Corporate culture and values

Material impacts, risks, and opportunities and their interaction with strategy and business model (SBM-3)

Corporate culture and values are a key sustainability-related topic as an opportunity for NORMA Group’s own operations, which is directly related to corporate strategy, decision-making and the business model. NORMA Group is convinced that responsible corporate governance and practiced corporate values create trust among stakeholders, promote employee loyalty, strengthen reputation, and thus offer an opportunity for sustainable growth and long-term corporate success. NORMA Group’s Group-wide corporate values are:

• Team spirit – We empower people

• Open mindset – We share ideas and information

• Strong ties – We develop partnerships

• Change readiness – We drive change

NORMA Group’s corporate values constitute the compass for decisions and are taken into account in cooperation and dealings with business partners. They represent the desired behaviors within the corporate culture. NORMA Group believes that team spirit empowers people and that an open attitude promotes the exchange of ideas and information. At the same time, the Company believes that strong connections create trusting partnerships and that a willingness to change drives change. These values apply to all employees and are the basis of NORMA Group’s actions.

By establishing this vision, NORMA Group aims to strengthen the management’s strategic focus on a sustainable and resilient business model, combining long-term economic success with environmental and social responsibility.

Policies related to corporate culture and values (G1-1)

NORMA Group’s corporate culture is based on the corporate vision and mission and is further defined by the corporate values (Core Values). By integrating the corporate values into training courses for employees and line managers and embedding them in HR processes, they form the guiding principles for the further development of the corporate culture.

NORMA Group’s vision is based on committed collaboration and excellent global performance that creates sustainable solutions. The Company is constantly working to promote teamwork, value diversity and strengthen transparent communication in order to build trusting relationships. The focus is on efficiency, continuous improvement, sustainability, and resource conservation, supported by digitalization and automation while complying with global quality standards.

NORMA Group’s mission is to be a reliable partner, exceeding customer expectations with efficient solutions and building long-term relationships. Sustainable growth is to be driven by innovation and the highest quality standards within the framework of what is permitted by regulations in order to help customers overcome their challenges.

Central guidelines and systems

This understanding of NORMA Group’s values forms the basis for business policy decisions and actions. In particular, the global focus of the Company makes worldwide implementation and compliance with codes of conduct especially important. Compliance frameworks define rules clearly and transparently. NORMA Group’s central guidelines include:

• the Code of Conduct

• the Whistleblowing Policy

• the Anti-corruption Policy and

• the Supplier Code of Conduct.

The guidelines are related to the positive impacts, risks, and opportunities identified as material. These guidelines are regularly reviewed and updated in order to meet the relevant requirements.

Code of Conduct

NORMA Group’s Code of Conduct is a document that summarizes the ethical and legal standards expected of employees and managers in their dealings with each other and with third parties. It provides a guide for behavior and decision-making in the professional environment and promotes a positive, respectful, and law-abiding work environment. NORMA Group expects its employees to conduct themselves at all times in accordance with its corporate values and commitment to ethical behavior. In addition, they are expected to conduct NORMA Group’s business at all times in accordance with applicable national, regional, local, and foreign laws and NORMA Group’s internal guidelines. The Code of Conduct covers topics such as personal integrity, corporate integrity, human rights, and the handling of NORMA Group’s assets. In the event of suspected violations of the Code of Conduct, NORMA Group employees can contact their Supervisor or the Compliance Organization. In addition, the compliance organization also provides reporting channels that enable anonymous whistleblowing.

Whistleblower system

NORMA Group encourages its employees to report violations of regulations and internal policies – including across hierarchical levels if necessary. Employees have various reporting channels at their disposal for this purpose, including an electronic whistleblower system. This whistleblower system allows internal and external whistleblowers to report suspicious cases to NORMA Group’s Compliance organization and, if necessary, to maintain their anonymity. NORMA Group also offers other appropriate reporting channels, such as personal reporting to NORMA Group Compliance. Alongside the central internal reporting channel, which can be accessed electronically or in person, NORMA Group provides supplementary or alternative reporting channels at all sites where local laws require them. Additionally, every member of NORMA Group’s compliance organization can be contacted regarding any questions or issues related to compliance.

Both the suitability and the appropriateness of the reporting system are reviewed as required by NORMA Group Compliance – for example, with regard to the requirements of “Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law” (“Whistleblower Protection Directive”) and the corresponding implementing laws of the member states. The system is adapted if necessary. In view of the partial contradictions between the national implementation laws and the EU Directive in certain member states where NORMA Group also operates reporting channels, NORMA Group is closely monitoring further developments. Necessary adjustments are made if required.

The Compliance Organization investigates reports of compliance violations. The procedures and protective actions for whistleblowers are detailed in the Whistleblower Protection Policy. This is publicly accessible both on the intranet and on NORMA Group’s website WWW.NORMAGROUP.COM^11a) and is aimed at both internal and external potential whistleblowers.

