Whistle-Blower System

The purpose of these Rules of Procedure for the Whistle-Blower System is to provide a structured
method for receiving and handling reports and complaints about possible violations of laws, guidelines
or ethical standards within our Group. Their aim is to protect whistle-blowers and to ensure that all
reports and complaints are investigated and dealt with appropriately. We are committed to create a
transparent, confidential and fair environment in which employees, managers, contractors and others
with business dealings with our Group can safely and securely report concerns or grievances.
 

It is our firm policy that whistle-blowers who act in good faith and report concerns responsibly do not
have to fear any disadvantages or disciplinary measures. All reports and complaints are treated
confidentially and the identity of the whistle-blower is protected.
 

We encourage all employees and others involved who have concerns or who observe violations of
laws, guidelines or ethical standards to use these Rules of Procedure to submit reports or complaints.
The active participation of our employees and the preservation of the integrity of our Group enable us
to shape a responsible and successful future together.

These Rules of Procedure define the principles for operating the whistle-blower system in the
companies of the von Eicken Group. To this end, they contain instructions on access to the system and
its scope, the course of procedure, competencies and responsibilities as well as ensuring protection of
whistle-blowers.

All employees of the von Eicken Group have the option of addressing reports and complaints to the
complaints office. This also expressly includes employees who are in training or temporary employment
with the companies of the von Eicken Group.

The system is also available to those who have business dealings (in particular suppliers and customers)
or any other connection with companies of the von Eicken Group.

The following reporting channels are available for this purpose:
 

•  Telephone hotline
  Contact the complaints office on the following telephone number:
  +49 (0)451 89006-540
   

• Contact form
Contact the complaints office using the contact form on our website. You can find the form here:
www.von-eicken.com/de/verantwortung/kontaktformular-interne-meldestelle
 

Employees can also use the complaint channels to arrange a personal meeting with the complaints
office.

The procedure enables employees and third parties alike to report violations that fall within the material scope of Section 2 of the German Whistle-Blower Protection Act (HinSchG):

https://www.gesetze-im-internet.de/hinschg/__2.html.

Evidence or suspicions of violations within the meaning of Section 2 HinSchG can also be reported.

The von Eicken Group’s whistle-blower system is operated by an external third party engaged for this
purpose. The person engaged guarantees impartiality, is independent, is not bound by instructions and
is bound to secrecy.

This function is performed by A&K Consulting GbR. The reports and complaints submitted via the
reporting channels are received by A&K Consulting GbR on its own behalf, handled in accordance with
the applicable laws and these Rules of Procedure and documented accordingly.

The procedure, from receipt of a report to the result of the investigation, is as follows:

Abbildung: Prozess

Reports or complaints are submitted via the aforementioned reporting channels. Reports should be as
detailed as possible and include all relevant information, including the date, location, persons involved
and a clear description of the suspected violation. The whistle-blower is notified of the report’s receipt
within seven days from the date of submission.
 

The information received is then checked for plausibility and reviewed to determine whether there is
a case for initiating the complaints procedure, i.e. a legitimate suspicion of a violation within the
meaning of Section 2 HinSchG.

Rules of Procedure for the Whistle-Blower System of the von Eicken Group (3)
If this is not the case, the whistle-blower will be referred to the local works council. If it is determined
that the whistle-blowing and complaints procedure within the meaning of these Rules of Procedure is
applicable, the facts of the reported incident shall be investigated. The aim of the investigation is to
determine whether a violation has actually occurred. In the course of the investigation, the necessary
information and documents will be obtained in strict compliance with all procedural principles. If
necessary, the whistle-blower will be contacted for further information. Other von Eicken Group
employees may need to be consulted on a case-by-case basis for the purpose of investigating the
suspected incident, particularly the person implicated in the report or other third parties. The group
of such persons must be limited to those absolutely necessary for the appropriate handling of the
suspected incident.

The follow-up action to be taken after the investigation depends on the outcome of the investigation
in each case. Examples of such action include:
 

• Conducting further internal investigations
• Contacting the person(s) concerned
• Submission of the case to a competent authority for further investigation
• Conclusion of the procedure due to no violations within the meaning of Section 2 HinSchG
  being identified
   

If individual actions are initiated on the basis of further findings, the taking of the action is monitored
by the complaints office if necessary and checked for effectiveness.

The procedure ends with a response to the whistle-blower. In this response, the complaints office
provides information on the findings and the outcome of the investigation and/or the action taken.
 

Anonymous reports and complaints are accepted as long as they contain sufficiently detailed and
relevant information to conduct an investigation. However, please note that in the case of anonymous
reports, confirmation of receipt, any reference to the local works council, queries and any other
feedback to the whistle-blower provided for in the Rules of Procedure are ruled out.

In order to enable an appropriate and effective complaints and whistle-blowing procedure, the
following principles apply to all findings obtained on the basis of whistle-blowing:
 

• Confidentiality
  All information that becomes known to the complaints office in the course of the proceedings
  shall be treated confidentially. In particular, the identity of the whistle-blower is protected
  with the utmost care. The same applies to the identity of the person(s) implicated by the
  report.
  The procedure follows a strict ‘need to know’ principle. Only persons who are absolutely
  essential for the handling of the report are involved in the procedure. Information about
  investigation findings is only shared with those persons who actively need it for further
  proceedings or to comply with legal obligations.
   
• Independence and freedom from instructions
  The complaints office performs its duties independently. Its methods are at its own discretion
  and it is only subject to legal requirements and these Rules of Procedure.
  Page 4 of 4
  Rules of Procedure for the Whistle-Blower System of the von Eicken Group (3)
  The independence and freedom of the complaints office are explicitly guaranteed.
   
• Protection against reprisals
  No reprisals of any kind will be directed against the whistle-blower.
  They shall not be held responsible for the manner in which their information is procured, as
  long as the procuring action does not as such constitute a separate criminal offence or a
  violation of internal regulations of the von Eicken Group.
   
• Right to be heard
  Any person who is the subject of proceedings against them shall be given the opportunity to
  comment on the allegations. No action will be taken until the person concerned has been
  heard by the complaints office.
   
• Fairness
  The procedure shall be carried out in an objective manner and without any bias. In the event
  of suspicion against a person, they shall be considered innocent until proven otherwise.

•  Compliance with legal regulations
  Compliance with legal regulations will be ensured.

   

Lübeck, September 2026