PHOENIX CONTACT | Code of Conduct of the Phoenix Contact Group

Section 1 Section 2 Why do we need a Code of Conduct? 4 What you should know in advance 2.1 What is the Code of Conduct? 6 7 2.2 What is the relationship between the Code of Conduct and our corporate principles? 8 2.3 One Code of Conduct. For everybody. 9 Topic overview 2 Phoenix Contact

Section 3 Section 4 Your contact options 4.1 Your contact options at Phoenix Contact 4.2 Protection of whistleblowers 28 30 31 Upon which principles are our actions based? 3.1 Compliance with laws 3.2 Human rights and corporate due diligence 3.3. Sustainability 3.4 Anti-discrimination, respect, and integrity in everyday business 3.5 Occupational health and safety 3.6 Environmental protection and ecology 3.7 Data protection 3.8 Information security 10 11 12 15 16 17 18 20 21 3.9 Integrity and fairness in business transactions 23 3.10 Dealing with confl icts of interest 3.11 Quality and product safety 3.12 International trade 3.13 Protection of information and expertise 24 25 26 26 Phoenix Contact 3

1 | Why do we need a Code of Conduct? Dear Colleagues and Readers, We are a globally active, internationally leading, and independently operating family-run business with deep roots and an excellent corporate culture that guides us every day. We employ people and drive our business forward with innovation, independence, and strong partnerships at more than 100 locations worldwide. We move in a large number of cultural circles and have daily contact with a wide range of diff erent people. This diversity and variety demands a common basis, which is why we have subscribed to the ZVEI Code of Conduct for a long time. We continue to apply this Code without limitations. We would now like to build upon this basis and place it on an even broader foundation with the supplementary Code of Conduct of the Phoenix Contact Group. It defi nes the legal and moral guidelines for our actions and also helps us to transfer our values to our everyday operations. We are doing this because both the results of our work and the way we go about achieving those results are important to us. Through appropriate conduct, we have developed an exceptional image that we consider to be a prerequisite for our corporate success. Each and every one of us should take credit but also responsibility for this success. Join us in making an active contribution to the continuous development of our good reputation in the future so that we can ensure sustainable corporate growth and our long-term corporate independence. Your Executive Board Frank Stührenberg Dirk Görlitzer Torsten Janwlecke Ulrich Leidecker Dr. Frank Possel-Dölken Axel Wachholz Phoenix Contact 5

2 | What you should know in advance 2.1 What is the Code of Conduct? The Phoenix Contact Code of Conduct is binding interests arises – even if this results in lost for all of us. It makes the central guidelines for business transactions. Acting with integrity and our everyday actions inside and outside the our excellent reputation will always be a priority company transparent, and answers the question for us. of how we are to conduct ourselves in everyday business. Alongside the legal aspects, it covers Further, the Code of Conduct is both the core our expectations with regard to integrity and and the superstructure of our company-wide moral conduct. compliance management system. Important topics are addressed here in the core and then We will always give these guidelines priority elaborated upon in the detailed regulations. if a confl ict of objectives with our business Phoenix Contact 7

2.2 What is the relationship between the Code of Conduct and our corporate principles? Our purpose, our mission, and the cornerstones of our corporate culture have long been embedded in the corporate principles. They continue to apply without limitation, and are also reflected in our Code of Conduct. Together, we are creating a sustainable world based on our passion for technology and innovation. Mission Solutions for electriﬁcation, networking and automation are our contribution to a world in which renewable energy is available for the beneﬁt of everybody. Culture Independent We always act in a way to ensure our entrepreneurial freedom. Innovative and Creative We consider innovation as a path-breaking bridge to a sustainable future; thus we pro-actively develop our company. Partnerships of Trust Our actions are based on a mutually committed spirit, on friendliness and honesty. Our relations to customers and business partners focus on sustainable beneﬁts for both sides. Our corporate culture encourages trust and supports employees‘ development for achieving agreed targets. 8 Phoenix Contact / 7 9 6 7 5 3 1 / 1 2 / 0 1 n o i t i d E . . 5 L 0 0 0 1 2 - 2 0 R N

3.2 Human rights and corporate due diligence Human rights are irrevocable. They are • The ban on unequal treatment in employment a right for all people worldwide in equal (see also Section 3.4) measure. • The ban on withholding appropriate wages • The ban on destroying the natural basis of life As a company, we are committed to respecting through environmental pollution human rights. This includes in particular: • The ban on unlawful violation of land rights • The ban on child labor • The ban on the hiring or use public or private (ILO Conventions No. 138 and 182) security forces, unless adverse effect may arise • The ban on forced labor and all forms due to a lack of instruction or control of slavery • The ban on any other action or omission (ILO Conventions No. 29 and 105) in breach of duty which is directly capable • The ban on disregarding the occupational of impairing a protected legal position in health and safety obligations applicable under accordance with § 2 Para. 1 GSCA the law of the place of employment (see also Section 3.5) • The ban on disregarding freedom of association (ILO Conventions No. 87 and 98) 12 Phoenix Contact

