Approved for publicationTLP:CLEAR

PPM High Purity Metals GmbH

Compliance and Ethics Guidelines

As at7 September 2026
PPMHigh
Purity
Metals

1. Human Rights and Working Conditions

PPM High Purity Metals GmbH respects and observes human rights at every level of the organisation. Any kind of discrimination based on gender, age, origin or nationality, mental or physical disability, sexual orientation, religious or political views, or trade union involvement is prohibited. Ignorance and inaction are no justification for any kind of discrimination. Therefore, any violation of human rights and discrimination will not be tolerated. Any moral, sexual, or generally unlawful attempts at intimidation, bullying, harassment, and victimisation are prohibited. We ensure equal opportunities for all in terms of career and work opportunities, working relationships, and job offers. The human resources management and employee relations are based on the principles of mutual trust and respect, which ensures that every employee is treated with the natural level of dignity. In compliance with local regulations, trade union independence, and the pluralistic organisation of industrial relations, a social dialogue is conducted with employee representatives. It goes without saying that the company and its employees comply with the applicable rules on employee privacy.

2. Data Protection

Data is only collected and stored by PPM High Purity Metals GmbH to the extent that is necessary for the smooth running of the business, health and environmental protection, and the fulfilment of legal requirements.

The company reserves the right to make data available to external service providers if this is necessary for the provision of the services. The data provided for this purpose is reduced to a minimum.

The data collected will not be used commercially by anyone other than the company. In particular, the company excludes the forwarding of collected data to third parties for advertising purposes.

Further details on the handling of your data can be found in our Privacy Policy.

3. Prevention of Crime

When working for PPM High Purity Metals GmbH, all employees must comply with the criminal laws of the countries in which the Group operates. Employees working on behalf of the company must exercise particular care if they transfer discretionary powers to third parties (where this is permitted), ensuring that the persons appointed are well informed and are aware of their obligation to comply with applicable laws and company policies.

Employees acting on behalf of the Company shall refrain from any involvement in any alleged or actual criminal conduct. All employees must be sufficiently aware of the criminal laws and regulations applicable to their area of work so that they can identify or prevent potential risks and recognise in which cases (namely financial, environmental, or safety issues) legal advice is required. Employees of PPM High Purity Metals GmbH who have questions or doubts regarding compliance with criminal laws or regulations for a proposed activity in one of the companies should immediately contact their superiors or the management.

4. Bribery and Corruption

Directly or indirectly secret or undocumented payments or accounts are not permitted under any circumstances.

Direct or indirect payments and expenditures for purposes unrelated or only partially related to the supporting documents for these transactions will not be authorised or made.

Activities and transactions on behalf of PPM High Purity Metals GmbH are to be carried out in compliance with the applicable regulations and internal procedures, and must be fully, accurately, and truthfully recorded in the company's books.

Employees who record accounting data are responsible for the accuracy of the data recorded and must ensure that each entry is properly documented. All transfers of funds require employees to be particularly conscientious and vigilant with regard to the identity of the recipients and the intended use of the transfer.

5. Competition Violations

All employees of PPM High Purity Metals GmbH are obliged to comply with the applicable laws and regulations concerning antitrust violations. This applies regardless of their validity in Germany or abroad. In connection with violations of competition law, the misconduct of a single employee may involve themselves, their direct supervisors, the management, and the company in difficult and costly administrative or legal proceedings, including injunctive relief, high fines, and, in some jurisdictions, imprisonment in the worst case.

With regard to competition law infringements, the laws and regulations are based on the principle that free competition without any collusion between competitors best serves the public interest. The participation in agreements or arrangements in violation of applicable laws and regulations, namely in the area of anti-competitive behaviour, is therefore strictly prohibited.

In particular, agreements, arrangements, or procedures with the aim to:

  • fix, directly or indirectly, prices, discounts, or conditions of sale;
  • restrict or control production, technical development, or investment;
  • divide markets, customers, or sources of supply among themselves;
  • treat business partners unequally, to impose conditions on them that are contrary to commercial practice, or to refuse to do business with them for unlawful reasons.

If, in the course of their work, employees of the Company are in doubt as to whether they are complying with regulations in connection with anti-competitive behaviour, they are required to contact the management immediately.

PPMHigh
Purity
Metals
PPM High Purity Metals GmbHHoppenstedter Straße 6 · 38835 Osterwieck · Germany