Code of conduct for business partners

HEGELMANN TRANSPORTE UAB

PURPOSE
This code of conduct describes the requirements and basic principles of UAB Hegelmann Transporte (hereinafter referred to as Hegelmann Transporte) for our business partners in compliance with applicable laws and other legal acts, in particular those relating to: basic working conditions, human rights, environmental protection and business transparency.
The term business partners refers to any company or person that conducts joint activities with Hegelmann Transporte, for example, organizations that supply goods and/or services to Hegelmann Transporte.
BASIC PRINCIPLES
Code of Conduct is based on internationally proclaimed human rights, including the International Bill of Human Rights, the eight core conventions of the International Labor Organization and Article 32 of the UN Convention on the rights of the Child. In addition to this, Hegelmann Transporte also supports the United Nations Global Compact initiative which is a strategic policy initiative for businesses that are committed to aligning with ten universally accepted principles for human rights, labor, environment and anti-corruption.

OUR EXPECTATIONS FOR BUSINESS PARTNERS
At Hegelmann Transporte, we conduct business responsibly wherever we operate, and we expect the same from business partners. We require our business partners not only to familiarize their employees with this Code of conduct, but also to ensure that their employees adhere to them. In this way, we aim to ensure that everyone involved with Hegelmann Transporte activities is honest, responsible and trustworthy.
You and your employees, as our business partners, must always comply with this Code of Conduct or similar principles, all applicable laws and regulations and, of course, your contractual obligations towards Hegelmann Transporte. If stricter laws apply to a matter covered by this Code of Conduct or stricter contractual obligations are assumed towards Hegelmann Transporte, the stricter regulation shall prevail.
We expect all our partners to follow these requirements professionally and systematically.

ENVIRONMENTAL PROTECTION
We expect our business partners to, like us, continuously strive to reduce the environmental impact of their activities, including the handling of raw materials. We also expect our business partners to act sustainably, responsibly and prudently. By this we mean that precautionary measures should be taken when there is reason to believe that a certain action may have a negative impact on human health, society or the environment. Our business partners must ensure that they comply with all applicable environmental requirements set out in laws and other regulations.

WORKING CONDITIONS AND HUMAN RIGHTS
We firmly believe that employees are the most important resource of the company, therefore we require our business partners to respect and adhere to internationally proclaimed human rights principles:
Child labor
Business partners must prevent any form of child labor. Under no circumstances may employment be offered to anyone under the age of 16 (or 14, even if national law permits it) or under the minimum age set by national law if they are over 16).
Employment conditions
Our business partners must ensure that the working conditions of their employees comply with all applicable legal requirements. In addition, every employee should have the right to receive written information about their working conditions in a language they understand.
Working hours
Working hours of business partners, including but not limited to overtime and rest time requirements, must always comply with applicable laws. Hegelmann Transporte is guided by Regulation (EC) No. 561/2006 of the European Parliament and of the Council of 15 March 2006 and we require our business partners to comply with the relevant standards for working and rest time.
Health and safety
A safe working environment must always be considered a key factor in all decision-making processes. We expect our business partners to ensure and maintain safe and healthy working conditions that meet — and preferably exceed — all applicable legal and regulatory standards
Forced labor
No form of forced labor shall be tolerated in connection with services provided to Hegelmann Transporte. Our business partners are strictly prohibited from engaging in or benefiting from any form of forced labor, including but not limited to debt bondage, human trafficking, or other manifestations of modern slavery.
Salary and benefits
Our business partners shall provide wages and benefits that meet or exceed the minimum standards required by applicable laws or, where relevant, by collective bargaining agreements. All employees must be personally informed about their wages and benefits in a manner consistent with applicable legal requirements.
Freedom of association
Business partners shall respect the rights of their employees to lawfully form, join, or refrain from joining associations, including employer-employee associations and trade unions, and to engage in collective bargaining, where permitted by applicable local law. We encourage our business partners to ensure that employees have the opportunity to communicate with management regarding their working conditions without fear of retaliation, intimidation, or harassment.
Non-discrimination and equal opportunities
Our business partners shall not discriminate against employees based on gender, race, ethnicity, religion, age, disability, sexual orientation, nationality, political opinion, union membership, social status, or any other characteristic protected by applicable law. They must treat all employees with respect, dignity, and fairness at all times.