3 | Upon which principles are our actions based? Our due diligence does not stop at our We publish the details of the relevant activities factory gates. We also use the available transparently and openly within the legally legal framework in our supply chain in defi ned time frame as a policy statement on our order to work towards compliance with homepage. The corresponding obligations and relevant standards or to safeguard them prohibitions are part of this Code of Conduct, within the legal framework. and elsewhere, so that they are transparent for Human rights are closely linked to our corporate to the human rights issues mentioned above, due diligence, which we implement consistently this includes further due diligence related to the within the Phoenix Contact Group. We also fulfi ll environment. all employees and other stakeholders. In addition our corporate due diligence appropriately in our supply chain. The basis and legal framework for this is currently provided by the German Supply Chain Act (GSCA). Phoenix Contact 13

3 | Upon which principles are our actions based? 3.3 Sustainability Harmony among environmental, social, At Phoenix Contact, we live and breathe and governance aspects is the framework sustainability. As part of our 10-year strategy, for sustainable management and corporate sustainability was included as a key aspect of our responsibility at Phoenix Contact. It is corporate principles. important to us to make our contribution • In conformity with the relevant standards, to a sustainable world. sustainability at Phoenix Contact involves three dimensions: the environment, society, and governance. Our activities and decisions are made within the framework of these three dimensions. • As an independent family-owned company, we see sustainability as the foundation for our future development. • We implement sustainability throughout our existing organization, continuously rolling out progress monitoring based on the three dimensions across the entire Phoenix Contact Group worldwide. Further information on our corporate responsibility and commitment is published transparently on our homepage: phoenixcontact.com/codeofconduct Phoenix Contact 15

3.4 Anti-discrimination, respect, and honesty in everyday business life Respectful, fair, and honest conduct is • Our interactions are characterized by fair, the basis of our everyday interactions. respectful, and considerate conduct, equal rights, and equal opportunities. • We respect the dignity of every individual person and strongly oppose inappropriate behavior towards others, for example, mobbing or disrespect. • We do not tolerate discrimination or unequal treatment in employment on the basis of, for example, national or ethnic origin, social origin, health status, disability, sexual orientation, age, gender, political opinion, religion, worldview or any other grounds, insofar as it is not justifi ed by the requirements of the employment (including but not limited to ILO Conventions No. 100 and 111). 16 Phoenix Contact

3 | Upon which principles are our actions based? 3.5 Occupational health and safety Together, we ensure a safe and healthy • As a company, we maintain and promote working environment. In particular, we occupational health and safety in order to observe the occupational health and safety prevent accidents and injuries and to help keep obligations applicable under the law of the employees healthy. place of employment. • As employees, we make an active contribution toward ensuring and promoting a healthy and safe working environment. In particular, we observe general order and safety regulations and take care of ourselves and our colleagues. • We draw attention to inadequate safety standards, dangerous working conditions, and violations of the occupational health and safety regulations so that preventive measures can be taken. • We proactively draw attention to any areas where there is potential for improvement. Phoenix Contact 17

3.6 Environmental protection and ecology Protecting our environment and with it, • Our corporate due diligence also includes the health of our fellow human beings, for environmental aspects. It encompasses both example, is an important goal for us. A complying with prohibitions and restrictions on careful and considerate approach to using substances in our products and treating waste resources informs everything that we do. in accordance with the relevant provisions of the GSCA (Minamata Convention, Stockholm Convention on Persistent Organic Pollutants – POP Convention – as well as the Basel Convention). • As part of maintaining a sustainable business, we meet the relevant environmental protection standards and regulations. • Moreover, environmental compatibility, the eﬃ cient use of resources, and climate protection have high priority in our considerations and activities. • We use natural resources responsibly and operate proactive energy and environmental management programs. • We comply with the applicable international, European, and national legal requirements, as well as the internal mandatory regulations, guidelines, and standards that defi ne material requirements for our products. 18 Phoenix Contact

3.7 Data protection We protect everyone who entrusts their • Data protection is, among other issues, firmly personal data to us. established in the German constitutional rights and the principles of EU law, and serves to protect general privacy rights. Therefore, we consider protecting personal data to be of great importance. • To ensure our protection, we have created internal regulations with the aim of securing and further developing exemplary and appropriate data protection within our Group companies. • Rather than considering data protection in isolation, we take solution-oriented actions which consider the interests of all parties. While doing so, in case of doubt, we give higher priority to the informational autonomy of individual persons. 20 Phoenix Contact

3.8 Information security Information security is essential for • The principles for the security of our ensuring an adequate level of protection IT systems and our business data are stated for our company and the data that we in our directives on information security and process. our international IT standards. We therefore understand and follow them. • Operating powerful IT systems is indispensable • Information security is not limited to the use for our day-to-day work and, furthermore, of electronic systems alone. Beyond such is a matter of course for a company that systems, we will always conduct ourselves with off ers innovative solutions in the fi eld of the required sensitivity. digitalization. Therefore, the protection of our infrastructure is equally important. Phoenix Contact 21

