Foreword by the Management Board

At LMT Tools Group, we are a partner and provider of solutions for our customers in the development and manufacture of special tools. With our tools and customized solutions, we want to make our contribution to the success of our customers.

We understand that, in the rapidly evolving world of industrial production, we can only be the best partners for our customers if we prioritize precision in every aspect of our thinking and actions. That is exactly what we do—because this is our understanding of progress, social responsibility, and trust built on partnership.

An outstanding customer experience is at the heart of LMT Tools. Reliability and fast action create an uncomplicated and trust-based business relationship between LMT Tools and our customers.

Shared values are the basis for our responsible actions. They shape the way we work together, respect each other, communicate, perform, pursue our goals, and assume management responsibility.

Our actions are based on the core values in the company: I care – I act – I trust.

In order to be successful together, the trust of our employees, customers, business partners and society in us as a company is a fundamental prerequisite.

We are very aware of this responsibility. Our Code of Conduct translates our values into standards and principles of behavior. They ensure compliance with standards and internal guidelines throughout the company, provide a clear orientation for us and our employees, and create a working environment characterized by integrity, respect, and fair and responsible conduct.

As the management, executives, and employees of LMT Tools, we are committed to ensuring that integrity guides our decisions and that our business is conducted in accordance with national and international laws as well as generally accepted ethical principles. We expect the same from our business partners.

Each individual at LMT Tools Group contributes with their behavior to ensuring that this trust is maintained and that we continue to stand for I care – I act – I trust in the future.

Management Board LMT Tools Group

Oliver Thomas & Carsten Storm

Scope and purpose

As an internationally active company, LMT Tools GmbH & Co. KG and its affiliated companies (hereinafter referred to as "LMT Tools Group”) are obliged to observe a wide range of social, political and legal conditions in Germany and abroad. Even supposedly minor violations of the law by employees and executive bodies can significantly damage the reputation of the company and cause it great damage, including of a financial nature.

This Code of Conduct describes the values, principles and practices that govern LMT Tools Group’s corporate behavior. Its main objective is to ensure compliance with standards and internal guidelines throughout the company and to create a working environment characterized by integrity, respect, and fair and responsible conduct. The Code of Conduct is also a pledge to the outside world for responsible, inclusive and environmentally-conscious behavior in general, toward business partners and the public.

It applies to all employees and bodies of LMT Tools Group worldwide. All employees bear responsibility.

1. Corporate guidelines/values at LMT Tools Group/ General management

At LMT Tools Group, we are committed to a shared set of values, which are reflected in our corporate guidelines.

The corporate guidelines are intended to guide and motivate the LMT Tools Group as a whole as well as its individual members. We make it clear what we stand for as a company and thus convey an idea of the corporate identity, goals and strategy of the company.

We are passionate about the interests of the LMT Tools Group and take responsibility for our decisions (‘Acting with passion and accountability’). We are willing to embrace change in order to continuously improve ("Willpower to drive change for continuous improvement").

We are open-minded towards others and strive for trustful collaboration at all times (‘Open minded to foster trustful collaboration’).

We strive for the best possible business performance while maintaining the corporate culture of the LMT Tools Group based on our values. (‘Committed to performance and a recognising culture’).

We place our customers and their satisfaction at the centre of our actions. We want our customers to perceive us as reliable, fair partners with high ethical standards. (Caring for our Customer Experience)....

... and always keep an eye on the environment around us (“… and our environment”).

We expect all employees to internalise these corporate guidelines and take them into account in their daily work. These corporate guidelines are also based on our core values within the company: I care – I act – I trust. We actively oppose any violations of our self-image as expressed therein or any other discrimination, harassment or derogatory behaviour by or towards employees.

ADDITIONAL RESPONSIBILITIES FOR MANAGERS

The Executive Team of the LMT Tools Group (managing directors, senior executives, etc.) have an additional obligation to promote a culture of integrity and compliance with legal requirements.

They should therefore serve as ambassadors and role models for ethical behaviour in all business relationships. Direct supervisors are generally the first point of contact for employees who have concerns or questions. Every manager in the company is expected to be familiar with the contents of the Code, to demonstrate exemplary behaviour on a daily basis, and to ensure that every employee is aware of the expectations placed on them employees.

