This policy sets forth the principles and procedures for reporting concerns regarding potential or actual violations of laws, regulations, or internal policies of SINNLA Holding Deutschland oHG, hereinafter SINNLA. It serves to implement EU Directive 2019/1937 and the German Whistleblower Protection Act. The objective is to encourage whistleblowers to raise concerns in good faith without fear of retaliation and to establish a clear, confidential process for the investigation of such reports.

The group of persons entitled to report includes all natural persons who have obtained information about violations in connection with their professional activities for SINNLA. This specifically includes: a. Employees, including temporary workers and trainees b. Former employees c. Applicants d. Independent service providers, freelancers, and contractors e. Suppliers and their employees f. Shareholders and persons in management bodies

Reasonable suspicions or knowledge of actual or potential violations concerning SINNLA may be reported. The substantive scope particularly includes: a. Criminal offenses such as corruption, fraud, theft, or money laundering b. Violations of regulations protecting personal data c. Violations of environmental, health, and safety regulations d. Violations of antitrust and competition law e. Violations of accounting and financial reporting regulations f. Serious forms of discrimination, harassment, or bullying g. Any other act or omission constituting a violation of applicable EU law or German law

SINNLA provides an internal reporting channel that safeguards the confidentiality of the whistleblower's identity and of third parties mentioned in the report. We encourage you primarily to use this internal channel as it enables a swift and effective investigation and remediation. Internal reporting channel: Email: compliance@sinnla.com Postal address: SINNLA Holding Deutschland oHG, Attn. Internal Compliance Reporting Office, Ortsstraße 125, 07368 Liebengrün, Germany Upon request, a report may also be made during a personal meeting. Please contact us via one of the above channels to arrange an appointment. External reporting channels: Without prejudice to internal reporting, you have the right to contact the competent external reporting offices of the federal or state authorities as well as the competent bodies of the European Union.

Upon receipt of a report, the following strictly confidential procedure shall apply: a. Acknowledgment of receipt: The whistleblower shall receive confirmation of receipt of their report no later than seven days after submission. b. Review and validation: The internal reporting office shall examine the credibility of the report and whether the reported violation falls within the substantive scope of the law. c. Investigation: If the report is deemed credible, appropriate follow-up measures shall be taken. This may include initiating internal investigations, interviewing involved parties, or engaging external experts. d. Feedback: The whistleblower shall receive feedback no later than three months after the acknowledgment of receipt regarding the planned and already taken follow-up measures and the reasons therefor.

SINNLA undertakes to protect whistleblowers who report in good faith from any form of retaliation. The following are expressly prohibited: a. Termination, suspension, or non-renewal of contracts b. Demotion or denial of promotion c. Disciplinary measures, salary reductions, or reassignment of duties d. Bullying, exclusion, or any other form of disadvantage Any person who violates this prohibition of retaliation shall face labor law and disciplinary consequences. Whistleblowers who experience retaliation should report this immediately to the internal reporting office or management.

The identity of the whistleblower as well as all persons who are the subject of a report shall be treated with strict confidentiality. Access to this information is limited to a narrowly defined circle of authorized persons responsible for handling the report. All personal data processed in connection with a report are subject to the strict provisions of the General Data Protection Regulation and shall be used exclusively for the purpose of clarifying the reported matter and stored securely.