Anti Money Laundering Directive (AML Directive)

The Lenzing Group is committed to the highest standards of ethical business principles and commits to fight money laundering and terrorist financing (ML&TF). Money launderers aim to introduce money from illegal transactions into legal circulation. Terrorists aim to obtain money from illegal and also legal transactions for terrorist activities. Lenzing avoids business with criminals and uses a series of preventative measures to ensure that money laundering and terrorist financing are not unwittingly aided and abetted. The AML Directive describes the processes and control mechanisms implemented at Lenzing. The directive was introduced in 2020. In 2022 tools for the KYC (Know Your Counterpart) process were introduced to identify Lenzing counterparties and verify their identities. Furthermore, counterparties can be checked for adverse media, politically exposed persons (PEP) and sanctions to mitigate the risk of business relationships with illegitimate business activities.

Antitrust Directive

Lenzing does not tolerate or participate in any business conduct, transaction or activity that violate the antitrust and competition laws applicable to it. The company respects applicable trade laws and restrictions as imposed by the United Nations or other national or supranational bodies or governments. To ensure that all relevant antitrust regulations are known and adhered to within the Lenzing Group, Lenzing’s internal Antitrust Directive serves as a supplement to the Lenzing Global Code of Business Conduct. It applies to all business activities and operations in accordance with applicable competition law. It informs all employees how to behave correctly when dealing with business partners and shows which activities may pose an increased risk of antitrust violations. Furthermore, this directive helps to promote trust in business dealings, preserve Lenzing’s reputation and avoid or reduce costs, risks and damages resulting from a violation of antitrust law.

Anti-Bribery and Corruption Directive (ABC Directive)

The Anti-Bribery and Corruption Directive (ABC Directive) supplements Lenzing’s Global Code of Business Conduct by providing global minimum standards to ensure that Lenzing’s activities are conducted ethically and with integrity. The goal of this Directive is to ensure that all relevant anti-bribery and corruption regulations are known and observed across the Lenzing Group. The Directive applies to all operations and activities in compliance with all applicable anti-corruption laws, including the Austrian Criminal Code, the United Kingdom Bribery Act 2010 and the US Foreign Corrupt Practices Act. The directive clearly defines what bribery, corruption and acceleration payments mean, and provides guidelines on what is considered acceptable behavior. Receiving and giving gifts, as well as accepting and giving hospitality or invitations, require – depending on the monetary value – specific approval within the Registration Tool for Gifts and Hospitalities. Country-specific limits have been defined for all legal entities.

Know-How Protection Directive

Specialization and innovative strength are key factors for the worldwide success of Lenzing. In today’s economy, information and know-how as a result of R&D investments, creativity and business initiatives have become the most important factors for developing and maintaining competitive advantages. Lenzing’s know-how is a central asset that must be preserved and protected using all the protective measures at Lenzing’s disposal. The protection of know-how relates not only to Lenzing’s leadership in technology, but also extends to its many different activities worldwide, including business secrets. Every employee is a key factor in Lenzing’s future know-how protection program and is directly affected by the know-how protection process described in this directive.

Investigation Directive

The purpose of this Compliance Investigation Directive is to set out a framework for the investigation of material and substantiated violations of laws, Lenzing’s Code of Business Conduct or internal Policies and Directives as set forth in the intranet.

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