At the same time, managers must ensure that colleagues reporting to them feel confident in raising issues and concerns without fear of retaliation; every complaint must be investigated professionally and promptly, and jeopardising LMT Tools' policies solely to achieve business results will not be tolerated.

2. Compliance with applicable laws and regulations

Compliance with all applicable laws and other legal regulations (including internal company policies) is an essential foundation for all activities within the LMT Tools Group.

It is made clear that this Code of Conduct cannot address all laws and regulations that the LMT Tools Group’s executive bodies and employees worldwide are required to comply with. However, it sets out the fundamental principles for responsible and legally compliant conduct by the LMT Tools Group, including its employees and executive bodies.

The Code of Conduct is supplemented by internal company guidelines covering specific legal areas, such as anti-corruption, antitrust compliance, and the avoidance of conflicts of interest, as well as training and information sessions on these topics.

3. Fair competition

The LMT Tools Group is fully committed to fair competition, compliance with antitrust and copyright laws, as well as all related legal regulations, and expects the same from its competitors, suppliers, customers, and other business partners.

In competition, the company relies exclusively on performance, customer focus, and the quality of its products and services. Agreements with competitors regarding prices or terms and conditions are therefore prohibited, as are agreements with competitors for the purpose of dividing up markets or customers. It is made clear that agreements prohibited under antitrust law may not be replaced by coordinated conduct with competitors or by coordination within associations.

The intellectual property of the LMT Tools Group must be protected; conversely, the intellectual property of third parties must be respected.

4. Avoiding corruption

The LMT Tools Group rejects corruption in business dealings both domestically and abroad and has established detailed rules of conduct in its own anti-corruption policy. This applies both in dealings with public officials and in dealings with the governing bodies and employees of other companies. In connection with the activities of the LMT Tools Group both domestically and abroad, no personal benefits may be promised or granted to the executive bodies and employees of other companies or to public officials in exchange for preferential treatment.

The employees and executive bodies of the LMT Tools Group are not corruptible and derive no profit from their activities—apart from the compensation paid by the company. They therefore do not accept gifts or invitations outside the guidelines and value limits set forth in the LMT Tools Group Anti-Corruption Policy that go beyond customary practices or constitute other direct or indirect grants of benefits. They also refrain from offering such benefits to competitors, consultants, customers, suppliers, service providers, and other business partners of the LMT Tools Group.

5. Conflicts of interest

It is a contractual obligation of all officers and employees of the LMT Tools Group to do their utmost to avoid conflicts of interest between their private interests (whether direct or indirect, or involving related persons or entities) and the interests of the LMT Tools Group.

Avoiding conflicts of interest also requires that the officers and employees of the LMT Tools Group, in their business dealings with competitors, consultants, customers, suppliers, service providers, and other business partners of the LMT Tools Group, avoid even the appearance of favoritism based on a personal relationship with any of the aforementioned groups of persons.

Examples of conflicts of interest include, among other things, the private exploitation of business opportunities, company property, or company personnel, or the undertaking of a secondary employment that is not in the interests of the LMT Tools Group (e.g., consulting work for a competitor).

If conflict situations cannot be avoided in individual cases, they must be disclosed transparently and resolved in compliance with the law and the company’s internal guidelines.

In any case, business decisions must always and exclusively be guided by the interests of the LMT Tools Group.

6. International trade and due diligence in the supply chain

The LMT Tools Group is bound to comply with and unreservedly acknowledges the legal regulations governing international trade that apply to its products and services. The companies of the LMT Tools Group therefore comply with all export or import prohibitions and regulatory licensing requirements under national or international law. From a German perspective, this applies in particular to the regulations governing the export of goods issued by the Federal Office for Economic Affairs and Export Control (BAFA). The LMT Tools Group is also a company in the secure supply chain for aviation security and complies with all relevant regulations as well as the necessary security provisions and measures.

Furthermore, the LMT Tools Group exercises the utmost care to uphold human rights and environmental due diligence obligations within the framework of international supply chains. Further details are set forth in the LMT Tools Group’s “Declaration of Principles on the Protection of Human Rights” and in the “Supplier Code of Conduct,” which all suppliers are required to observe.

