德国《供应链尽职调查法案》（“LKSG”）

自2022年以来，遵守人权和环境相关尽职调查要求一直是整个集团合规管理体系（CMS）的重点主题。TÜV南德意志集团的合规管理体系建立在以下七大支柱之上：

3.1. 合规文化

合规文化是TÜV南德意志集团合规管理体系的基础，其特点是管理者“上层定调”。合规对TÜV南德意志集团至关重要，因为集团在致力于保护人类、环境和资产的过程中，始终以其独立和诚信服务为根基。 TÜV南德意志集团的合规文化包括所有认同、尊重并支持合规行为重要性的员工。我们也希望供应商建立相应的合规文化。

3.2. 合规目标

TÜV南德意志集团合规管理体系的主要目标之一是确保TÜV南德意志集团的所有员工和签约第三方在提供服务时守法合规。对于TÜV南德意志集团的供应商，我们的目标是使其符合TÜV南德意志集团供应商行为准则中提出的期望。集团将对所有违规指控进行调查，并对违规行为进行处罚。TÜV南德意志集团对任何违规行为均秉持零容忍态度。

3.3. 合规风险

通过在全集团对一般合规和特定LkSG风险进行定期分析，我们确定了可能造成违规行为进而导致无法实现合规目标的风险。对于TÜV南德意志集团等全球运营集团而言，各专业部门和地区之间的互联互通至关重要。针对已识别的风险，我们会根据其发生概率及潜在后果进行分析。此外，由集团高管组成的合规委员会每年多次召开会议，讨论全集团内的合规动态，并评估潜在的新风险。在风险分析的基础上，制订出旨在降低合规风险并防止违规行为的原则和措施。

3.4. 合规计划

TÜV南德意志集团的合规计划以预防为主。对于潜在的违规行为需要提前作好预防措施，尤其需提高员工意识、加强员工教育并实施预防性的企业流程。除了预防措施外，合规计划还包括违规情况下的补救措施以及举报系统（即TÜV南德意志集团信任渠道）。自2022年起，合规计划还将着重关注人权和与人权相关的环境保护义务。

作为合规计划的核心，行为准则规定了适用于整个集团的TÜV南德意志集团合规事项的基本规则。其中一章规定了遵守人权和环境保护义务。

在适用于整个集团并由专业部门发布的各类指南中，均明确提出了行为准则中规定的基本规则。集团人力资源部的各类指南确保TÜV南德意志集团在自身业务运营中始终尊重人权，包括人权和劳动法、多元化和包容性、结社自由、全球健康和安全管理、公平同酬等指南。其内容包含了与LkSG所定义的人权相关环境风险，尤其是在集团房地产部和环境政策中。采购部确保在供应链中尊重人权，并在采购指南、采购手册和供应商行为准则中为此规定了必要和适当的措施。

3.5. 合规组织

TÜV SÜD AG 管理委员会全面负责TÜV南德意志集团合规管理体系和合规组织结构。TÜV 南德意志集团的合规组织包括位于TÜV SÜD AG且具有全球指导职能的全球合规办公室、为全球所有公司和地区设立的地方合规官和区域合规官，以及企业合规委员会、企业风险委员会和信任渠道合规委员会。全球合规办公室由首席合规官、企业合规主管、企业合规官、全球人权官和其他员工组成。TÜV南德意志集团的合规组织由首席合规官领导。首席合规官直接向管理委员会主席汇报工作，在履行这一职能时不受任何指示的约束。企业合规主管负责管理TÜV南德意志集团合规组织的战略和运营。全球人权官负责监督LkSG规定的人权和环境相关尽职调查义务方面的风险管理。