BUSINESS TRANSPARENCY
We expect our business partners to conduct their operations in a transparent, ethical, and fair manner at all times.
Anti-corruption
None of our business partners or their employees shall engage in or tolerate any form of bribery or corruption. As a business partner of Hegelmann Transporte, you shall not offer, promise, give, or accept any benefit to or from any third party — including Hegelmann Transporte — with the intention of obtaining or retaining business or securing an improper advantage.
Improper benefits may include, but are not limited to: monetary gifts, cash loans, leisure trips or vacations, luxury items, hidden commissions, preferential payments, or other forms of undue advantage.
We also expect our business partners to ensure that all reports, records, and invoices are accurate, complete, and free from false or misleading information.
Conflict of interest
We expect our business partners to promptly disclose any situation that may give rise to a conflict of interest in connection with Hegelmann Transporte. Similarly, we expect any employee or other representative of Hegelmann Transporte to disclose any affiliation with, or financial interest in, any of our business partners.
Export Control and Sanctions
Hegelmann Transporte is committed to fully complying with all applicable export control laws and regulations, including sanctions principles, and to adhering to international economic sanctions requirements as implemented in the jurisdictions where the Company operates. We expect the same level of compliance from our business partners.
Fair competition
Our business partners must support fair business practices and comply with all applicable laws related to fair trade, advertising, competition, and antitrust. We expect our partners to engage in fair competition and to refrain from entering into any agreements or arrangements that could restrict or distort competition.
Specifically, business partners shall not engage in any conduct with competitors that involves price fixing, setting discounts or terms of sale, or allocating markets, market shares, customers, or territories.
Business partners must also avoid undermining competition by disclosing or exchanging confidential or non-public information. Sensitive information includes, but is not limited to: prices, timing or amount of price changes, costs, profit margins, sales forecasts, sales plans, sales territories, distribution practices, terms offered to specific customers, capacity utilization, strategic intentions, competitive bidding strategies, pricing or marketing plans, product plans, and market shares.
These obligations apply equally when participating in trade fairs, industry meetings, or events organized by trade associations.
Protection of personal data, confidential information and intellectual property
Business partners must respect the Company’s intellectual property rights and ensure the protection of confidential information and personal data against unauthorized access, misuse, theft, fraud, or improper disclosure.
These obligations must be fulfilled at a level no less stringent than that required by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 — the General Data Protection Regulation (GDPR) — concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data.

Disclosure and protection from harassment
Business partners should implement complaint and whistleblowing procedures that cover both internal practices and interactions with external suppliers. Investigating supplier-related issues helps ensure that behavioral standards and legal requirements are upheld throughout the supply chain. Protection against retaliation is a critical part of any whistleblowing procedure. It is essential to ensure that individuals who report unethical or illegal activities do not suffer negative consequences as a result of their actions.

BREACHES OF THE CODE
We reserve the right to audit business partners who supply goods or services to Hegelmann Transporte at any time, with prior written notice. Upon request, our business partners are required to provide all necessary information and/or grant us or our representatives access to their premises for audit purposes. Additionally, we reserve the right to appoint an independent third party of our choosing to conduct the audit, ensuring compliance with this Code of Conduct. Failure to cooperate and/or violations of our Code of Conduct and/or applicable laws may result in a reduction of the scope of cooperation and/or termination of the partnership with Hegelmann Transporte.

INFORMATION DISSEMINATION
At Hegelmann Transporte, we encourage our business partners to ask questions and report any ethical concerns or instances of non-compliance with strive to prevent all forms All reported issues will be thoroughly assessed and investigated. If you wish to report a violation of our Code of Conduct, please feel free to contact us through any communication method that is most convenient for you.

All Hegelmann Transporte business partners must comply with the Code throughout the duration of cooperation.

Date: 15-05-2025