As an industrial enterprise and an employer, we are aware of our significant responsibility toward

- the areas surrounding our production sites,
- the environment, whose resources we use,
- the customers, whom we want to convince daily with our performance and service,
- the many partners who support us in the process,
- our employees, whose ideas and energy enable our success in the first place.

In order to fulfil this responsibility, we have developed common guiding principles and defined them in our Code of Conduct.

The Code of Conduct summarizes the common values that serve as our compass. It defines principles that we can implement in daily life. It establishes binding guidelines where legal provisions dictate our actions.

Our company's values are PRIMA:

Performance,
Responsibility,
Integrity,
Mutability,
Appreciation.

Observing our company's values (PRIMA), legal provisions and internal guidelines holds great significance at Aurubis, as illegal conduct can cause considerable damage and lead to offense proceedings or criminal proceedings. Furthermore, there is the danger of harming the company's reputation and thus its market position.

The term "compliance" refers to conduct that is consistent with specific requirements. These include laws, regulations and internal company guidelines, e.g. a code of conduct or ethics.

Since the Aurubis Group acts through its employees, every employee is obligated to follow applicable laws. Internal Group conduct guidelines (e.g., Code of Conduct, Compliance Guideline, Anti-corruption Guideline) provide employees with standards for lawful conduct. The principles formulated in these guidelines apply in particular to interactions with customers, suppliers, other companies, shareholders, authorities, employees and supervisors and include adherence to anti-discrimination provisions, product and occupational safety regulations and environmental protection, in addition to prohibiting anti-competitive behavior and corruption.

Observance of legal provisions and conduct guidelines is ensured by three factors: prevention, monitoring and sanctions. Preventive measures include internal guidelines, consultation and especially employee training. For example, employees regularly participate in training related to antitrust and environmental law issues. Corporate auditing has a monitoring function. It verifies whether provisions and internal guidelines are being observed. If breaches of the law or internal guidelines are discovered, sanctions come into effect under labor law, civil law or even criminal law.

Aurubis has appointed a Chief Compliance Officer (CCO) in order to better fulfill the extensive requirements resulting from legal standards and conduct guidelines. The CCO is the central contact for all questions relevant to compliance and is responsible for further incorporating the issue of compliance into the company culture. He ensures that the same rules apply to all employees in the Group.