Classification: Public

CODE OF CONDUCT
FOR CONTRACTORS AND
SUPPLIERS
 Classification: Public

Code of Conduct for Contractors and Suppliers

Code of Conduct

This Code of Conduct sets out the binding principles for compliant and responsible
behavior of the contractors and suppliers of the Nordex Group. The Code of
Conduct for Contractors and Suppliers will take effect from 01 May 2024.

VALIDITY
Global ☒ Europe ☐ International ☐
Countries //
Responsible department Sourcing Excellence and Governance
Owner Wim Geldhof
Author Elsa Schäfer, Ming Chua

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Code of Conduct for Contractors and Suppliers

Message to our Contractors and Suppliers 3

1. Code of Conduct for Contractors and Suppliers 4
1.1. Business Integrity 4
1.2. Quality, Health & Safety 4
1.3. Labor and Human Rights 4
1.4. Environment 5
1.5. Conflict Minerals 5
1.6. Society 5
1.7. Supply Chain 5
1.8. General provisions 6
2. The Nordex Group Whistleblower System ”notify!” 7
3. Acknowledgement and Consent 8

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MESSAGE TO OUR CONTRACTORS AND SUPPLIERS

Dear Contractor, Dear Supplier,

At the Nordex Group, we are proud of our 35-year history of harnessing wind
power for a sustainable world. Our success is due to our passion, technical
expertise, and commitment to our core values of integrity, respect, colleagueship,
and ownership. As one of the world's largest onshore wind turbine manufacturers,
we have built a global reputation based on ethical and law-abiding practices.

Maintaining this reputation is essential to the trust placed in us by our customers,

shareholders, business partners, and the public. To ensure that we continue to do
the right thing in our day-to-day business and throughout our value chain, we are
committed to following the principles of Nordex Code of Conduct for own
employees: Code of Conduct Employees EN

Our Code of Conduct sets out the principles of a compliant and responsible
behavior for our contractors and suppliers in our supply chain. It serves as an
ethical compass for our business relationship with you, our supplier. By adhering
to these principles, you help protect our joint business and the community,
ensuring the long-term sustainable success of our relationship.

We ask you to take these principles of good conduct to heart and follow them in
your dealings with us. Thank you for your contribution to our joint success.

Sincerely yours,

Wim Geldhof

Chief Procurement Officer

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1. CODE OF CONDUCT FOR CONTRACTORS AND

SUPPLIERS
Ethics determine our course. This summarizes the values under which Nordex SE
and the group of companies headed by Nordex SE in its capacity as ultimate parent
company (altogether referred to as “the Nordex Group”) are bound, based on the
principles of compliance, integrity and ethical behavior. They apply to all
employees, contractors, and suppliers.

As part of this, the Nordex Group expects from its contractors and suppliers
(hereinafter “supplier”) – throughout its complete business relationship with them
– integrity and ethical law-abiding behavior as well as strict adherence to the
principles set out in the United Nations Universal Declaration of Human Rights, the
United Nations Guiding Principles on Business and Human Rights, the International
Labor Organisation’s (ILO) core labor standards, and the ILO’s Declaration on the
Fundamental Principles and Rights at Work. This includes in particular:

1.1. Business Integrity

• Comply with all applicable laws and regulations.
• Do not tolerate, permit or engage in bribery, corruption associated with
state agents and private-to-private corruption, collusion, insider trading,
market manipulation or other stock market crimes, fraud, forgery,
counterfeiting, tampering, money laundering or any other illegal and/or
unethical practices.
• Support fair competition and avoid conflicts of interest.
• Comply with the use of institutional channels for communication with state
agents.

1.2. Quality, Health & Safety

• Maintain a suitable and systematic approach to Quality, Health, and Safety
(e.g., in accordance with ISO 45001/OHSAS 18001, ISO 9001, or national
equivalent), designed to ensure compliance with all applicable laws and
regulations and to achieve continuous improvement.

1.3. Labor and Human Rights

• Prohibit and refrain from any kind of forced labor, including any form of
forced or compulsory labor, slavery and modern slavery, human trafficking,
servitude, debt bondage, labor exploitation, verbal or physical humiliation,
violence or coercion, mental abuse, sexual harassment, threat or
intimidation, and any other abusive working conditions.
• Prohibit and refrain from any kind of child labor.
• Prohibit and refrain from disregarding the occupational safety and health
obligations.
• Comply with all applicable laws and regulations on freedom of association
and collective bargaining.

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• Promote equal opportunities and equal treatment.

