All publicly available policies of the Lenzing Group are available under the following link: Compliance – Lenzing – innovative by nature. For international regulatory references in the Group’s policies, please see the “Intergovernmental regulation references in policies” table in the annex. To ensure that no human rights violations occur within the sphere of Lenzing’s influence, Lenzing has a Policy on Human Rights and Labor Standards, which refers to the Organisation for Economic Co-operation and Development (OECD), International Labour Organization (ILO) and the Universal Declaration of Human rights (UDHR). For more information on policies stipulating respecting human rights, please see the “Own workforce” chapter. Each of the policy commitments was approved by the Managing Board of the Lenzing Group, the former Executive Committee or the Management Directors of Lenzing Fibers Grimsby Ltd. (Modern Slavery Act of Lenzing Fibers Grimsby Ltd.). Policies and Directives are available to all employees in Lenzing’s intranet. They exist in the following languages: German, English, Czech, Chinese, Bahasa, Portuguese and Thai.

The document manager (“caretaker”) in Compliance is the Group Compliance Officer, who therefore has the responsibility to disseminate a document to relevant business units. Compliance guides and materials are stored in Lenzing’s intranet and made available to compliance stakeholders. The resources are managed, updated and supplemented by Lenzing Global Compliance.

Hierarchy of compliance guidelines and directives

Hierarchy of compliance guidelines and directives (illustration)

Lenzing’s internal rules and principles

Besides the Lenzing Global Code of Business Conduct, there are additional internal rules and principles of conduct (known as directives) that help to ensure that daily actions are in line with the applicable legal frameworks and Lenzing’s demand for integrity from each individual employee. Directives define rules of conduct that are binding for all employees of the Lenzing Group. Classifying a document as a directive always implicates the decision that non-conformance with the content of the directive may incur penalties and, in the worst case, termination of employment. Important directives include, amongst others, the Anti-Bribery and Corruption Directive, the Antitrust Directive, the Whistleblower Directive, the Issuer Compliance Directive, the Anti Money Laundering Directive and the Know-How Protection Directive.

Lenzing Global Supplier Code of Conduct

All of the Lenzing Group’s suppliers must comply with the Lenzing Global Supplier Code of Conduct. Wood and pulp suppliers additionally comply with its Wood and Pulp Policy. In this policy Lenzing gives preference to suppliers compliant with FSC® or PEFC standards. Lenzing expects its suppliers to conduct all operations with respect to health and safety at work, labor and human rights, environmental protection, ethics and management practices. To ensure compliance with this Code, suppliers are required to allow Lenzing and/or any of its representatives to have access to all their facilities and to all relevant records upon advance notice, and to carry out assessments through supplier assessment tools.

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