NORMA Group’s Whistleblowing Policy is committed to protecting whistleblowers who act in good faith from retaliation, dismissal, demotion, and other forms of retaliation, ensuring that whistleblowers are not subject to labor, disciplinary, criminal, or civil sanctions and that they are protected from retaliation for reporting. According to the guideline, any form of discrimination against whistleblowers will not be tolerated and NORMA Group will take the necessary measures to ensure the safety and protection of whistleblowers. Discriminatory behavior toward whistleblowers is strictly prohibited and subject to disciplinary action.

The suitability and appropriateness of the reporting system are reviewed on an ad hoc basis, in particular with regard to the requirements of the Whistleblower Protection Directive and the corresponding implementing legislation of the member states. Where necessary, adjustments are made to ensure that legal compliance and whistleblower protection are always met.

Supplier Code of Conduct

NORMA Group strives to fulfill its responsibility along the entire value chain and therefore expects its suppliers to act in accordance with the Supplier Code of Conduct. This means that suppliers must conduct their business in strict compliance with the law and ethical principles. In addition, they should respect human rights and comply with the applicable standards in the areas of occupational safety and environmental protection. Further details can be found in the section S2 WORKERS IN THE UPSTREAM VALUE CHAIN.

The Management Board of NORMA Group is responsible for maintaining an effective compliance management system. Group-wide compliance activities are coordinated by NORMA Group’s Integrity Director. This person reports to the Executive Vice President Group Legal and Compliance & Integrity and, if necessary, directly to the Chair of the Management Board. In addition to the central Compliance department at Group level, there are also Regional/Local Compliance Delegates at regional level in the EMEA, Americas, and Asia-Pacific regions, as well as in all individual operating companies. The Local Compliance Delegates report to the respective Regional Compliance Delegates, who in turn report to NORMA Group’s central Compliance department.

Every member of NORMA Group’s compliance organization is available to answer questions and concerns about compliance. The Compliance department works closely with the Company’s own legal department to continuously integrate new or changed legal requirements into the compliance risk analyses and the compliance program. In addition, coordination takes place with Internal Audit in order to take current developments into account. The Compliance Committee is a cross-divisional body in which current compliance issues are discussed and necessary actions are agreed. Permanent members of the Compliance Committee are representatives of Compliance, Legal, and Internal Audit & Risk Management. The Compliance Committee generally meets at least quarterly and on an ad hoc basis if necessary. With the Human Rights Committee, a format has also been established in which potential violations of human rights are discussed. In addition to the members of the Compliance Committee, representatives from Human Resources and Corporate Responsibility are permanent members of the Human Rights Committee. The Human Rights Committee usually meets every six months and on an ad hoc basis as required.

The effectiveness of the compliance organization established by the Management Board is monitored by the Supervisory Board of NORMA Group, which is informed of compliance-related matters as needed.

Actions relating to material impacts, risks, and opportunities in connection with corporate culture and values

To ensure the effectiveness of NORMA Group’s compliance management system, all employees must be familiar with the relevant legal requirements as well as the internal compliance guidelines. The goal is to ensure that all NORMA Group employees know the applicable compliance rules as well as the contact persons and reporting channels. The basis for this is NORMA Group’s compliance training, which is mainly carried out in the form of online training and, if necessary, as classroom training. The training courses to be completed are assigned to employees according to their job and responsibility profile. In these training courses, employees are given specific guidance on how to behave in accordance with the compliance guidelines. They then have the opportunity to apply and test their knowledge on the basis of practical questions and case studies. The fundamental training courses, which are mandatory as basic training for all NORMA Group employees with a PC workstation, include the online courses “Code of Conduct & Compliance Basics” and “Anti-corruption.” Depending on the area of activity, specific focus training, such as “Antitrust and Competition Law,” may also be required. Employees’ knowledge is continuously updated and deepened through refresher training. The “Speak Up!” training course with important information on the topic of whistleblowing has been an integral part of the company-wide training portfolio since the roll-out. For non-commercial employees, especially in the production area, who generally do not have a PC workstation, for example, compliance safety cards or posters are made available in the most important languages and clearly communicate the most important compliance topics. Training requirements are reviewed where necessary, while an internal reporting system documents the progress and status of compliance training. Compliance-relevant topics are also communicated via various communication channels, such as posters, brochures, compliance safety cards with compact summaries of key compliance topics, emails, and intranet articles.

Targets related to corporate culture and values

NORMA Group aims to strengthen employee loyalty and increase its attractiveness as an employer through a clearly defined mission, vision, and strong corporate values. The Company’s aim is for these cultural elements to promote identification, provide guidance, and help retain people over the long term while attracting new talent.