3.6. 合规沟通

TÜV南德意志集团合规管理体系最重要的要素之一是合规问题的风险沟通。一方面，TÜV南德意志集团通过书面规定和培训课程以及其他沟通措施对其员工进行合规沟通，如管理人员至少每六个月进行一次的“合规时刻”。合规沟通的目的是让员工了解相关的合规问题，加深合规认识，同时彰显员工对自身行为的责任感，并深化对TÜV南德意志集团合规管理体系的认识。指南出现修订或新版本时，通过多种渠道在整个集团公布。TÜV南德意志集团全球所有员工都必须参加年度合规电子化学习。自2022年起，合规电子化学习还包括学习卡，内容涉及LkSG规定的人权和环境相关保护义务。此外，我们还开展了面向目标群体的沟通，例如针对TÜV南德意志集团供应商的沟通，或针对从事较多风险相关活动员工的课堂培训。

除了对TÜV 南德意志集团员工进行沟通外，全球合规办公室每年还向TÜV SÜD AG 管理委员会和监事会提交合规报告。合规报告包含上一年开展的合规活动以及处理的合规事件，包括采取的措施。全球人权官每年至少编写一次报告（可能临时编写报告），介绍为遵守LkSG规定的人权和环境相关尽职调查义务所开展的监督风险管理方面的主要活动。该报告特别包括与TÜV南德意志集团自身业务运营及其供应商有关的基于事件（如适用）的定期风险分析结果，以及任何相应的措施。该报告需上交至TÜV SÜD AG管理委员会以及同样属于LkSG直接管辖范围内的集团公司管理层。

3.7. 合规监督和改进

为了验证合规管理体系的适当性和有效性，TÜV南德意志集团的合规管理体系不仅接受全球合规办公室的定期监督，还接受内部和外部利益相关方的监督。为此，所有相关的合规活动均应具有适当的文件记录。系统的合规监督应作为一项特别监督措施予以强调。合规监督基于事件相关的调查、TÜV南德信任渠道中的条目以及其他合规相关信息和数据，例如定期进行的员工调查。此外，合规监督还基于定期和标准化的合规监督调查，尤其是针对地方合规官的调查，以及集团内部审核部进行的定期合规核查。

如果在监督TÜV南德意志集团合规管理体系的过程中发现可能存在的薄弱环节或违规行为，一方面会向相关决策者报告，同时还会采取适当措施以改进合规管理体系。

To identify and assess human rights and environment-related risks in TÜV SÜD's own business operations and at TÜV SÜD's suppliers, the respective responsible departments conduct risk analyses as described below. These are carried out at least once a year and on an ad hoc basis, i.e. if TÜV SÜD must expect a significantly changed or significantly expanded risk situation in its own business operations or in the supply chain, for example due to new projects, business areas or relevant company acquisitions, or if reports from whistleblowers suggest a changed risk situation.

4.1. Risk analyses relating to TÜV SÜD's own business operations

Risk analyses relating to human rights risks within the meaning of Section 2 (2) Nos. 1-8 and 12 of the LkSG in TÜV SÜD's own business operations are carried out under the responsibility of the Human Resources Group Department; the Local Compliance Officers are consulted for specialist support.

Risk analyses relating to human rights and environment-related risks within the meaning of Section 2 (2) Nos. 9-11 and (3) LkSG in TÜV SÜD's own business operations are carried out by the Global Compliance Office; relevant departments such as the Real Estate Group Department or the Quality Management Group Department are consulted for specialist support.

The risk analyses in TÜV SÜD's own business operations are monitored by the Global Human Rights Officer, who provides specialist support where necessary. 

The risk analyses are carried out using the so-called countercurrent method: 

"Top-down": Coordination with various stakeholders and definition of risk scenarios relevant for TÜV SÜD. Preparation of a risk-based questionnaire that inquires with respect to each risk scenario i) what the potential impact of the occurrence of a risk is in a realistic worst-case scenario without countermeasures, ii) which relevant countermeasures exist, and iii) what the probability of occurrence of the risk scenarios is, taking into account the existing countermeasures. "Bottom-up": Risk assessment by means of a questionnaire along risk scenarios by employees in key functions of TÜV SÜD companies. In particular, these are employees who can potentially influence the risk, such as local QM officers in the case of environment-related risks within the meaning of Section 2 (3) LkSG or local HR officers in the case of human rights risks within the meaning of Section 2 (2) Nos. 1-8 and 12 LkSG. In addition, the questionnaire is answered by the local compliance officers in order to maintain the dual control principle and to take into account different professional views.

