Rules and standards form the basis for fair and peaceful cooperation. Our ethical principles are binding for us and our partners. Information about violations of these principles of interaction helps us to recognize and correct misconduct at an early stage and thus prevent damage to the company and our partners.

We, the Sennheiser Group, would like to encourage both employees and employees of affiliated companies to contact us if they have a concrete suspicion of violations of rules in connection with the Sennheiser Group and to report them openly without fear of negative consequences.

Whistleblowers who report violations for a specific reason will be protected by us and their identity will be treated confidentially. Discrimination against whistleblowers is a violation of our ethical principles and will result in consequences under labor law. Although it is easier to process reports if you disclose your identity to our Compliance Office, we expressly point out that you can also submit reports anonymously. As a matter of principle, the identity of a whistleblower will only be disclosed internally if the whistleblower has given his or her consent.

What are the examples of rule violations?

In case of concrete suspicion, all rule violations can be reported. Examples of rule violations are:

• Cases of sexual harassment, discrimination, racism
• Violation of human rights
• Violations of physical and psychological integrity
• Corruption, embezzlement and theft offenses
• Violations of privacy and violations of data protection relevant under criminal law
• Violations of (technical) security guidelines, environmental templates, accounting and bookkeeping guidelines

How can I submit a report?

In order for your report to be processed by our Compliance Office in a target-oriented manner, it is important that the tip is as specific as possible. Please note the following information in your message

• Your contact details or anonymously without feedback
  • Name, telephone, e-mail address, etc.
• When did it happen?
  • Date, time, duration, frequency
• Where did it happen?
  • Country, location, plant, etc.
• Who acted?
  • e.g. names of the persons involved
• What happened? (necessary information)
  • Exact description of the suspicious incident, the circumstances and the general conditions
• Who else besides you noticed the suspicious behavior?
  • Witnesses, name, tel. no., e-mail address, etc.
• Further information
  • If necessary, please use this field to provide us with additional information (e.g., motivation of the individual, regulation that the individual violated, etc.).

How and by whom is a tip processed?

All reports are accepted and evaluated by the employees of our Compliance Office. If a tip relates to violations of applicable law, the content is legally reviewed. If an initial suspicion is substantiated, the appropriate measures are taken. If the Compliance Office assigns the processing to an internal or external unit, the whistleblower will be informed in advance, provided that his or her identity is known.

The Compliance Office acts on the basis of the GDPR when processing a whistleblower. The relevant information on data protection at Sennheiser can be found here https://en-de.sennheiser.com/privacy. All notices are taken seriously and processed thoroughly and systematically. Naturally, those affected will be given the opportunity to comment as soon as this is possible.

The employees in the Compliance Office follow each case through to its conclusion. All personal data collected in the course of the process is deleted once the process has been completed. Only data required for anonymous reporting is retained.

As long as violations have not been proven, the presumption of innocence applies to the persons concerned. We attach importance to the fair treatment of whistleblowers and those affected and always maintain the proportionality of our measures.

What happens when my tip is finally processed?

The person affected by the allegation and his or her manager will be informed in writing of the results of the investigation. The whistleblower, unless he or she remains anonymous, will also be informed of the case closure and the final decision.

If the allegations are unfounded, the person concerned will be rehabilitated on request.

Personnel measures are taken in accordance with the principle of proportionality. In the event of misconduct by a business partner, appropriate consequences will also be applied in accordance with the principle of proportionality.

In addition to other criteria, the following aspects play a role in our assessments:

• Type and severity of the rule violation
• Intent or negligence
• Amount, reversibility and probability of occurrence of the damage
• Attitude of the person concerned to the violation
• Cooperation or reparation
• The Sennheiser Group's ability to influence the business partner
• Specific personnel measures taken by our company are based on local law, but may include both disciplinary and labor law measures depending on the severity of the violation.
• We reserve the right to file criminal charges in the event of identified criminal offenses

Does the Sennheiser Group report on results and tips?

As part of our activities on socially and ecologically sustainable business practices, we also report annually on the results of the whistleblower system in an anonymous manner.

Whistleblowers and other third parties have the right to take legal action before the national courts. In particular, the submission of a whistleblower's report on legal violations and breaches of rules does not constitute a waiver of any existing right to take legal action. We maintain confidentiality in the course of our investigations. It goes without saying that we cooperate with the state prosecution authorities.

If you have any information, you are welcome to contact the employees of our Compliance Office via the following contact addresses or call the Legal Services department directly at +49 (05130) 600 0.

compliance@sennheiser.com

Sennheiser electronic SE & Co. KG

Am Labor 1

30900 Wedemark