SUNGALLON and its subsidiaries (“SUNGALLON”) conducts its global business in compliance with all applicable national and supranational laws and regulations as well as applicable international conventions, and it prevents violations of law. SUNGALLON undertakes to act upon the highest ethical standards and treat others with respect and integrity in accordance with the principles of this Code of Conduct，and comply with ISO 9001 and ISO 14001.

This Code of Conduct applies to all suppliers, customers and other business partners of SUNGALLON (hereinafter referred to as “business partners”) as well as their management boards, employees and subcontractors. They are encouraged to also comply with this Code of Conduct and the related principles.

SUNGALLON reserves the right to update the Code of Conduct if necessary and expects its business partners to accept such amendments.

CORRUPTION AND BRIBERY

SUNGALLON and its business partners including managing boards, employees and subcontractors act in accordance with applicable laws in relation to criminal and administrative offenses. In particular, acts of corruption and bribery in dealing with the public sector are punishable by law and/or subject to fines.

Management, employees or subcontractors must not demand, allow themselves to be promised or accept any benefits for themselves or for third parties in return for providing improper advantages or promising to provide such advantages in the future (receiving a bribe). Conversely, the offer, promise or granting of any such improper benefit (bribing) is not permitted either. The latter applies especiallywhen dealing with public officials and persons entrusted with special public service functions in view of their official function but also when dealing with private persons, unless they have a legally effective permission from their relevant superior.

It is permitted to grant and accept benefits that are customary and socially appropriate with regard to the respective business relationship. Such benefits must usually not exceed a value of ¥ 350.00. If benefits above this amount are to be granted or received, approval from the relevant compliance officer and/or management board must be obtained in advance. Approval can only be granted if the benefit is not related to giving preferential treatment.

ANTITRUST LAW

Competition and the free-market economy are essential elements of a free society. Their protection is in the interests of SUNGALLON and its business partners. Management board, employees and subcontractors must also comply with the applicable European and international competition and antitrust laws. In particular, the following is not permitted:

Exchanging non-public sensitive market information, such as turnovers, prices, strategies,

customer data or market shares between competitors

Partitioning of markets, particularly allocating customers and sales territories to each other

Non-solicitation and exclusivity obligations, unless they are exempted from antitrust regulations

Price maintenance obligations that oblige the customer to resell at minimum or fixed prices

Abuse of a dominant market position

Bid rigging in public and private bidding procedures

LABOR AND HUMAN RIGHTS

SUNGALLON and its business partners comply with the UN Universal Declaration of Human Rights as well as the ILO Declaration on Fundamental Principles and Rights at Work (core labor standards) as well as the requirements of Section 2 Subsection 2 Nos. 1–12 of the Supply Chain Due Diligence Act. We expect our business partners to protect international human rights, not commit any human rights violations and not to be complicit in any human rights violations. Forced labor, including prison labor, compulsory labor and child labor are strictly prohibited. Unless the relevant national laws require a higher age limit, no children of school age or children younger than 15 years of age may be employed. Wages and other benefits may not fall below the statutory minimum salary. Employees’ rights to freedom of association and wage negotiations must be respected.

ENVIRONMENTAL AND CLIMATE PROTECTION

SUNGALLON and its business partners seek to conduct their business activities in an ecologically sustainable manner and comply with all applicable laws and regulations for the protection of the environment. When selecting new business partners and raw materials, developing new products, operating production facilities, in packaging, transport and logistics as well as throughout the product life cycle (cradle-to-grave), attention is paid to keep any resulting impact on society, environment and climate as low as possible. All employees are therefore obliged to protect soil, water, air, biological diversity and cultural assets. Environmental damage must be avoided by using appropriate environmental protection measures consistent with the applicable laws. Resources must not be wasted. An environmental management system in line with ISO 14001 or a comparable system shall be put into force and a climate strategy shall be developed.

COMPLIANCE WITH HEALTH AND SAFETY REGULATIONS

SUNGALLON’s staff members and business partners are obliged to always ensure a safe and healthy workplace. They must always strictly comply with occupational safety and health regulations. Appropriate strategies, preventive measures and checks must be in place for the occupational health and safety of employees. We also expect these regulations to be complied with within the supply chain.

EQUAL OPPORTUNITY, ANTI-DISCRIMINATION AND RESPECTFUL CONDUCT

All SUNGALLON employees and business partners treat other people, especially those with different origins and experience, with respect and integrity. Discrimination based on ethnic origin, gender, religion, world view, age, sexual or political orientation as well on any kind of disability will not be tolerated. SUNGALLON and its business partners stand for an open-minded, upright and tolerant company culture and are committed to the protection of human rights. Employees must not be subjected to physical, mental, sexual or verbal harassment or assault.

Any violation of this Code shall be reported to SUNGALLON. Reports can be made directly to the responsible contact person at SUNGALLON: Violations of this Code can also be reported via our company-internal reporting channel for whistleblowers. Our business partners shall also provide a contact person to report violations. SUNGALLON reserves the right to terminate business relations with suppliers which directly or indirectly commit material violations of this Code