3 | Upon which principles are our actions based? 3.9 Integrity and fairness in business transactions We respect and protect the integrity of • We do not use our business connections for free competition. personal gain. • We fi rmly reject any type of business practices • We do not accept any corruption or bribery. that are designed to restrict free competition. In particular, this includes accepting or granting To this end, we fully subscribe to the unjustifi ed benefi ts or monetary bribes. regulations of antitrust law in particular. • When dealing with our business contacts, • We will also maintain respectful and fair we will avoid giving even the appearance of dealings with our competitors. This also corruption or dishonest business practices. applies to the way in which we promote Phoenix Contact. Phoenix Contact 23

3 | Upon which principles are our actions based? 3.11 Quality and product safety Our guiding principle is the satisfaction • Of course we comply with all relevant product of our customers and their pleasure in safety laws and the directives and standards working with us. This does not just apply embedded in them. This is how we ensure to the quality of our products. both the high quality of our products and solutions and their compliance with all relevant • We set high standards for the products and international regulations and standards. solutions that we off er. We do not focus on • We also aim to ensure a comprehensive quality alone, but also include innovation – and eff ective quality management system which we consider to be a ground-breaking that reaches from our production processes bridge to the future. We create solutions that and the business processes involved to our do not merely satisfy – they inspire. aftersales services. • Our customers have the right to source high- quality and fl awless solutions and products from us. We consistently align our processes with this goal. Here, the safety of our products in particular is very important to us. Phoenix Contact 25

3.12 International trade Our success is based on global • We ensure that our international business collaboration and the exchange of activities do not violate any of the relevant goods all over the world. When trading regulations. internationally, we comply with national • In foreign trade, we always check for possible and international regulations. restrictions or prohibitions based on country embargoes, for material-related sanctions (dual-use), and for any critical end-use of our products. • We also ensure that all business partners are vetted using the applicable sanctions lists for both domestic and international transactions. 3.13 Protection of information and expertise Information and expertise are the • Information, expertise, and intellectual cornerstones of corporate success. Both in property play a very important role in the relation to ourselves and to third parties. success of corporate activities. We therefore place significant importance on the necessary diligence when dealing with the relevant information and take appropriate protective measures. • In particular, we adhere to the regulations relevant to the transfer of information, as well as to the obligation to maintain confidentiality with regard to operational and business secrets as laid out, for example, in our know-how protection policy. • We also respect the confidential information, expertise, and intellectual property of third parties. 26 Phoenix Contact

4 | Your contact options Iceland Finland Norway Sweden Denmark Estonia Latvia Lithuania Ireland United Kingdom Belgium Netherlands Poland Blomberg, Germany Luxembourg Czech Republic France Austria Slovakia Ukraine Kazakhstan Mongolia Spain Portugal Morocco Algeria Italy Tunisia Switzerland Slovenia Croatia Bosnia and Herzegovina Hungary Moldova Romania Serbia Kosovo Montenegro North Macedonia Greece Cyprus Egypt Ghana Nigeria Cameroon Uganda Kenya Tanzania Zambia Mozambique Mauritius Namibia Zimbabwe Botswana South Africa South Korea Japan China Pakistan Bangladesh Taiwan, China Bulgaria Georgia Uzbekistan Turkey Armenia Azerbaijan Lebanon Iraq Israel Kuwait Jordan Bahrain Qatar Saudi Arabia UAE Oman India Sri Lanka Myanmar Thailand Philippines Malaysia Vietnam Singapore Indonesia Australia New Zealand Canada USA Mexico Dominican Republic Guatemala Honduras Nicaragua Costa Rica Panama Colombia Ecuador Peru Trinidad and Tobago Venezuela Brazil Bolivia Paraguay Chile Uruguay Argentina Do you have questions about the Within the framework of our open Code of Conduct of the Phoenix Contact communication culture, we should fi rst Group? Do you need help in evaluating a attempt to address our concerns directly with particular issue? Do you have a particular a matter-of-fact approach. Of course, this will concern in connection with the topics described not be possible in all cases because selecting the or with something further? suitable contact option really depends on the We want to put you in touch with the nature of the individual concern. The contact appropriate contact option for any concern. option you select should, ultimately, be your own decision. Phoenix Contact 29

4.1 Your contact options at Phoenix Contact Our management team and The HR department Executive Board Contacts for a large number of issues are You can approach your line management team available in the Corporate Human Relations with your concern at any time. Further, you can department. Key points are available on the also voice your concern to our Executive Board. corresponding Intranet page. The compliance organization Corporate Facility Management If there is already a local compliance management Corporate Facility Management is available team for your area, it is available as a contact for any questions or concerns regarding option. Centrally, you can contact Corporate environmental protection and ecology. Compliance Management. The whistleblower system The Legal department Phoenix Contact off ers a whistleblower system Particularly in cases where legal advice is needed, that can be used in particular to report potential you can also contact our Legal department. violations of legal regulations. Our whistleblower system is also available as a complaint procedure in accordance with the GSCA. Product Compliance The Product Compliance department is available to answer any questions you may have regarding product-related legal regulations. 30 Phoenix Contact The Executive Board (from left to right): Axel Wachholz, Torsten Janwlecke, Frank Stührenberg, Dr. Frank Possel-Dölken, Dirk Görlitzer, Ulrich Leidecker