Supplier Code of Conduct of HMF Smart Solutions GmbH

2 Scope of application

2.1 The following Code of Conduct for Suppliers applies to all deliveries and services (“subject matter of the contract”) from a contractual partner (“Supplier”) to HMF Smart Solutions GmbH (“HMF”).

2.2 The Supplier is aware that the products it has supplied to HMF are integrated into HMF’s end products, among other things. The end products are sold by HMF to its customers worldwide.

2.3 The supplier’s terms and conditions of delivery and contract shall not become part of the contract unless HMF expressly agrees to them in writing.

3 Laws and guidelines

We expect our suppliers to conduct themselves in an impeccable manner and to comply with the laws and regulations of the individual countries in which we do business. The following points must be observed.

3.1 Avoidance of conflicts of
a) Establishment of precautionary measures to prevent corruption, extortion or bribery
b) No acceptance of gifts and benefits that go beyond what is generally accepted and could lead to conflicts of interest
c) Compliance with fair competition in the selection of suppliers/subcontractors
d) Establishment of precautionary measures to prevent money laundering

3.2 Compliance with data protection regulations (DSGVO/GDPR, BDSG)

3.3 Protection of confidential information and intellectual property rights

3.4 Compliance with national and international embargo, export and import regulations

4 Social responsibility

We expect compliance with the following human rights and labor guidelines.

4.1 Fair and open-minded behavior towards each other and towards our business partners, with the aim of advising and serving our customers as well as possible

4.2 No discrimination or harassment in the workplace based on age, disability, origin, gender, political views, trade union activities, race, religion or sexual orientation

4.3 Compliance with the ban on child labor

4.4 Compliance with the ban on forced labor

4.5 Guaranteeing the freedom of assembly

4.6 Fair working conditions and compliance with statutory working hours and remuneration guidelines must be ensured.

4.7 Compliance with applicable occupational health and safety requirements (HMF has published further information on health and safety on the HMF Corporate Social Responsibility website).

4.8 The contractual partner undertakes to deliver the delivery item in accordance with the provisions of Regulation (EU) 2017/821 of 17.05.2017 laying down supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores and gold originating from conflict-affected and high-risk areas and Section 1502 of the US Dodd-Frank Act. The contractual partner also undertakes to identify the use of so-called “conflict minerals” (tin, gold, tantalum, tungsten) in its supply chain and to take appropriate measures to ensure that the delivery item does not contain any conflict minerals in accordance with the above Regulation (EU) 2017/821 of 17.05.2017 and Section 1502 of the US Dodd-Frank Act. In the event of a violation of the aforementioned regulations, the contractual partner shall indemnify and hold HMF harmless from and against all resulting damages and claims of third parties.

5 Ecological responsibility

5.1 HMF Smart Solutions GmbH is aware of its responsibil-ity to make a contribution to environmental and climate protection and has published its guidelines on its website: Sustainability.

5.2 The supplier warrants that it complies with the requirements of the EU Chemicals Regulation REACH (Regulation (EC) No. 1907/2006 of December 30, 2006) as amended from time to time – hereinafter referred to as the REACH Regulation – and in particular that the substances have been registered, if required. We are not obliged to obtain an authorization under the REACH Regulation for a delivery item supplied by the supplier.

5.3 The supplier further assures not deliver any delivery items containing substances according to
a) Annex 1 to 9 REACH Regulation as amended,
b) Council Decision 2006/507/EC (Stockholm Convention) on persistent organic pollutants, as amended,
c) EC Regulation 1005/2009 on substances that deplete the ozone layer, as amended,
d) the Global Automotive Declarable Substance List (GADSL) in its current version,
e) RoHS (2011/65/EU, (EU) 2015/863) for products according to their scope of application,
f) EU Battery Regulation (EU) 2023/1542 for products that fall within the scope

5.4 If the delivery items contain substances that are listed on the so-called “Candidate List of Substances of Very High Concern” (“SVHC list”) in accordance with REACH, the supplier is obliged to inform us of this immediately. This also applies if substances not yet listed are added to this list in the case of ongoing deliveries.

5.5 Furthermore, the delivery items must not contain asbestos, biocides or radioactive material. If these substances are contained in the delivery items, we must be informed of this in writing prior to delivery, stating the substance and the identification number (e.g. CAS) and a current safety data sheet for the delivery item. The delivery of these delivery items requires a separate release by us.

5.6 The supplier is obliged to use environmentally compatible products and processes in the production or provision of the subject matter of the contract as well as in the case of supplies or ancillary services of third parties within the scope of economic and technical possibilities.

5.7 The supplier shall pack the subject matter of the contract in a professional and environmentally friendly manner, whereby the necessary scope shall not be exceeded. At the request of HMF, the packaging material shall be taken back free of charge at the place of performance and disposed of in accordance with the statutory provisions. If the packaging material is not taken back, HMF shall be entitled to have it professionally disposed of or recycled at the Supplier’s expense.

5.8 The supplier is responsible for compliance with the requirements in accordance with the current version of Directive 2012/19/EU of the European Parliament (WEEE) and the Electrical and Electronic Equipment Act (ElektroG)

5.9 The Supplier shall take back electrical and electronic equipment subject to return at the request of HMF free of charge and dispose of it in accordance with the statutory provisions. A return facility shall be provided for this purpose. In the event of non-return, HMF shall be entitled to have professional disposal carried out at the Supplier’s expense.

5.10 The supplier shall be liable for the environmental compatibility of the subject matter of the contract and the packaging materials and for all damage caused by the breach of its statutory obligations. At the request of HMF, the supplier shall issue a certificate of quality for the delivered subject matter of the contract free of charge.

6 Information security and data protection

The supplier undertakes to comply with appropriate organizational and technical measures to protect confidential information and personal data. This includes the implementation and maintenance of an information security management system in accordance with ISO/IEC 27001 or an equivalent standard, or proof of comparable procedures. Upon request, the supplier shall provide suitable evidence (e.g., certificates, audit reports) of compliance with these requirements.

7 Complaints procedure

Suppliers and third parties have the opportunity and the right to report any violations or suspected violations of our Code of Conduct or applicable laws. For this purpose, there is the option of reporting such cases via our whistleblower system on the HMF website in the footer area. Anyone who, on the basis of solid evidence and in good faith, is convinced that a violation of the law or the Code of Conduct has occurred or may occur and decides to report this to HMF can be sure that they will not suffer any disadvantages. In each individual case, HMF will, if necessary, take measures to protect the person making the report from any disadvantages. To the extent possible and permitted by law, HMF will ensure the confidentiality of the identity of persons who report violations or suspected violations under this policy and of those who assist in the investigation of such cases.

8 Priority rule

This Supplier Code of Conduct is drawn up in German and English; in the event of any discrepancies, the German version shall prevail.

Valid from: September 2025