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 we can only be the best partner for our customers in the rapidly transforming industrial production sector if we put precision first in every aspect of our thoughts and actions. And that is exactly what we do – because it is in our genes.

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.

We expect ourselves as management, our managers and our employees to act with integrity when making decisions and to conduct our business in accordance with national and international laws as well as generally recognized ethical principles. And we expect the same of 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 & Joachim Dittrich

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

Managers at LMT Tools (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 regulations (including internal company guidelines) is an essential basis for all actions within the LMT Tools Group. It is made clear that this Code of Conduct cannot cover all laws and regulations

It should be noted that this Code of Conduct cannot cover all laws and regulations that the bodies and employees of the LMT Tools Group worldwide are required to comply with. However, it sets out the essential principles for responsible and lawful conduct by the LMT Tools Group, including its employees and bodies.

The Code of Conduct is supplemented by internal company guidelines and training courses for individual areas of law, such as anti-corruption, antitrust prevention and the avoidance of conflicts of interest.

3. Fair competition

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

The company bases its competitive strategy exclusively on performance, customer focus and the quality of its products and services. Price or condition agreements with competitors are therefore prohibited, as are agreements with competitors for the purpose of market or customer sharing. It is made clear that agreements that are inadmissible under antitrust law may not be replaced by concerted practices 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 domestic and international business transactions and has established detailed rules of conduct in its Anti-Corruption Policy. This applies both to relations with public officials and to relations with bodies and employees of other companies. In connection with the activities of the LMT Tools Group at home and abroad, neither the bodies and employees of other companies nor public officials may be promised or granted any personal advantages in return for preferential treatment.

The employees and bodies of the LMT Tools Group are not corruptible and do not derive any profit from their activities apart from the remuneration paid to them by the company. They therefore do not offer any gifts or invitations outside the guidelines and value limits specified in the LMT Tools Group's Anti-Corruption Policy Group's Anti-Corruption Policy. They also refrain from granting such benefits to competitors, consultants, customers, suppliers, service providers and other business partners of the LMT Tools Group.

5. Conflicts of interest

It is the contractual obligation of all organs and employees of the LMT Tools Group to avoid conflicts of interest between their private interests (direct or indirect, or through related persons or companies) and the interests of the LMT Tools Group as far as possible.

Avoiding conflicts of interest also requires that the bodies and employees of the LMT Tools Group avoid even the appearance of favouritism in their business dealings with competitors, consultants, customers, suppliers, service providers and other business partners of the LMT Tools Group on the basis of personal proximity to any of the aforementioned groups of persons.

Examples of conflicts of interest include the private exploitation of business opportunities, property or employees of the company, or taking on secondary employment that is not in the interests of the LMT Tools Group (e.g. consulting for a competitor).

If conflict situations cannot be avoided in individual cases, they must be made transparent and resolved in compliance with the law and internal company guidelines.

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

6. International trade and due diligence in the supply chain

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

In addition, the LMT Tools Group takes the utmost care to ensure that international supply chains also comply with human rights and environmental due diligence Further details are set out in the LMT Tools Group's "Policy Statement on the Protection of Human Rights‘ and ’Supplier Code of Conduct", which all suppliers are required to comply with.

7. Human rights, working conditions and social responsibility

The LMT Tools Group is unreservedly committed to upholding and complying with internationally recognised human rights.

The commercial 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 within the framework of its business activities.

It is in the company's interest that fair working conditions apply throughout the LMT Tools Group worldwide. The LMT Tools Group considers it its duty to treat its employees with respect and fairness. This includes, in particular, compliance with all applicable occupational health and safety regulations to ensure the safety of employees in the workplace.

Violations of legal requirements and all unsafe conditions, such as blocked escape routes, missing fire extinguishers, accumulations of combustible material, visible damage to buildings, 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 and emergency measures, as well as emergency evacuation procedures in the event of an accident, and are trained in fire safety measures and rules of conduct in the event of a fire. Notices, the functionality of fire alarm systems and fire extinguishers, and regular fire drills are checked by the fire safety officers.

Potential emergency situations and events must be identified and assessed. Their impact must be minimised by introducing emergency plans and reporting procedures. These include emergency reporting, evacuation notifications, training and emergency drills, appropriate fire alarm and extinguishing equipment, clearly marked unobstructed exits and escape routes, and comprehensive rescue plans. The aim of these management measures is to minimise damage to life, the environment and property.

Further details can be found in the LMT Tools Group's occupational health and safety policy in its currently valid version.

The requirement for 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 colour, religion or other personal characteristics.