The evaluation of the questionnaires, weighting and prioritization of the risks identified, as well as documentation and reporting, are carried out by the responsible specialist department. Further details can be found in the group-wide Compliance Risk Analysis Guideline.

In addition to the risk analysis carried out subject to the countercurrent method described above, all TÜV SÜD group companies in which TÜV SÜD AG, TÜV SÜD Auto Service GmbH, TÜV SÜD Industrie Service GmbH, TÜV SÜD Product Service GmbH or TÜV Technische Überwachung Hessen GmbH directly or indirectly holds a majority stake or over which TÜV SÜD AG, TÜV SÜD Auto Service GmbH, TÜV SÜD Industrie Service GmbH, TÜV SÜD Product Service GmbH or TÜV Technische Überwachung Hessen GmbH otherwise exercises a decisive influence are monitored for potential human rights and environment-related risks using an artificial intelligence-based Internet screening software solution. This involves checking social media, news and other information available on the Internet 24/7 on the basis of a keyword search in order to find out reports on individual TÜV SÜD companies. Reports of potential risks are communicated to the Global Compliance Office by way of "risk alerts". The Global Compliance Office checks the "risk alerts" for adequate plausibility and deals with solid information in accordance with the procedure defined for notifications via the TÜV SÜD Trust Channel (cf. para. 7. below).

4.2. Risk analyses regarding TÜV SÜD's direct suppliers and, if applicable, indirect suppliers

Risk analyses relating to TÜV SÜD's suppliers are carried out under the responsibility of the Purchasing Group Department. This does not include risk analyses relating to TÜV SÜD's suppliers that are based on procurement transactions as per Annex 2 of the Purchasing Guideline and for which the Purchasing Group Department is therefore not responsible (such as insurance contracts or contracts with auditors and tax consultants); risk analyses relating to such suppliers are carried out under the responsibility of the Global Compliance Office.

Risk analyses relating to all TÜV SÜD suppliers are monitored by the Global Human Rights Officer, who provides specialist support where necessary.

The purpose of the risk analyses is to identify human rights and environment-related risks at TÜV SÜD's direct suppliers around the globe and to assess the identified risks, in particular, on the basis of the following criteria: the probability of occurrence of the risk, the severity of the breach typically to be expected if the risk occurs, TÜV SÜD's ability to influence the direct cause of the risk or breach, and the nature of TÜV SÜD's causal contribution.

4.2.1. Annual analysis of risks at TÜV SÜD's direct suppliers

The first thing obtained in the annual risk analysis is an overview of all current direct suppliers; of these, so-called exceptions as per Annex 2 of the Purchasing Guideline are filtered out and passed on to the Global Compliance Office for further analysis. Due to the large number of TÜV SÜD's direct suppliers and on the basis of an appropriate, risk-based approach, only those direct suppliers will be examined in more detail in the following until further notice where TÜV SÜD, due to its purchasing volume, exerts a certain degree of influence on the one hand, and on the other hand, a potential causal contribution to a possible breach would not be insignificant. In this way, priority is given to identifying those risks where TÜV SÜD's influence can be used to bring about a real positive change. This approach is reviewed on a regular basis.

