Scope Application WALTER

Code of Conduct WALTER GROUP | Business Partners CoC Business Partners | October 2025 Page 2 of 10 The WALTER GROUP, through its affiliated companies, conducts business across Europe and worldwide in various sectors. It is a fundamental corporate principle of the WALTER GROUP to ensure that all entrepreneurial activities are carried out in accordance with ethical values and with social as well as economic responsibility. We require every business partner to adhere to the values of the WALTER GROUP and to comply with its Code of Conduct. Furthermore, the WALTER GROUP expressly commits itself to internationally recognised standards, including the Universal Declaration of Hum an Rights (UDHR) of the United Nations, the Core Labour Standards of the International Labour Organization (ILO), the principles of the UN Global Compact and the OECD Guidelines for Multinational Enterprises. These frameworks form the foundation of our Code of Conduct and guide our daily business practices. 1. Scope of Application This Code of Conduct sets out the binding minimum requirements for every business partner of the WALTER GROUP with regard to social and environmental aspects in particular, human rights, working conditions, environmental protection and ethical business conduct. For the purposes of this Code of Conduct, a business partner shall mean any company, organisation or individual who, outside an employment relationship, is in a contractual or de facto business relationship with the WALTER GROUP or any of its affiliated companies. This includes, in particular, suppliers, subcontractors, consultants and other service provi ders (hereinafter collectively referred to as Business Partner). Acceptance of this Code constitutes a binding foundation and an integral part of every business relationship with the WALTER GROUP. Should a Business Partner engage other business partners, subcontractors or service providers, the Business Partner undertak es to pass on the principles of this Code and to ensure that the requirements are upheld throughout the entire value chain. In line with the Corporate Sustainability Due Diligence Directive (CSDDD), this obligation specifically includes the duty to implement appropriate and risk- based control and monitoring measures, to identify, prevent or bring to an end adverse impacts and to report on their implementation. Any breach of this Code of Conduct may ultimately entitle the WALTER GROUP to terminate the business relationship, including all related contracts.