BEESINESS CODE OF CONDUCT

INTRODUCTION

BEESINESS has adopted the following code of conduct. The company reserves the right to amend, delete or add any provision in this code as and when it deems necessary. All updates made to this code shall be brought to the attention of employees by way of e-mail prior to the effective date of the updates.

The company’s professionalism, honesty and integrity must at all times be upheld in the business dealings with the following parties as below:

• clients
• suppliers and contractors
• vendors
• government and regulators
• the whole business community
• among employees

How to raise an integrity concern:

Disclosures can be submitted in good faith through the following channels as below:

1. Via email: BEESINESS@BEESINESS.eu
2. Via mail:
   BEESINESS UG
   Gotzinger Str. 8
   81371 München
   Germany
   Please write on the envelope “Strictly Confidential.”
3. Via Online Form: Whistleblower Form

EUROPEAN SUSTAINABILITY REPORTING STANDARDS (ESRS)

The ESRS are reporting standards for sustainability within the EU. The objective of the European Sustainability Reporting Standards (ESRS) is to enhance both the breadth and excellence of corporate sustainability reporting, fostering transparent practices that contribute to sustainable development. The aim is to provide stakeholders, including investors, other businesses, and society at large, with improved insights into the operational conduct of companies. This goal is achieved through the implementation of various mechanisms.

BEESINESS is voluntarily committed to observe from its early beginning the ERSR and expects the vendors to read and get informed about it. In this way, the company can prepare to gather proper information to customers, banks, investors, or other stakeholders in the future, when requested.

We invite all involved business partners to read about it:

https://finance.ec.europa.eu/news/commission-adopts-european-sustainability-reporting-standards-2023-07-31_en

OBJECTIVE

This code has been developed with the purpose of:

• Certifying that our employees adhere to high standards of honesty and integrity. It serves as a guide for their conduct in the workplace while carrying out the daily responsibilities.
• Encouraging employees to actively participate in sustainability initiatives, including the promotion of our sustainable products to customers, the introduction of sustainable packaging, and the implementation of eco-friendly practices within BEESINESS.
• Instilling ethics across all areas, encompassing marketing research, e-commerce, direct marketing promotion, and advertising on social media or any other platform to meet customers' needs.

RESPONSIBILITY

This code applies to all employees, including those working on a full-time, part-time, fixed- term, permanent, and/or trainee basis and business partners, i.e. vendors.

Managers bear additional responsibilities to serve as role models, oversee, and guide the employees under their supervision in the consistent application of the code in their daily business practices.

BEESINESS INTERNAL CONDUCT

All employees must adhere to all applicable laws, treaties, rules, and local regulations.

In describing our products and their uses, employees must provide truthful, accurate, and transparent information, ensuring that customers have appropriate and sufficient details to understand the properties and uses of the products.

Environmental considerations must be paramount in all activities, particularly in areas such as in packaging and recycling.

Employees involved in creating advertising and promotional materials must ensure that the information presented is clear, unambiguous, accurate, and fair. It should not include false or misleading information about price, value, or service and should refrain from belittling other companies.

All employees managing the company's social media or other platforms representing the Company at a corporate level, utmost care must be taken to uphold the corporate image.

EXTERNAL CONDUCT

As a representative of BEESINESS, employees are expected to demonstrate respect towards all individuals, irrespective of their race, color, gender, language, religion, political or other opinions, national or social origin, physical or mental abilities, age, marital and family status, sexual orientation and gender identity, health status, economic and social situation.

It is imperative to refrain from sharing discriminatory, offensive, or libelous content and comments. Avoid posting or transmitting any messages, content, or links that are abusive, hateful, homophobic, discriminatory, malicious, aggressive, threatening, violent, sexist, harassing, inflammatory, indecent, tortious, defamatory, knowingly false, misleading, deceptive, vulgar, obscene, scandalous, sexually explicit, profane, offensive, or otherwise objectionable.