Annual risk analyses are conducted in the following manner: 

• Taking into account numerous recognized indices such as the Global Slavery Index, the ITUC Global Rights Index or the EPI - Environmental Performance Index, various indicators from the UN SDG database, or the Research Report 543 published by the German Federal Ministry of Labor and Social Affairs in July 2020, the first step is to determine which of TÜV SÜD's direct suppliers are subject to an abstract industry-specific or country-specific risk. Considering the large number of TÜV SÜD's direct suppliers, a software solution is used to support this process. 
• In a second step, this abstract view is defined more precisely: The Purchasing Group Department i.a. uses information, on the one hand, obtained in the software solution through artificial intelligence-based internet screening and, on the other hand, supplemented by self-disclosures from suppliers. The Global Compliance Office carries out risk-appropriate, individual investigations. In this second step, the probability of occurrence and the severity of the violation when the risk occurs are also analyzed.
• In a final step, the purchasing volumes are used to determine TÜV SÜD's ability to influence as well as any causal contribution, and, in this way, prioritize which of TÜV SÜD's direct suppliers must first respond to the identified risks with appropriate measures.

In the future, in addition to considering direct suppliers, indirect suppliers are also to be more strongly included in the consideration of TÜV SÜD's supply chain. Among other things, "Worker Voice" surveys are planned for indirect suppliers identified as critical. 

4.2.2. Permanent monitoring of risks at TÜV SÜD's direct suppliers

In addition to the annual risk analysis described above, the direct suppliers with the highest risks and certain significant suppliers are permanently monitored for potential human rights and environment-related risks using a software solution. This involves checking social media, news and other information available on the internet 24/7 on the basis of a keyword search to find out what the reports are on direct suppliers. Reports of potential risks are communicated as "risk alerts" to the employees in the Procurement Group Department responsible for the relevant product group or region and to the Global Human Rights Officer. Such notifications trigger a review process defined in the Purchasing Manual, which may lead to further measures (for more details, cf. para. 5.2. and para. 6.2. below).

4.2.3. Risk analysis regarding new direct suppliers

Notwithstanding the foregoing, TÜV SÜD subjects all new direct suppliers to an independent risk analysis as per the criteria set out in para. 4.2.1. for annual risk analyses prior to entering into the new business relationship. 

4.2.4. Ad hoc event-related risk analyses with respect to individual indirect suppliers

If TÜV SÜD obtains substantiated knowledge of the existence of factual indications that suggest the possibility of materialization of a breach of human rights or environment-related obligations by an indirect supplier, the information available will promptly be subjected to an initial review by the Purchasing Group Department or, in case of suppliers as defined in Annex 2 of the Purchasing Guideline, by the Global Compliance Office, depending on its origin in the supply chain. Subsequently, the probability of materialization and the severity of the breach in case of materialization of the risk are analyzed or, in case of an actual breach of a human rights or environment-related obligation by an indirect supplier, the effects are analyzed. Depending on the ability to influence and any causal contribution, it is finally determined to what extent appropriate measures can be taken in response to the knowledge obtained (for more details, see para. 5.2. and para. 6.2. below).

The results of such an event-related risk analysis are used to review the outcome of the regular risk analysis in order to determine the extent to which the prioritized risks need to be adjusted.

4.2.5. Ad hoc event-related risk analyses regarding the entire supply chain

If TÜV SÜD anticipates a significantly changed or significantly expanded risk situation in the supply chain, the Purchasing Group Department and the Global Compliance Office will promptly conduct an initial review of the changed or added risks based on an abstract consideration of the relevant industry-specific and country-specific risks and then conduct targeted, risk-appropriate investigations. This is followed by an analysis of the probability of occurrence and the severity of the breach if the risk materializes in the supply chain. Finally, depending on the ability to influence and any causal contribution, the extent to which appropriate measures can be taken in response to the findings obtained is determined.

The results of such an event-related risk analysis are used to review the outcome of the regular risk analysis in order to determine the extent to which the prioritized risks need to be adjusted.

5.1. Preventive measures for risks in TÜV SÜD's own business operations

At TÜV SÜD, preventive measures taken with respect to the prevalence of human rights and environment-related risks in its own business operations consist primarily of defining the relevant rules of conduct in written rules, communicating them throughout the group via various channels, and reinforcing the content in training courses. Local Compliance Officers have been appointed in all TÜV SÜD companies and regions around the globe to coordinate the communication of compliance topics and compliance training, including content on human rights and environment-related obligations.