7. Human rights, working conditions and social responsibility

The LMT Tools Group is fully committed to upholding and complying with internationally recognized human rights and the UN Convention on Human Rights.

The business success of the LMT Tools Group depends to a large extent on its employees. The company is therefore committed to the principles of social responsibility in the context of its business activities.

It is in the company’s best interest to ensure that fair working conditions are in place worldwide within the LMT Tools Group. The LMT Tools Group considers it its duty to treat its employees with respect and fairness. This entails, in particular, compliance with all applicable occupational safety regulations to ensure the safety of employees in the workplace.

Violations of legal requirements as well as any unsafe conditions, such as blocked escape routes, missing fire extinguishers, accumulations of flammable materials, visible building damage, etc., must be reported immediately to the responsible departments within the company. The fire safety officers at LMT Tools ensure that all employees are informed about escape routes, emergency procedures, and emergency evacuation measures in the event of an accident, and are trained in fire safety measures and rules of conduct in the event of a fire. Posters, the functionality of fire alarm systems and fire extinguishers, as well as regular fire drills, are checked by the fire safety officers.

Potential emergency situations and incidents must be identified and assessed. Their impacts must be minimized through the implementation of emergency plans and reporting procedures. This includes, among other things, reporting emergencies, notifications regarding evacuation measures, training and emergency drills, appropriate fire alarm and suppression systems, clearly marked, unobstructed exits and escape routes, as well as comprehensive rescue plans. The goal of these management measures is to minimize harm to life, the environment, and property.

Further details can be found in the LMT Tools Group’s Occupational Safety and Health Policy in its currently valid version.

The commitment to fair working conditions supports diversity and inclusion, ensures equal rights for all employees, and therefore prohibits any form of discrimination based on gender, sexual orientation, origin, skin color, religion, physical and mental disabilities, or other personal characteristics.

All forms of child labor, forced labor, and slavery are strictly prohibited.

The LMT Tools Group recognizes the right to freedom of association and collective bargaining. The company promotes cooperation with works councils and is committed to not discriminating against or disadvantaging employees on the basis of their membership in a works council. Furthermore, the company does not prevent works councils from contacting and interacting with the workforce.

The LMT Tools Group also expects its employees and supervisors to treat one another with respect in both verbal and written communication, particularly in meetings and emails. This includes, in addition to consideration for a country’s social customs, the unconditional respect for the personal integrity of others and the avoidance of personal insults, denigration, or sexual harassment. Such behavior will not be tolerated and will result in consequences under labor law as well as, if the conditions are met, further legal consequences.

8. Financial integrity and reporting

Business transactions and business records of companies within the LMT Tools Group must be complete, factually accurate, and in order. There is an obligation to record, document, and report all business transactions, assets, and liabilities to the authorities in accordance with legal requirements.

Documents relevant to financial accounting must not contain intentionally false or misleading entries. Any form of financial statement manipulation is strictly prohibited.

For the LMT Tools Group, honest and transparent reporting—including between companies within the LMT Tools Group—is indispensable. All governing bodies and employees of the LMT Tools Group are therefore obligated to provide conscientious, complete, loyal, and timely reporting within the LMT Tools Group.

Officers and employees of the LMT Tools Group who are required to report to third parties (e.g., auditors, authorities) must adhere to the same principles. This is essential for the credibility of the LMT Tools Group in both business and social contexts.

9. Sustainability and product safety

The LMT Tools Group is constantly striving to develop innovative, high-quality products and processes for its customers. Product safety is always the top priority. At the same time, the LMT Tools Group’s products also support customers in their sustainable production efforts, for example by improving efficiency in material and resource consumption.

To the same extent, the LMT Tools Group prioritizes sustainability in both the development and manufacturing of its products. This applies to material procurement as well as to the production process and logistics.

Protecting the environment and the climate, as well as resource efficiency, are of great importance to the LMT Tools Group. As part of its business activities, the LMT Tools Group takes into account all environmental concerns and the natural foundations of life. Every employee bears the responsibility to use natural resources sparingly and to contribute to the protection of the environment and climate through their individual behavior.

