Compliance Principles

Compliance Statement

We understand compliance to mean fulfilling both legal requirements and internal company standards.

The export sector is subject to strict regulations. These complex rules present a significant challenge for management, leaders, and staff. Consequently, our goal must be to ensure that our business operations are legally sound and ethically sound.

To this end, the management has initiated a process aimed at establishing a compliance management system. This process is currently underway. As a first step, the shareholders have defined core values for our compliance culture (ethical principles). Furthermore, compliance principles for export operations have been established.

At an extraordinary general meeting, the shareholders declared the framework strictly binding.

MLW is committed to anti-corruption. Therefore, the Federal Government’s Directive on Corruption Prevention in the Federal Administration of July 30, 2004, is also binding. The directive can be found here (in German):

http://www.verwaltungsvorschriften-im-internet.de/bsvwvbund_30072004_O4634140151.htm.

The management holds ultimate responsibility for compliance, supported by an external Compliance Officer.

Export and Trade Ethics

Preamble

Founded in October 1991, our company began its journey at our traditional location in Schicklerstraße, in the very heart of Berlin. Transitioning into a market-driven economy, free from planned targets, inspired deep reflection on the massive changes of that era. As outdated symbols faded alongside much of what was familiar, the drive to anchor the company and its people within a clear system of values deeply shaped the spirit of the times.

In a company profile from our initial phase—parts of which are still preserved today—MLW intermed established a key maxim: the synthesis of preserving tradition while embracing new entrepreneurial dynamism.

This foundation was reinforced by the following core principles:

- in the heart of Berlin – building something new at the traditional site!

Since 1968, MLW has stood as a recognized and globally registered trademark, representing the international reach of East German Medical, Laboratory, and Weighing technology products.

Until 1990, more than 500 employees of the former state-owned foreign trade enterprise (AHB) MLW intermed-export-import ensured worldwide exports of capital goods and materials for healthcare, research, and education from the GDR. Its radius of operations extended from Russia's Far East regions to Chile, and from Canada to New Zealand.

In October 1991, 20 former AHB employees took the leap and made a fresh start in the global export business. We critically reviewed our traditions and found the following to be worth preserving:

- MLW intermed operates as a globally protected wordmark and figurative mark;

- an appreciation for an industry- and user-oriented business philosophy;

- the utilization of a number of well-established markets, particularly overseas;

- highly specialized know-how in export credit business;

- direct access to trusted supply, sales, and service partners worldwide

The foundation for the successfully achieved start into our future was the trust built in the past in the reliability of those individuals who represented MLW intermed both internally and externally.

During this time, the idea was born to define corporate principles for MLW intermed. This trend was amplified by a unique feature of MLW intermed GmbH: we started with 20 employees who were also equal shareholders. This dual role inherently required a sense of equality among everyone involved, although responsibilities were naturally weighted differently based on each specific function.

Driven by this environment, but above all in the interest of a stable and economically successful corporate development with a clear focus on the challenges of the present and future, our

Corporate Values: What We Aim to Stand For

Two key aspects deserve mention as an introduction:

First, it was essential to highly motivate all employees based on their tasks and challenges. The aim is to unleash their creativity and use available resources effectively. We believe a binding corporate culture with shared guidelines fosters relationships both internally and with external partners like customers, suppliers, and service providers. Moreover, since our business focuses heavily on exports worldwide, it is crucial to treat people from diverse cultural backgrounds, mentalities, and characters with the utmost respect.

Therefore, what matters to us is:

- to always encounter every individual with dignity, respect, appreciation, and value;

- to act honestly, reputably, responsibly, and fairly in every situation;

- to aim for a measurable positive impact on the people in the countries and regions where our projects take place;

- to guarantee transparency and equal opportunities for all. We reject any form of corruption and discrimination;

- to promote motivation, personal responsibility, cooperative behavior, and mutual understanding across all areas;

- to create a trusting working atmosphere in which every individual can optimally contribute and develop their strengths;

- to collaborate with our contractual partners on the basis of mutual trust, equality, and fairness, applying the same standards that govern our internal company practices.