The core of this set of rules at TÜV SÜD is the Code of Conduct, which includes a chapter on compliance with human rights and environment-related protection obligations. The basic rules from the Code of Conduct are specified in group guidelines, such as the guideline on Human Rights and Labor Law, Diversity and Inclusion, Freedom of Association, Global Health and Safety Management, Fair and Equal Remuneration, and the Environmental Policy.

All TÜV SÜD employees around the globe are required to participate in the compliance e-learning once a year. Since 2022, this training has also included a learning card on human rights and environment-related protection obligations as defined by the LkSG, which is reviewed annually for the need for adjustment. In addition, there is target group-oriented communication and classroom training for employees who perform more risk-related activities.

In January 2023, the Compliance Moment was issued with a focus on human rights and environment-related risks. One Compliance Moment will be presented to all employees by their managers in each half year. In this way, all employees around the globe will be made aware in particular of the issue of human rights and environment-related obligations in a "Tone from the Top" approach.

In addition to the preventive measures above, which cover all TÜV SÜD employees, there are further risk-appropriate, target group-oriented measures. These include, in particular, the wide range of measures taken by the Purchasing Group Department. TÜV SÜD's procurement strategy is geared toward sustainability; in any purchasing decisions, a special focus is placed on the social and ecological aspects of sustainability. All employees of the Purchasing Group Department are regularly trained on human rights and environment-related due diligence. Compliance with the binding purchasing practices specified in the Purchasing Manual is reviewed at regular intervals.

Further, there are regular preventive control measures: For example, the Internal Audit Group Department conducted an internal audit in the first half of 2023 with a focus on reviewing the implementation status of the LkSG requirements. No negative deviations were identified. In the second half of 2023, the Internal Audit Group Department conducted another internal audit in which the implementation status of the LkSG requirements was reviewed specifically at the TÜV SÜD group companies that carry out procurement without the direct involvement of the central Shared Service Center Procurement. No significant deviations were identified during this internal audit.

5.2. Preventive measures for risks at TÜV SÜD's direct suppliers and, if applicable, indirect suppliers

One of the most important preventive measures regarding human rights and environment-related risks at TÜV SÜD's direct suppliers is a consistent selection. Before a contract is signed, a supplier is screened and evaluated from a sustainability perspective. When selecting suppliers, TÜV SÜD consistently ensures that they meet sustainability requirements.

Another important preventive measure is the TÜV SÜD Supplier Code of Conduct which was completely revised in 2024; it is the core of TÜV SÜD's understanding of sustainability and compliance in purchasing. In particular, it sets out the human rights and environment-related expectations vis-à-vis TÜV SÜD's direct suppliers. With the new version of the TÜV SÜD Supplier Code of Conduct, the purchasing processes were adapted and the risk-based approach was strengthened. The TÜV SÜD Supplier Code of Conduct is i.a. communicated to direct suppliers by e-mail and is published on the Internet in German and also in 12 other languages. It also forms an integral part of TÜV SÜD's General Terms and Conditions of Purchase. The purchasing volume from suppliers who have committed themselves to compliance with the expectations contained in the TÜV SÜD Supplier Code of Conduct by contract is to be continually increased to 100% by 2026.

TÜV SÜD also implements additional preventive measures to an extent appropriate to the risk. These include, for example, a training video targeted specifically to suppliers to raise awareness of human rights and environment-related protection obligations among direct suppliers, preventive self-reporting by suppliers, and on-site audits of suppliers to assess compliance with the expectations set out in the TÜV SÜD Supplier Code of Conduct.

If TÜV SÜD obtains substantiated knowledge of the existence of factual indications that suggest a possible breach of a human rights or environment-related obligation at an indirect supplier and in case these indications are also confirmed in the risk analysis (cf. para. 4.2.4. above), the responsible specialist department will take appropriate preventive measures from the list of possible measures described above, depending on its ability to influence the party directly responsible for the risk and TÜV SÜD's own causal contribution, if any. In addition, TÜV SÜD will use the knowledge thus obtained to review this Policy Statement for any need for adjustment.

