Code of Conduct

Foreword
As a leading global manufacturer, K2 Systems (“K2”) develops and markets high-quality mounting systems for solar technology. Highly standardised mounting system solutions make it possible to tap into the enormous potential for rooftop PV systems through simple, safe and cost-effective mounting solutions. In conjunction with our digital services, we make it even easier for our customers to install an increasing number of PV systems. The values we live by form the basis for K2’s success. This Code of Conduct serves as our guide in our day-to-day work and sets out the values, principles and behaviours to which all K2 Systems employees worldwide are committed and which they confirm by signing this document. In this way, we create a working environment characterised by integrity, respect and fair and responsible behaviour. A breach of this policy may result in disciplinary action under employment law, such as a warning, a formal notice or dismissal. We expect the same behaviour from our business partners.

1. Compliance with applicable law
We comply with applicable law and internal company regulations. We adhere to all relevant laws, regulations and guidelines in the countries in which we operate. We document all processes fully, accurately and in a traceable manner, and do not tolerate false or misleading records. Where permitted by law, we disclose information transparently, truthfully and in accordance with legal requirements. Our shared aim is to take responsibility for our company and to protect our brand’s reputation. Breaches of applicable law and the rules of conduct set out in this Code of Conduct will not be tolerated and will be subject to appropriate sanctions. We undertake to familiarise ourselves with and comply with the regulations applicable within our area of responsibility. The same applies to this Code of Conduct. In the event of any uncertainty, we shall consult the designated contact persons within the company or our line managers. Where necessary, we shall seek advice from external experts.

2. Fair Competition and Competition Law
In our day-to-day business activities, we act in the spirit of free and fair competition and comply with applicable competition and antitrust law, which prohibits agreements or conduct that unduly restrict trade or competition. In discussions or other contacts with competitors, we avoid topics that are relevant to competition between us. These include, in particular, agreements on offers, prices, pricing, business planning, sales quotas and market shares. This also applies to informal exchanges. We do not make any statements that could lead to concerted practices and we act with integrity.

3. Conflicts of interest
We strictly separate business and private interests. Our business conduct is guided exclusively by the interests of the company. Secondary employment requires the prior written consent of senior management as the responsible body. Consent will not be refused without good cause. If conflicts of interest cannot be avoided, we inform our line manager or the Human Resources department in order to find a fair and transparent solution.

4. International Trade and Services
We comply with the regulations governing cross-border trade. The legal requirements relating to our trade products and services in international commercial transactions are binding on us. Accordingly, we observe existing import and export restrictions, economic sanctions, export control regulations and all national and international regulatory approval requirements.

In case of doubt, our customs officers should be consulted or external customs experts should be called upon.

5. Anti-corruption, bribery, fraud and the granting of unauthorised benefits
We only make payments to business partners, customers or other external third parties within the legally permissible framework. Before giving or accepting gifts, we take it upon ourselves to familiarise ourselves with the internal regulations. We do not accept any benefits from customers or other business partners that could compromise an objective and fair business decision, nor do we offer such benefits ourselves. We do not tolerate corruption, bribery or fraudulent behaviour. This applies to individuals, companies, public authorities and other institutions. Corruption, bribery and fraud are strictly prohibited. We report any indications of corruption, bribery or fraud immediately, without fear of reprisals, to the appropriate authorities – for example, to our line manager, the Legal Department or via our whistleblowing system. We also comply with the legal provisions against money laundering and the financing of terrorism. Through regular training for all employees, we promote a consistent understanding of compliant and responsible conduct.

6. Social Responsibility and Human Rights
We respect and observe human rights and comply with the laws and regulations applicable to us. We expressly adhere to the prohibition of child labour and forced labour. Everyone bears responsibility for upholding human rights and is called upon to comply with them at all times. In order to fulfil our social and corporate responsibilities, we expect our business partners to adhere to these values. Furthermore, we require that all parties also uphold the environmental and social practices applicable to them.