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

The LMT Tools Group recognises the right to freedom of association and collective bargaining. The company promotes cooperation with works councils and undertakes not to discriminate against or disadvantage employees on the basis of their membership of 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 managers to treat each other with respect in verbal and written communication, especially in meetings and emails. In addition to respecting the social customs of a country, this includes unconditional respect for the personal integrity of others and refraining from personal insults, disparagement or sexual harassment. Such behaviour will not be tolerated and will result in consequences under labour law.

8. Financial integrity and reporting

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

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

For the LMT Tools Group, honest and transparent reporting is also essential between companies within the LMT Tools Group. All bodies and employees of the LMT Tools Group are therefore obliged to report conscientiously, completely, loyally and in a timely manner within the LMT Tools Group.

Bodies 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 business and social contexts.

9. Sustainability and product safety

The LMT Tools Group constantly strives to develop innovative and high-quality products and processes for its customers. Product safety is always a top priority. At the same time, the LMT Tools Group also supports its customers in their sustainable production, e.g. through efficiency improvements in material and resource consumption.

The LMT Tools Group pays equal attention to sustainability in both the development and manufacture of its products.

Protecting the environment and climate, as well as resource efficiency, is of great importance to the LMT Tools Group. As part of its business activities, the LMT Tools Group pays attention to protecting the environment and natural resources. Every employee is responsible for treating natural resources with care and contributing to the protection of the environment and climate through their individual behaviour.

Companies in the LMT Tools Group always attach great importance to avoiding or reducing environmental impact by reducing energy and water consumption, emissions and waste. In doing so, the company relies on the use of eco-efficient technologies and materials for environmental protection, economy and reusability.

Sustainable management and environmentally conscious behaviour by managers and employees are encouraged.

The requirements of REACH, RoHS and conflict minerals are complied with. The selection of chemicals and other hazardous substances is carried out responsibly, taking into account environmental and climate protection aspects. The use of prohibited chemicals is strictly prohibited. Nevertheless, we are constantly looking for ways to further reduce the use of chemicals and hazardous substances in the production process. Chemicals or other materials that pose a risk when released into the environment must be identified and handled in such a way that their handling, transport, storage, use or reuse and disposal are carried out safely.

Details can be found in the current version of the LMT Tools Group's environmental policy.

10. Trade and business secrets

The knowledge and information acquired within the LMT Tools Group are an essential element of its business success. The LMT Tools Group invests considerable human and financial resources in the development of innovative products and services. Protecting the innovations developed in this way ensures the LMT Tools Group's success in the competitive arena.

All employees and bodies of the LMT Tools Group are obliged to prevent knowledge and information that constitutes trade or business secrets of the company from becoming known outside the LMT Tools Group, e.g. through the unauthorised dissemination 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 find out to what extent the acquisition of industrial property rights for this knowledge and information is possible.

To the same extent, trade or business secrets of LMT Tools Group's business partners must also be protected against unauthorised disclosure.

11. Data protection and communication

The LMT Tools Group takes the utmost care when processing personal data belonging to 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 officer is sought.

The LMT Tools Group is committed to the security of all IT systems, including by providing information and training to employees 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.

The right to freedom of expression and the protection of personal rights and privacy of employees are respected. However, every employee should be aware that they may be perceived as part of and representative of the company, even in their private lives. All employees are therefore required to maintain the reputation and image of LMT Tools Group through their behaviour and conduct in public.

No confidential or sensitive company information is therefore communicated on social networks.

12. Compliance management and internal reporting office

As part of its compliance management, the LMT Tools Group actively promotes communication of the rules set out in this Code of Conduct. Managers have a special role model function and are the first point of contact for questions regarding the understanding of the regulations. As part of their management responsibilities, they prevent unacceptable behaviour and take appropriate measures to prevent violations of the rules within their area of responsibility.

Employees can also contact the responsible compliance officer of the respective company within the LMT Tools Group if they have any questions about this Code of Conduct. Violations of this Code of Conduct, legal regulations or internal company guidelines can have far-reaching consequences. In addition to financial consequences and a loss of trust, violations can also have consequences under labour law for the employee concerned.

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

The LMT Tools Group expressly encourages all employees to address issues and problems openly.

Employees who raise concerns in good faith about company matters will not suffer any disadvantages. If they so wish, their identity as whistleblowers will be protected and not disclosed. Employees who raise concerns in good faith about company processes will therefore not suffer any disadvantages. If they wish, their identity as whistleblowers will be protected and not disclosed.

Tips can also be submitted anonymously via ‘Speak Up’. These anonymous tips 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 can of course also be submitted to the management of the affected company within the LMT Tools Group and to the responsible compliance officer.

Schwarzenbek, 2 October 2025

Management Board of LMT Tools GmbH & Co. KG