Implementation Requirements particular

Code of Conduct WALTER GROUP | Business Partners CoC Business Partners | October 2025 Page 9 of 10 In particular, the offering, promising, granting, soliciting, accepting or obtaining of money, gifts, invitations or any other benefits of any kind that are intended to, or could appear to, improperly influence a business decision or obtain an unlawful advantage is prohibited. This prohibition applies regardless of whether public officials, business partners or other third parties are involved. The Business Partner is required to implement effective procedures and internal controls to ensure and demonstrate compliance with these standards at all times. 4.5 Import and Export Controls The Business Partner shall ensure strict compliance with all relevant laws governing the import and export of goods, services and information. Applicable sanctions and embargo lists must likewise be observed. The Business Partner shall further ensure that all taxes, duties and licence fees levied in connection with the extraction, trade and export of minerals from conflict - affected and high -risk areas are duly paid in accordance with applicable legal requirements. 4.6 Insider Information and Confidential Data In the event that the Business Partner gains access, in the course of cooperation, to confidential or non- public information, it is required to treat such information as strictly confidential. Such information must neither be disclosed, directly or indirectly, nor used for its own benefit or that of third parties. This applies in particular to information which if relevant to financial or capital markets could qualify as insider information within the meaning of applicable market abuse regulations. Any misuse or unauthorised disclosure of confidential information constitutes a serious breach of this Code of Conduct. 5. Implementation of Requirements The Business Partner is expected to systematically identify and assess risks throughout its supply chain and to implement appropriate preventive and remedial measures. The Business Partner is required to regularly review its procedures and to report to the WALTER GROUP upon request or at agreed intervals. If there is any suspicion or indication of potential or actual violations directly or indirectly affecting the business relationship with the WALTER GROUP, such suspicion must be reported to the WALTER GROUP immediately and without delay even if the fact s have not yet been fully clarified. Furthermore, the Business Partner is obliged to regularly and transparently inform the WALTER GROUP of risks and the measures taken to mitigate them. Compliance with the standards set out in this document may be verified by means of self -assessments as well as risk- based audits. The Business Partner agrees that the WALTER GROUP may, at its own expense, conduct such audits at the Business Partners opera ting sites either itself or through appointed external auditors. Such audits shall be carried out during regular business hours and with reasonable prior notice. An objection shall only be permissible where mandatory legal provisions prohibit such audits.