly and to comply with applicable antitrust laws. The supplier shall neither engage in anti-competitive agreements with competitors nor abuse any potentially dominant market position.

Money laundering:

The supplier does not participate in money laundering activities and complies with the relevant legal obligations to prevent money laundering.

Intellectual property / plagiarism / export controls and economic sanctions:

Fair competition includes combating plagiarism. The supplier handles business correspondence in good faith. Confidential information, all types of data requiring protection, and the intellectual property rights of Zeller Gmelin are appropriately safeguarded in accordance with the relevant legal requirements.

Relevant goods are reported to the appropriate office for export control and economic sanctions are complied with.

Protection of whistleblowers / whistleblowing:

Employees and business partners are encouraged to report violations of the law or misconduct in accordance with this Code of Conduct. Zeller Gmelin guarantees whistleblowers anonymity and protection against termination and will do everything in its power to prevent whistleblowers from suffering any other adverse consequences. Anyone who attempts to take retaliatory action against a whistleblower will face the strictest disciplinary measures.

Social and working conditions:

Zeller Gmelin expects its suppliers to recognize the fundamental rights of their employees, to commit to upholding these rights, and to treat employees with dignity and respect, in accordance with the understanding of the international community. In particular, suppliers must comply with the following provisions:

Free choice of employment: All employment is voluntary. Forced labor, forced prison labor, forced conscription of labor or human trafficking is strictly prohibited.

No child labor: The use of child labor is strictly prohibited in accordance with the provisions of the ILO, the United Nations Convention and/or national laws. Of these various laws, the one with the strictest requirements is to be applied.

Compensation and benefits: All applicable laws, regulations and industry standards on compensation and benefits must be complied with. Deductions from benefits as a disciplinary measure are not permitted. Likewise, deductions from benefits that are not provided for under national law are not permitted without the express consent of the employee concerned.

Working hours: All applicable laws, regulations and industry standards on working hours must be complied with. Overtime must be voluntary.

No Discrimination: Supplier shall comply with all applicable laws prohibiting discrimination in hiring and employment on the basis of race, color, national origin, disability, physical condition, sexual orientation, medical condition, political affiliation, gender, age, appearance, association membership, parenthood or any other characteristic protected by law.

Freedom of association and the right to collective bargaining: The supplier recognizes the right to freedom of association and collective bargaining within the legally permissible framework.

Health and Safety: Supplier shall provide its employees with safe and healthy workplaces in compliance with all applicable laws, regulations and industry standards. Harassment in the workplace is not tolerated.

Working conditions: The supplier must provide its employees with appropriate working facilities. As a minimum, access to drinking water and sanitary facilities must be ensured and care must be taken to ensure fire safety, access to emergency medical care, adequate lighting and ventilation.

Diversity, equality and inclusion: are integral parts of our culture. We empower our employees to contribute their personalities to help shape cultural movements and moments for ourselves, our customers and society. We see diversity, equality and inclusion not only as morally right, but also as crucial to our growth and success. We believe that with a team made up of employees from all demographics and with different backgrounds and experiences, we can develop more meaningful campaigns. We want to actively learn from each other, celebrate different perspectives and ensure that everyone is able to realize their personal potential and develop freely.

Rights of minorities and indigenous peoples: In the supplier’s company, all employees are treated equally in accordance with legal and official requirements. The protection of minorities and indigenous peoples is one of the points of cooperation with its customers and suppliers.

Land, forest and water rights and eviction: The supplier is requested to avoid evictions and the withdrawal of land, forests and water when acquiring, developing or otherwise using land, forests and water. It is expected that all relevant national and international legal and regulatory requirements in this regard are complied with and implemented.

Use of private or public security forces: When using private or public security forces to protect the company, it must be ensured that those affected are protected from extensive violence, torture and the violation of freedom of association and freedom of association. Respect for internationally recognized human rights by the security forces must be guaranteed.

Ecological sustainability / environmental guideline:

Zeller Gmelin expects its suppliers to comply with all applicable laws and regulations, as well as internationally recognized standards for environmental protection.

Environmental Permits: The Supplier shall ensure that all necessary environmental permits and approvals are obtained, kept up to date and complied with in order to act in accordance with the law at all times.

Resource consumption, avoidance of environmental pollution and waste minimization: The supplier undertakes to optimize the consumption of natural resources, including energy and water. Sound measures are taken to prevent pollution and minimize the generation of waste, wastewater and air emissions. Waste water and waste is appropriately labeled and treated prior to discharge or disposal in accordance with applicable laws and regulations.

Hazardous materials and product safety: The supplier undertakes to label hazardous materials, chemicals and substances and to ensure their safe handling, movement, storage, recycling, reuse and disposal. All applicable laws and regulations relating to hazardous materials, chemicals and substances must be strictly observed. Substance restrictions and product safety requirements defined by applicable laws and regulations must be complied with.

Animal welfare: Suppliers pay attention to the welfare of animals and ensure humane treatment in accordance with the five freedoms of animals formulated by the World Organization for Animal Health (OIE): Freedom from hunger, thirst and malnutrition;

Freedom from fear and distress; freedom from physical and thermal discomfort; freedom from pain, injury and illness; and freedom to exhibit normal patterns of behavior.

Soil Quality: Suppliers must also protect ecosystems—and, in particular, areas critical to biodiversity—that are affected by their activities, and avoid illegal deforestation in accordance with international biodiversity regulations, including IUCN resolutions and recommendations. Suppliers must routinely monitor and control their impact on soil quality to prevent soil erosion, nutrient depletion, land subsidence, and contamination.

Noise emissions: General emissions from operations (air and noise emissions) and greenhouse gas emissions shall be typified, routinely monitored, reviewed and treated as necessary prior to release. The supplier also has the task of monitoring its exhaust gas purification systems and is required to find economical solutions to minimize any emissions.

Conserving energy and resources

They ensure that products and processes make efficient use of energy and resources and comply with applicable environmental standards.

Suppliers shall endeavor in particular to:

• Reduction of energy and water consumption
• Reduction of greenhouse gases / compliance with the climate targets of the Paris Agreement / EU / German government
• Increased use of renewable energy
• Suitable recycling/disposal concepts

ZG will regularly review and, where necessary and appropriate, make changes to the Code. Important changes are always communicated to the suppliers.

Eislingen, 01.03.2026

Michael Halmel (Head of Purchasing)

Gülen Ak (Head of Management, Sustainability and Compliance)