Companies within the LMT Tools Group consistently prioritize the avoidance or reduction of environmental impact by minimizing energy and water consumption, emissions, and waste. To this end, the company relies on the use of eco-efficient technologies and materials to promote environmental protection, resource conservation, and reusability.

Sustainable business practices and environmentally conscious behavior by managers and employees are encouraged.

We comply with the requirements of REACH, RoHS, and the Conflict Minerals Regulation. Chemicals and other hazardous substances are selected responsibly, taking environmental and climate protection into account. The use of prohibited chemicals is strictly prohibited. Nevertheless, we are constantly seeking ways to further reduce the use of chemicals and hazardous substances in the production process. Chemicals or other materials that pose a hazard when released into the environment must be identified and handled in such a way that their handling, transport, storage, use, reuse, and disposal are carried out safely.

Details can be found in the LMT Tools Group Environmental Policy in its currently valid version.

10. Trade and business secrets

The knowledge and information acquired within the LMT Tools Group are essential to its business success. The LMT Tools Group invests significant human and financial resources in the development of innovative products and services. Protecting these innovations ensures the LMT Tools Group’s competitive success.

All employees and officers of the LMT Tools Group are obligated to prevent knowledge and information—insofar as it constitutes trade or business secrets of the company—from becoming known outside the LMT Tools Group, e.g., through the unauthorized disclosure of confidential data and information in conversations with third parties or in trade journals. In addition, every employee dealing with such knowledge and information should inform themselves as to the extent to which obtaining industrial property rights for this knowledge and information is feasible.

To the same extent, trade or business secrets of the LMT Tools Group’s business partners must also be protected from unauthorized disclosure.

Violations of such statutory or contractual confidentiality obligations entail labor law consequences and, under certain circumstances, may also result in criminal liability.

11. Data protection and communication

The LMT Tools Group exercises the utmost care when processing the personal data of employees, customers, or other third parties and ensures compliance with applicable laws and regulations.

In cases of doubt, the advice of the company’s data protection officers is sought. The LMT Tools Group is committed to ensuring the highest possible security of all IT systems, including through employee education and training on these topics. In this way, the LMT Tools Group ensures the security of information with regard to confidentiality, integrity, and availability, as well as the protection of internal and external data. In the event of attacks on this security, appropriate procedures, emergency plans, and emergency systems are in place.

Through the Information Security Officer, the LMT Tools Group ensures that all international and national security standards are observed.

The right to freedom of expression, as well as the protection of employees’ personal rights and privacy, is respected. However, every employee should be aware that they may also be perceived as part of and a representative of the company in their private life. All employees are therefore required to uphold the reputation and standing of the LMT Tools Group through their behavior and conduct in public. Consequently, no confidential or sensitive company information is shared on social media.

12. Compliance management and internal reporting office

As part of its compliance management, the LMT Tools Group actively promotes communication of the rules set forth in this Code of Conduct.

Managers serve as role models and are the first point of contact for questions regarding the interpretation of these rules. As part of their managerial responsibilities, they prevent unacceptable behavior and take appropriate measures to prevent violations of the rules within their area of responsibility.

For questions regarding this Code of Conduct, employees may also contact the designated compliance officer of the relevant company within the LMT Tools Group.

Violations of this Code of Conduct, legal regulations, or internal company guidelines can have far-reaching consequences. In addition to financial repercussions and a loss of trust, violations may also result in labor law consequences for the employee involved or criminal prosecution.

The LMT Tools Group expressly encourages all employees to openly address issues and problems. Employees who, in good faith, raise concerns regarding company matters will therefore not face any disadvantages. If they so desire, their identity as a whistleblower will be protected and not disclosed.

Reports can also be submitted anonymously via “Speak Up.” These anonymous reports will also be investigated.

The following link can be used to submit reports; additional information about the relevant process can also be found there.

In addition, reports may of course also be submitted to the management of the relevant company within the LMT Tools Group or to the responsible compliance officer.

Schwarzenbek, March 1, 2026

Management Board of LMT Tools GmbH & Co. KG