5.3. Review of effectiveness of preventive measures

All sets of rules that apply to all TÜV SÜD employees throughout the group, as well as those that TÜV SÜD bindingly agrees with suppliers and third parties, are regularly reviewed for their effectiveness and any need for adjustment. The same applies to the other preventive measures described above. This is done at least once a year on the basis of the results of the annual risk analyses as well as on an ad hoc basis, i.e., if TÜV SÜD must expect a significantly changed or significantly expanded risk situation in its own business operations or in the supply chain, for example due to new projects, business areas, or relevant company acquisitions, or if reports from whistleblowers suggest a changed risk situation.

The regular review of the TÜV SÜD Supplier Code of Conduct, for example, revealed a certain potential for further development. The revision and publication took place in the first quarter of 2024.

6.1. 针对TÜV南德意志集团自身业务运营的补救措施

如果TÜV南德意志集团的业务运营中即将或已经发生违反人权或环境相关义务的明显行为，TÜV南德意志集团应立即采取适当补救措施，防止或终止违规行为。TÜV南德意志集团对任何违规行为均秉持零容忍态度。

采取何种措施取决于各种因素，比如即将发生或实际发生的违规行为的类型和严重程度。根据特定案例的主要情况，可能会采取纪律处分，和/或提起刑事或民事诉讼。根据适用的劳动法，纪律处分的范围涵盖非正式的员工通知、正式警告函以及解雇（发出或不发出通知）。其他可能的措施包括参加特殊培训课程的义务、双方同意变更聘用合同以及调职。更多详情，请参见集团有关“合规举报、调查和制裁”的指南。

6.2. 针对TÜV南德意志集团直接供应商以及间接供应商（如适用）的补救措施

一旦TÜV南德意志集团获悉TÜV南德意志集团的直接供应商即将或已经违反人权或环境相关义务，TÜV南德意志集团将立即采取适当补救措施，防止或终止违规行为，或减轻违规程度。

采取何种适当措施取决于特定案例的主要情况，如即将发生或实际发生的违规行为的类型和严重程度，以及TÜV南德意志集团施加影响的能力和任何因果贡献，以决定在具体情况下采取何种适当措施。根据特定案例的主要情况，可以考虑采取以下措施：首先，凭借在保护人员、环境和资产免受技术风险方面的多年经验和专业知识，TÜV南德意志集团可与相关供应商以及利益相关方（如适用）合作，共同制订解决方案。 如果在可预见的将来无法终止违规行为，供应商应制定具有针对性的方案，以有效终止或减轻该行为。必要时，TÜV南德意志集团将提供相应的支持与协助。TÜV南德意志集团将对规定时间内该方案的实施情况进行核查。此外，TÜV南德意志集团还将随时评估是否有必要与其他公司的合作，比如在行业倡议框架内合作，以增加对违规方施加影响的可能性。其他措施包括暂时中止供应关系，最严重时可以终止业务关系。

如果TÜV南德意志集团确凿获悉间接供应商出现违反人权或环境相关义务的迹象，且该迹象经风险分析得以确认（请参见上述第4.2.4条），负责的专家部门将根据其对违规方施加影响的能力以及TÜV南德意志集团自身的因果贡献（如有），从上述措施清单中采取适当的补救措施。

6.3. 补救措施的有效性审查

适用于TÜV南德意志集团所有员工的所有规则，以及TÜV南德意志集团与供应商和第三方达成的具有约束力的协议，都会进行定期审查，以确定其有效性以及是否需要进行调整。上述其他补救措施也需进行审查。基于年度风险分析结果的审查每年应至少进行一次，此外在出现如下情况时也可进行临时审查：在TÜV南德意志集团预计其自身业务运营或供应链中的风险状况将发生重大变化或显著扩大时，例如由于新项目、业务领域或相关公司收购，或当举报人的报告显示风险状况发生变化时。

The TÜV SÜD Trust Channel may be used to submit complaints or information regarding human rights or environment-related risks as well as breaches of human rights or environment-related obligations.

