Compliance with laws and internal regulations is a top priority for the Liebherr Group. In order to meet this requirement, it is important to identify possible misconduct early and follow up on it immediately. For compliance with statutory regulations, the Code of Conduct and other internal group regulations, employees of the Liebherr Group and external informants are encouraged to report possible misconduct.

Possible misconduct may concern the following areas:

• Economic crimes (corruption, fraud, misappropriation, etc.)
• Breaches of antitrust and competition law
• Money laundering crimes
• Violation of product safety and conformity requirements (including breaches of safety requirements in the civil aviation sector)
• Breaches of personal data protection regulations
• Breaches of applicable embargo and export regulations
• Violations of the German Supply Chain Act (LkSG) (e.g. child labour, forced labour and slavery, non-compliance of occupational health and safety, non-compliance of freedom of association, failure to provide a fair wage, use of mercury as defined in the Minamata Convention, use of persistent organic pollutants as defined in the Stockholm Convention, export of hazardous waste as defined in the Basel Convention)
• etc.

The Liebherr Group has created several options for reporting a suspected compliance breach. Verbal tip-offs of violations or infringements are accepted in German, French, English, Italian and Portuguese. For written tip-offs, we kindly request that you send these by post or electronically. We accept written tip-offs in the following languages: French, German, English, Italian, Spanish, Portuguese, Bulgarian, Russian and Chinese. When reporting, informants are invited to reveal their identity. For the purpose of further communication and any queries, we also request that the informants leave us their contact details. At the justified request of the informant, a personal meeting with a responsible person can be arranged in order to report possible violations.

Every informant who reports a compliance breach with good intent is guaranteed their report and their personal data will be handled confidentially. No disadvantages, discrimination or penalties are tolerated for an informant who reports a compliance breach. However, misuse of the reporting channel for improper purposes will also not be tolerated. It must be highlighted at this point that a deliberately untrue report can also have criminal consequences.

Within seven days of receipt of the tip-off, the informant will receive an acknowledgement of receipt. The Chief Compliance Officer or their appointed representative will then conduct a preliminary review of the potential legal or regulatory violation. If the suspicion is substantiated, the case is assigned to the responsible investigative body with a specific investigation order. Incriminating as well as exculpatory facts are included in the investigation. If the investigative body cannot prove a breach, innocence is presumed. Within no more than three months of confirmation of receipt of the report, the informant shall be notified of any measures planned or already taken.

For reports concerning Liebherr companies based in Germany, the German Whistleblower Protection Act (HinSchG) also provides for the possibility of external reporting. For this purpose, the German Federal Government has established an external reporting body within the Federal Office of Justice (BfJ). This is objectively independent and organisationally separate from the other areas of responsibility of the BfJ. If you prefer to report externally, please consult the following link: www.bundesjustizamt.de/DE/MeldestelledesBundes/MeldestelledesBundes_node.html