Varta : Human Rights Policy

Human Rights Policy Statement

Dated: 1st December 2022

Scope and Responsibilities

VARTA AG and its affiliated companies1 (here after "VARTA") are committed to comply with human rights due diligence requirements, to strengthen human rights and to enable affected people to seek remediation in the event of a human rights violation. This applies to VARTA own operation globally as well as in the value chains. Across VARTAs own operation these values- both in its operating business and in exceptional activities, such as construction projects- are taken into account.

The overall responsibility for the strategic alignment for compliance and monitoring of human rights due diligence lies with the Executive Board of VARTA AG, including the procedures and allocation of resources for the implementation of the measures. The monitoring of the implementation of the strategy is the responsibility of those responsible for the respective locations. The relevant departments, in particular Sustainability, Human Resources and Quality, are responsible for the implementation and continuous further development of measures within the framework of the defined strategy. The Sustainability department is responsible for monitoring risk management regarding human rights due diligence. The strategy for implementing human rights and environmental due diligence is based on the following international frameworks:

• International Labour Organisation Conventions and Recommendations
• OECD Due Diligence Guidelines for Promoting Responsible Supply Chains of Minerals from Conflict- affected and High-Risk Areas
• OECD Guidelines for Multinational Enterprises
• Principles of the United Nations (UN) Global Compact
• UN Children's Rights and Business Principles
• UN Convention on the Elimination of All Forms of Discrimination against Women
• UN Convention on the Rights of the Child
• UN Declaration on the Rights of Indigenous Peoples
• UN Guiding Principles on Business and Human Rights
• UN Sustainable Development Goals
• UN Universal Declaration of Human Rights

Risk analysis and management

An initial risk analysis was conducted in 2022, considering the above-mentioned frameworks for the company's own operations as well as the upstream and downstream value chain. Besides country risks, industry-specific,company-specific, and product-specific risks were also taken into account. The analysis was based on studies by internationally operating organisations, information from recognised indices and experience gained during audits at VARTA and in its supply chain. In addition, ESG ratings are carried out regularly to identify and monitor further risks.

Working conditions

Compliance with human rights standards in the workplace, including the creation of healthy working conditions, sufficient breaks as well as appropriate working hours and fair pay, has a positive impact to the health and upkeep of the living standards of employees.

Occupational health and safety

Substantiated training and personal protective equipment of employees reduces safety risks and serves as measures against negative health effects when handling chemicals, machinery, metals, or minerals.

1 Affiliated companies of VARTA AG are all companies that are directly or indirectly controlled by VARTA AG. A complete list can be found in the current annual report.

VARTA AG | Human Rights Policy Statement

Soil, groundwater, and air pollution

Appropriate due diligence processes throughout the use of various substances in the context of raw material extraction and battery production contribute to the protection against contamination of soil and water as well as to the preservation of air quality and biodiversity.

Climate and energy-related risks

The implementation of measures to reduce the usage of climate-related resources in order to decrease greenhouse gas emissions and contributes to the mitigation of climate change.

Risks related to conflict and high-risk minerals

The establishment of a management system to respect human rights and environmental due diligence in mineral and metal supply chains contributes to mitigate existing and potential risks of these supply chains and to contribute to the respect and promotion of human rights, including the fight against child and forced labour and the empowerment of indigenous peoples.

Preventive and remedial actions

Operations

VARTA employees are committed to respecting and promoting human rights within their sphere of influence. VARTA has anchored the values and principles described in the international frameworks as guidelines in the VARTA Code of Conduct, which must be observed by all employees. This code also includes compliance with the requirements of the amfori BSCI initiative and the ten principles of the UN Global Compact. Employees receive regular training on the Code of Conduct and other compliance topics. Employees whose job responsibility relate to the supply chain have received dedicated training on dealing with human rights issues in the supply chain with a focus on procurement practices. The integration of sustainability criteria into procurement processes to continuously minimise risks is gradually taking place.

ISO 14001 certification of all production sites supports the promotion of environmental protection, reduction of environmental impacts, in order to ensure the implementation of environmental targets. Selected sites have ISO 50001 certification to further improve energy-related performance as well. VARTA is currently developing a water management concept and is working towards an EMAS certification. Moreover, VARTA is reporting to CDP to continuously enhance the environmental management system. Through various measures such as the switch to green electricity and energy efficiency measures, VARTA has already been able to reduce emissions significantly.