The TÜV SÜD Trust Channel is a secure and confidential channel which is available 24/7 and may be used by all TÜV SÜD employees around the globe, as well as all customers, suppliers and other third parties, to report concerns about suspected cases or breach; reports may also be submitted anonymously to the extent required. Whistleblowers have the option of providing their contact details or setting up a secure electronic mailbox through which they can communicate with the Global Compliance Office anonymously and confidentially. The TÜV SÜD Trust Channel is an Internet-based whistleblower system that is available in the 19 languages relevant for TÜV SÜD's business activities and it is technically managed by a third-party provider. Any reported content is processed exclusively by TÜV SÜD employees. Any and all data contained in a whistleblower report is stored on secure servers in Germany. Further information on the whistleblower system as well as the rules of procedure are available on the TÜV SÜD Trust Channel website which is hosted on a secure server; the TÜV SÜD Trust Channel is also linked on TÜV SÜD's website and intranet and it is promoted at regular intervals on various communication tools. In order to ensure the most barrier-free access possible, the rules of procedure are available in 19 languages as well as an explanatory video.

Employees who report and submit information to the best of their knowledge and in good faith must not be disadvantaged in any way at TÜV SÜD. At the same time, TÜV SÜD recognizes the importance of protecting individuals against whom a tip-off is directed. Neither these persons nor whistleblowers may be compromised prematurely.

The compliance organization investigates any and all incoming information locally, regionally or globally, if necessary, also involving the Internal Audit Group Department. Any and all information is treated as confidential and forwarded only to individuals who need to know this information in the context of investigation or subsequent action ("need-to-know principle"). The protection of the whistleblower and the person concerned is ensured in every investigative measure.

If the whistleblower has communicated or set up a contact option, this person will receive an acknowledgement of receipt no later than seven days after submitting a whistleblower report. Within three months after sending the confirmation of receipt at the latest, the Compliance Officer in charge of the case will inform the whistleblower of any measures planned to be taken and, if applicable, already taken and the reasons for such measures, provided that this information does not adversely affect the investigation or the persons concerned.

Whenever a tip-off has been confirmed, appropriate disciplinary measures will be imposed and, if and where necessary, criminal or civil action will also be taken. TÜV SÜD pursues a zero-tolerance approach in this respect. The relevant decision-makers are informed at regular intervals about human rights or environment-related risks confirmed as a result of a tip-off, as well as breaches of human rights or environment-related obligations. In order to prevent future risks and breaches, appropriate measures are taken in confirmed cases, such as process changes, communication measures, and target group-oriented training.

Further details can be found in the group guideline on Compliance Tip-Offs, Investigations and Sanctions. As with all rules and regulations that apply to all TÜV SÜD employees throughout the group, this guideline is regularly reviewed for effectiveness and any need for adjustment. The same applies to the other procedures described above. This is done at least once a year on the basis of the outcome of the annual risk analyses and on an ad hoc basis, i.e., if TÜV SÜD must expect a significantly changed or significantly expanded risk situation in its own business unit or in the supply chain, for example as a result of new projects, business fields, or relevant company acquisitions, or if reports from whistleblowers suggest a changed risk situation.

Compliance with human rights and environment-related due diligence obligations as per Section 3 LkSG is continuously documented by the respective responsible departments specified in para. 3.-7. above. Documentation will be archived for at least seven years from the date of issuance. The Global Human Rights Officer will monitor compliance with documentation obligations of the respective responsible departments and provides specialist support where necessary.

In 2024, TÜV SÜD AG, TÜV SÜD Auto Service GmbH and TÜV SÜD Industrie Service GmbH filed a report as per Section 10 (2) LkSG regarding compliance with human rights and environment-related due diligence obligations as per Section 3 LkSG in the fiscal year 2023 for the first time and made it publicly available free of charge on TÜV SÜD's group uniform website.