Code of Conduct: How We Bring Our Values to Life

We measure our daily commitment by how well it supports the company and its employees, while aligning with the interests of our shareholders.

Our shareholders took the risk of engaging in entrepreneurial activity with their investment. We bear a special responsibility toward them, as their commitment safeguards our jobs.

We foster our employees' engagement and individual competencies. We consider collaborative results to be especially resilient. We will address both strengths and weaknesses. Consequently, personal growth within the company is guided by following these principles. Our staff will also represent and maintain these values in public.

These principles are accessible to all staff members and strictly binding for everyone. Our management is committed to implementing these standards and bringing them to life every day. We ensure our principles remain clearly defined and continuously evolve. If you notice any potential violations, or if you have any questions or uncertainties, the Compliance Officer is your first point of contact (anti-corruption@ra-liese.de). They are subject to a strict duty of confidentiality.

Compliance Violations

Adherence to these principles is highly significant. We take a firm stand against any breaches of these standards. If there is a risk of negative or harmful consequences for our company, this may lead to consequences under employment law.

Compliance Principles for Exports

General Principles

MLW intermed Handels- und Consultinggesellschaft für Erzeugnisse und Ausrüstungen des Gesundheits- und Bildungswesens mbH (MLW) is highly committed to adhering to all applicable laws and regulations regarding export and trade in every country where we operate. These include laws on trade embargoes, economic sanctions, export controls, anti-corruption, cargo security, and free trade agreements. For cross-border business, all MLW employees are required to know and follow these legal requirements alongside MLW’s own trade policies, standards, and procedures. Since these legal provisions are complex and change frequently, employees must consult the MLW Compliance Officer to guarantee full compliance. If any MLW guidelines ever contradict local laws, the law always takes precedence.

Objective

MLW is globally active, with exports frequently going to various countries. These principles serve to guarantee that MLW adheres to all applicable laws and regulations governing cross-border export and trade. These guidelines apply to all employees worldwide.

Additional Information

• Anti-corruption laws strictly forbid all types of bribery. Regardless of local business customs or practices, MLW employees are prohibited from offering, giving, or accepting bribes, kickbacks, corrupt payments, facilitation payments, or unsuitable gifts involving government officials or legal entities. MLW acknowledges the Directive of the Federal Government on Corruption Prevention in the Federal Administration, dated 30 July 2004, and adopts it as binding, provided that MLW’s organizational structure as a GmbH does not prevent this. The directive is available here (in German): http://www.bmi.bund.de/SharedDocs/Downloads/DE/Themen/OED_Verwaltung/Korruption_Sponsoring/Richtlinie_zur_Korruptionspraevention_in_der_Bundesverwaltung.pdf.
• Employees should be aware that applicable laws and regulations may vary from country to country. In this context, employees are defined as those individuals who participate in foreign trade operations.
• These MLW principles incorporate the laws and regulations of numerous countries, alongside MLW’s management strategies, organizational structure, and key corporate values. Consequently, MLW’s guidelines frequently establish a higher standard than what is legally mandated. In these instances, employees are expected to follow MLW’s policies to guide their conduct.

Consequences of Non-Compliance

Failure to comply with legal export and trade regulations may result in criminal and civil penalties for MLW and potentially for individual employees. It can also cause severe operational disruptions and harm MLW’s reputation. Breaches of MLW’s Code of Conduct can lead to disciplinary measures up to the termination of the employment contract.

The management holds ultimate responsibility for compliance, supported by an external Compliance Officer.

Our Commitment to Data Privacy

Data privacy is a core priority for MLW intermed. Consequently, our website is operated in strict accordance with the applicable data protection and data security laws, specifically the provisions of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG), and the Telecommunications Digital Services Data Protection Act (TDDDG). For more detailed information, please refer to our Privacy Policy www.mlw-intermed.de/datenschutz.