VARTA's management system for occupational health and safety is based on the requirements of ISO 45001. The alignment or commitment to collective bargaining agreements at all production sites as well as works councils at the German sites, are contributing to ensure good working conditions beyond legal requirements. Through external social audits of the five production sites globally, VARTA optimises its performance in occupational health and safety and decreases risks further.

So-called "conflict minerals" represent a particularly high sustainability-related risk. For this reason, VARTA monitors relevant actors in the supply chain for 3TG (tin, tantalum, tungsten, and gold) and cobalt. VARTA also strives for transparency for further critical minerals and products such as aluminium, graphite, copper, lithium, manganese, nickel, and zinc. VARTA has implemented a thorough due diligence management system in accordance with the OECD Due Diligence Guidelines for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas. Further details can be found in the due diligence report.

If a violation of a human rights or environmental duty has occurred or is imminent in VARTAs own operation, VARTA will take immediate and appropriate remedial action to prevent, stop or minimise the extent of the violation. The type and scope of the measures taken depend on VARTA's contribution to the cause and its ability to exert influence.

VARTA AG | Human Rights Policy Statement

Value chain

VARTA expects that the values put forth in this policy which are based on international frameworks, are supported and adhered to by all stakeholders, but in particular by the business partners as well as their business partners. Jointly with its suppliers, VARTA is aiming to work towards this target. For this reason, VARTA has integrated the VARTA Supplier Code of Conductinto its contracts and expects suppliers to commit to these principles and to pass the requirements onto their business partners. VARTA checks compliance with these principles by carrying out amfori BSCI audits on particularly high-risk suppliers. In the event of violations, appropriate improvement measures are initiated. In addition, sustainability issues are also checked at suppliers as part of quality audits. VARTA also obtains information about suppliers through queries in the supply chain and discusses possible potential for improvement and development on this basis. Training on human rights and environmental issues is provided to suppliers via the amfori BSCI platform.

To take responsibility at the raw materials level, VARTA has joined the Responsible Minerals Initiative (RMI). The RMI provides companies with resources and tools to support the responsible sourcing of minerals in the supply chain. The RMI platform also provides training opportunities for suppliers. In addition, VARTA assesses smelters and refiners, particularly in the 3TG and cobalt supply chain, through audits conducted in accordance with the RMI standard RMAP. In the future, VARTA aims to participate in RMI working groups.

If a violation of a human rights or environmental obligation has already occurred at a direct supplier or is imminent, VARTA will immediately take appropriate remedial measures to prevent or end this violation or to minimize the extent of the violation. If termination of the breach is not possible in the foreseeable future, VARTA will develop a scheduled plan to terminate or minimize the breach. In the event of a very serious breach, agreed measures do not provide a remedy, no mitigating means are available and/or VARTA's ability to exert influence is insufficient, VARTA reserves the right to suspend or terminate the business relationship. In the event of an identified or imminent violation of human rights at indirect suppliers, possibilities to develop a remedy on the part of VARTA will be examined. The type of the measures taken depend on the causation contribution and VARTA's ability to influence.

Grievance mechanism

Information on misconduct, in particular violations of applicable laws and internal instructions and procedures, can be reported via the anonymous whistle-blower system at https://varta.integrityline.org/. VARTA employees have the right to make complaints. Depending on their location of employment, VARTA employees further have access to other internal grievance tools, such as contact persons responsible for compliance, open mailboxes and works councils. Whistle-blowers are subject to special protection and have no fear of retaliation, discrimination, or intimidation as a result of their disclosure by VARTA.

Review of effectiveness and continuous development

The implementation of human rights due diligence is a continuous process which requires regular review. All measures described for the fulfilment of due diligence obligations, including the risk analysis as well as the policy statement itself, are subject to an annual and an ad hoc review (e. g. due to internal/strategic decisions, external factors, substantiated knowledge of possible violations at indirect suppliers, significant changes in the risk situation due to new products/projects, etc…). with regard to their topicality, effectiveness and efficiency and are revised if necessary. The review is based on in-depth knowledge and experience and is continuously developed with the involvement of various stakeholder groups and indicators. VARTA continuously monitors the impact of its business activities on respect for human rights and reports to employees and external stakeholders through this policy statement and other formats.

Documentation and reporting

For further information on activities to uphold and promote human rights please refer to the annual Sustainability Report.

Dr. Markus Hackstein	Rainer Hald	Armin Hessenberger	Herbert Schein
Speaker of the Board	Chief Technology Officer	Chief Financial Officer	Member of the Board

VARTA AG | Human Rights Policy Statement