What to do in case of public negative comments:

1. Inform internally about the comment and define the course of action.
2. Reply with the CEO in copy, never reply or take any conversation in private.
3. Don’t ignore these comments. Find a way to improve and reply.

CODE OF ETHICS

Personal Data Protection

BEESINESS employees must comprehend the nature and classification of the information they handle, whether in paper format, electronic documents, or IT applications and systems. The company strictly adheres to the policy that any non-public information and personal data related to the company and customers must be safeguarded and treated with the utmost confidentiality by all employees.

Distribution or sharing of the company's or customer's information should only occur on a need-to-know basis. This ensures that only employees, authorized third parties, or others working for the company with a genuine business need have access to the information.

All employees are prohibited from sharing or using any company or customer information for personal benefit, either directly or indirectly.

In alignment with our values and applicable laws, and in respect for privacy as a human right, all employees are obliged to safeguard all information and data, as the company is committed to responsible, ethical, and fair data usage.

The collection, use, and other processing of personal data and corporate information must comply with privacy and information security laws and regulatory requirements.

Immediate reporting is required from all employees regarding events that could impact the security of the company's information. This includes instances such as clicking links or attachments in suspicious emails, inadvertently sharing confidential information with the wrong recipient, or any other relevant events.

Anti-Bribery and Anti-Corruption Obligation

All employees are strictly prohibited from offering, giving, soliciting, or accepting bribes from customers to gain business or personal advantages, or engaging in any transactions that could be interpreted as violating anti-corruption laws.

All employees should be aware that bribes can take various forms, including monetary considerations or unauthorized remuneration such as referral fees, commissions, material goods, services, gifts, business amenities, premiums, or discounts. These offerings should not have inappropriate values, exceed reasonable levels, or deviate from ethical and lawful business practices.

Before offering or accepting any business amenity or gift, all employees must evaluate the appropriateness of their actions. This assessment should consider whether the action could influence, or reasonably appear to influence, the business relationship between the Company and the organization or individual involved, or any resulting business decisions.

Compliance with bribery and corruption regulations, are based on Sections of the German Law against corruption as in Section 299 of the German Criminal Code (StGB) (https://www.gesetze-im-internet.de/englisch_stgb/englisch_stgb.html#p2783) and in dealings with public officials (Section 333 StGB) (https://www.gesetze-im-internet.de/englisch_stgb/englisch_stgb.html#p3286).

All employees are required to declare all gifts offered or received from customers or others through the e-mail to beesiness@beesiness.eu.

Human and Labor Rights

BEESINESS strongly advocates for human and labor rights. Regardless of their position in the value chain, every individual deserves respectful treatment and fair, secure working conditions(https://www.fairlabor.org/accountability/standards/manufacturing/mfg-principles/) . Consequently, our Business Partners are obligated to uphold fundamental human rights and, at the very least, adhere to all relevant local labor and safety laws and observe SDG8 (https://www.globalgoals.org/goals/8-decent-work-and-economic-growth/)

We firmly believe in the principle of equal treatment for all individuals. Our own teams are held to the highest standards in upholding this belief, and we anticipate comparable behavior from our business partners.

We anticipate that Business Partners will provide workers with a written employment contract containing comprehensive details, such as agreed compensation and working hours. The contract should be articulated in a language comprehensible to the worker. It is imperative that the agreed compensation never falls below the minimum wage stipulated by local law or industry standards under any circumstances.

BEESINESS adopts a strict zero-tolerance stance on child labor, making absolutely no exceptions to this policy. No individuals under the age of 16 or below the minimum age of employment specified by local law, whichever is higher, will be engaged. Additionally, all children must fulfill compulsory education requirements. Workers under the age of 18 will receive enhanced protections compared to adult workers, especially concerning overtime and hazardous tasks. Proof of age must be thoroughly verified before employment, and relevant documentation must be diligently retained. Our values are aligned with SDG8 target 8.7 (https://data.unicef.org/sdgs/goal-8-decent-work-economic-growth/)

We strictly prohibit any form of forced labor or work carried out through deceit, intimidation, or coercion. This commitment necessitates that all employees have their fundamental human needs addressed while on duty, such as the freedom to use restroom facilities and access to drinking water. Every worker is entitled to terminate their employment at any point in compliance with the law. Additionally, BEESINESS insists that the employment of international workers is contingent upon a valid work permit, and no one should unlawfully obstruct workers from accessing their identity or immigration documents. If accommodation is provided, it must adhere to all legal requirements, particularly those related to health and safety regulations.