• Do to not tolerate discrimination, harassment or retaliation.
• Fully comply with the applicable national statute on working time.
• Provide fair remuneration in line with the applicable national statute.
• Prohibit from unlawful eviction and unlawful taking of land, forests and
waters in the acquisition, development or other use of land, forests and
waters, the use of which secures the livelihood of a person.
• Prohibit from hiring or use of private or public security forces for the
protection of the enterprise’s project if, due to a lack of instruction or control
on the part of the enterprise, the use of security forces is in violation of the
prohibition of torture and cruel, inhumane or degrading treatment,
damages life or limb or impairs the right to organize and the freedom of
association.

1.4. Environment
• Comply with all applicable national and international environmental
regulations and standards.
• Maintain a suitable and systematic approach to Environmental management
(e.g., in accordance with ISO 14001 or national equivalent), and to achieve
continuous improvement.
• Reduce environmental impacts to a minimum. This applies in particular to
the production, use and disposal of mercury (as defined by the Minamata
Convention), persistent organic pollutants (as defined by the Stockholm
Convention) and hazardous waste (as defined by the Basel Convention).

1.5. Conflict Minerals

• Assess the usage of conflict minerals (at least those identified by applicable
EU regulation, currently tantalum, tin, tungsten and gold, see EU regulation
(EU) 2017/821) and investigate if they are sourced from conflict-affected
and other high-risk areas (CAHRAs).
• Establish due diligence measures to ensure the compliance with all
applicable regulatory requirements and to ensure that the sourcing of the
minerals does not directly or indirectly finance or benefit armed groups in
CAHRAs or is not connected to abuses of international law, including human
rights violations or environmental infringements.

1.6. Society
• Respect neighbors, local communities, and cultural heritage, and contribute
positively to the societies in which the supplier operates.

1.7. Supply Chain

• The Nordex Group expects from its suppliers that they ascertain that also
their own subcontractors and suppliers comply with the said principles set
out hereinabove.

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1.8. General provisions

• The Nordex Group expects from its suppliers to provide upon request
evidence of compliance with the requirements laid out in no. 1.1 to 1.7,
and/or supporting documents, in course of due diligence and/or verification
assessments.
• The Nordex Group reserves its right to change or supplement the
requirements of this Code of Conduct.

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2. THE NORDEX GROUP WHISTLEBLOWER SYSTEM

”NOTIFY!”
Committing to a speak-up culture, we have established the Whistleblower System
“notify!” based on principles of trust, confidentiality, good faith, impartiality, and
protection, with the purpose of encouraging and facilitating the reporting of any
form of compliance violation related to the Nordex Group’s business activities and
its authorized representatives.

Every Nordex Group representative, external stakeholders – including the

employees of suppliers at any stage of the supply chain – and the general public,
be they personally concerned or not, can submit a report via “notify!”. This
Whistleblower System is open to all types of compliance violations, irrespective of
topic. In addition, you can also submit observations of risks or violations regarding
human rights, or environmental topics in case they are related to the Nordex
Group or its supply chain.

The following contact options are available:

• Online portal: Web-based publicly accessible portal that can be accessed

24/7, 365 days a year from any computer with internet connection.
Available in all company languages. Reports can be made anonymously, and
full data security is guaranteed.
• Helpdesk: Direct dialogue via telephone, e-mail or post.
o Phone: +49 (0) 40 30030 3030. Can generally be reached on
weekdays from 9:00 a.m. to 5:00 p.m. (CET).
o E-mail: notify@nordex.whistleblowermail.com
o Post: Nordex SE, Corporate Compliance, Langenhorner Chaussee
600, 22419 Hamburg, Germany.

We guarantee legally compliant processing of any reports, confidentiality at all

levels, and effective whistleblower protection from retaliation, provided that the
report is submitted in good faith. Any form of retaliation will be punished
appropriately and could even lead to dismissal. The presumption of innocence and
the rights of defense apply. Where this is not restricted by country-specific
regulations, reports can be submitted anonymously.

All personal data is processed in accordance with the European General Data
Protection Regulation (GDPR) and applicable local data protection regulations.

Further information on the Whistleblower System “notify!” can be found on the

Nordex homepage under “Whistleblowing – Nordex Group Whistleblower System”.
Furthermore, under the same section, you can find the “Rules of Procedure for the
Complaints Procedure pursuant to the German Supply Chain Act” which elaborates
on reporting concerns related to human rights and environmental violations.

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3. ACKNOWLEDGEMENT AND CONSENT

By signing this document, the supplier confirms acceptance of the Supplier Code
of Conduct with the stated principles/requirements and will act responsibly
accordingly. The supplier is also responsible for ensuring that their employees,
agents, suppliers, subcontractors, and service providers understand the contents
of the document and take necessary measures to implement the requirements.

Place, Date Signature / Function

_______________________ ____________________________

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