7. Sustainable Procurement
We place great importance on social, fair and environmental criteria in our business operations. As a global company, we work with a wide range of suppliers and service providers. We select them carefully on the basis of objective criteria. We work continuously with our suppliers to further develop our supply chain and monitor this through an annual supplier assessment covering topics such as quality and sustainability, as well as relevant key performance indicators. Responsibility for implementing and further developing our sustainable procurement principles lies with our procurement department. Our sustainable procurement strategy focuses on measuring and minimising CO₂ emissions at product level, adhering to ethical standards, and working with suppliers who are predominantly based in Europe, thereby helping to reduce transport distances.

8. Equal Opportunities and Equal Treatment
Diversity is something we take for granted and which enriches our company. Equal treatment forms the basis for the fair, unbiased and open interactions we foster with one another and with our customers and business partners. We do not discriminate against anyone and do not tolerate discrimination on the grounds of gender, skin colour, ethnic origin, age, disability, sexual identity, religion, belief or any other personal characteristics. Responsibility for compliance, in particular with the AGG (General Equal Treatment Act), lies with the Human Resources department and senior management, who are also available as points of contact at any time. In the event of complaints, our whistleblowing system may also be used.

9. Fair working conditions
We comply with employment legislation and relevant regulations and attach great importance to fair working conditions. This includes compliance with applicable working time regulations as well as appropriate remuneration.

The desire for further training or professional development is expressly encouraged and supported. The relevant Human Resources department can be contacted at any time regarding this.

10. Safety, Health and Safety at Work, Health Protection
We comply with health and safety regulations and take our own health and safety, as well as that of our colleagues, very seriously. Within the scope of our powers and capabilities, we take all appropriate measures to minimise risks, prevent health problems and accidents, and ensure safe working practices. Our Human Resources department and our Facility Management team are responsible for this, as well as for monitoring the established control mechanisms, such as regular training sessions. Our aim is to promote the health, productivity and job satisfaction of everyone. Furthermore, we enhance safety when handling our products by offering practical product training on occupational safety and correct installation for customers and installers. Our products are designed and manufactured to be safe when used as intended.

11. Environmental and Climate Protection
As a company operating in the renewable energy sector, we are mindful of our responsibility towards the environment. We take responsibility for the environmental sustainability of our products, sites and services, and ensure the careful use of natural resources, a continuous reduction in our environmental impact, and compliance with environmental protection laws and regulations. When developing our products, we focus on resource efficiency, optimised use of materials and the durability of the materials employed. Thanks to the easy-to-install system components and the materials used in our products, it is possible to recycle materials appropriately at the end of the product’s long life cycle. To minimise greenhouse gas emissions, we meet our electricity needs using renewable energy sources, identify potential savings and strive to continuously reduce consumption. Similarly, we ensure the economical use of water and avoid air pollutants, noise emissions, waste and negative impacts on biodiversity at our sites. We sort and dispose of any waste generated in accordance with best practice. In addition, we measure and monitor resource consumption and waste generation. The Sustainability Department has overall responsibility for environmental and climate protection and is supported by the relevant specialist departments in individual sub-areas. We encourage and rely on the personal responsibility of every individual employee to play their part in the company’s environmental protection efforts.

12. Confidentiality and Plagiarism
Our expertise forms the basis of our commercial success and is either confidential or legally protected. We recognise the value of our company’s proprietary knowledge, handle all company information with care, never disclose it without authorisation, and undertake to maintain confidentiality regarding all trade and business secrets. We safeguard the confidentiality of sensitive information belonging to our customers, business partners and other third parties in equal measure. Plagiarism, unauthorised use, disclosure or reproduction of protected content is prohibited.

13. Data Protection and Information Security
Respect for personal rights and the protection of privacy include the protection of personal data. We process personal data relating to employees, customers, suppliers and other third parties in accordance with legal requirements, thereby ensuring confidentiality and traceability when handling information requiring protection. In cases of doubt or where anything is unclear, we consult the body responsible for data protection. In this way, we ensure compliance with the applicable data protection regulations.

Date: July 2026