BEESINESS anticipates that its business partners will proactively take measures to ensure that the minerals and metals utilized in their production or products do not contribute, either directly or indirectly, to conflicts in nations significantly affected by the mining industry.

BEESINESS mandates that its Business Partners uphold the legal entitlement to freedom of association and collective bargaining, encompassing unionization where permitted by local law. Any endeavor to impede or disrupt these processes contradicts our core values. Furthermore, Business Partners are encouraged to actively facilitate alternative avenues for their workers to express their opinions, such as through representation, mediation, and conflict resolution.

Environmental and Sustainable Business Practices

Every employee is required to carry out their daily tasks in the workplace with an environmentally responsible approach, adhering to all relevant environmental laws and regulations.

Printing is to be undertaken by all the personnel with careful consideration; if deemed necessary, double-sided printing should be employed to minimize paper consumption.

BEESINESS employees are encouraged to actively foster the use of our eco-friendly products among customers.

Prohibition on Dealing with Customers from Sanctioned Territories

It is mandatory for all employees to ensure that customers are informed that they are prohibited from selling or distributing the Company’s products to any entities located in Sanctioned Territories (https://www.sanctionsmap.eu/#/main/authorities<, https://www.eeas.europa.eu/eeas/european-union-sanctions_en ).

In case of possible conflicts or external hints BEESINESS reserves the right to cross-check and take actions accordingly.

Anti-Competitive Practices

All staff are obligated to steer clear of any business or marketing practices that are anticompetitive in nature. BEESINESS has a zero-tolerance policy for anti-competitive behavior from our staff and business partners. This encompasses any illegal agreements, coordinated practices, insider trading, or other infringements of antitrust and competition laws.

It is imperative for all employees to act in the company's best interest, maintaining independence from competitors, customers, and suppliers. This should be done in strict adherence to the principles of fair competition.

All employees must guarantee that they present the company's products or services to customers under the most favorable terms, emphasizing the commitment to fair and equitable business practices.

Ethical Engagement with Customers

All personnel are required to adhere to all relevant laws and regulations governing the advertising and promotion of products or services. This encompasses regulations specific to healthcare and related industries and their respective products.

All employees must uphold customer privacy by refraining from disclosing any personal information without prior consent. Furthermore, strict compliance with all pertinent data privacy laws is mandatory as written in the General Data Protection Regulation (https://gdpr.eu).

Transparency is essential to avoid conflicts of interest that might compromise objectivity or impartiality. This encompasses refraining from relationships with customers that could be perceived as influencing judgment or decision-making.

Maintaining professionalism is paramount for all employees. Inappropriate or offensive comments, gestures, or actions are strictly prohibited. Adherence to company policies is imperative in all interactions with customers. This includes compliance with policies on gifts, entertainment, and other relevant aspects.

BEESINESS AUDITS

BEESINESS retains the authority to perform audits regarding Business Partners' adherence to this Code of Conduct, in any of the cases described below:

• On a regular basis
• Randomly
• Based on anonymous reporting

The company will collaboratively establish risk mitigation plans within an agreed timeline and terminate relationships with Business Partners unwilling or unable to align with the specified requirements.

PENALTIES

Any breach of laws or the BEESINESS Code of Conduct will lead to disciplinary measures, which may include termination of employment or business contract and pursuit of other legal remedies available to the Company.

ACKNOWLEDGEMENT

I hereby acknowledge, agree, and undertake to adhere to the Company BEESINESS Code of Conduct as set out herein.

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