ZF Business Partner Principles

Introduction

These Business Partner Principles define the minimum requirements and fundamental principles that ZF expects all business partners to adhere to when operating with ZF or its affiliates. ZF reserves the right to suspend or terminate business relationships with partners who do not comply with these principles or applicable laws. These principles align with national and international laws and conventions, including the UN Global Compact, OECD Guidelines for Multinational Enterprises, the Universal Declaration of Human Rights, UN Guiding Principles on Business and Human Rights, and ILO conventions.

Business partners of ZF are natural or legal persons from whom ZF acquires products or services, or to whom ZF sells products or services. This includes suppliers, customers, commercial agents, representatives, intermediaries, consultants, or other product and service providers.

ZF business partners must:

• Conduct business with integrity, in compliance with all applicable laws, and implement the values and basic principles defined in this document.
• Ensure that these principles are also implemented throughout their supply chain.

Combating Corruption and Money Laundering

ZF does not tolerate any form of bribery or commercial conduct that could create an impression of impropriety or undue influence. This applies without exception, regardless of alleged local customs or practices.

During business activities with ZF, business partners must not directly or indirectly accept, offer, or grant tangible or intangible advantages (such as donations, invitations, or other gratuities) to or from the ZF Group, public officials, or third parties if these advantages are intended to unfairly influence business processes, expedite or carry out an official action (facilitation payments), or if they create such an impression. ZF expects its business partners to ensure their employees act with integrity, especially in dealings with public officials and government agencies.

Money laundering is understood as the process of integrating assets from illicit sources or illicit business activities (e.g., drug trafficking, theft, tax evasion, corruption, etc.) into the legal, financial, or economic circulation with the aim of concealing or disguising the illicit origin of the assets. ZF strives to combat money laundering and expects its business partners to do the same by adopting appropriate measures to ensure compliance with current national and international norms and laws.

Fair and Free Competition

ZF unequivocally upholds the principles of fair and free competition as a fundamental part of the market economy. Consequently, business partners commit to respecting applicable legal provisions concerning antitrust and competition laws. ZF expects all its business partners to refrain from any action that aims to or results in the impediment, restriction, or distortion of fair and free competition.

Specifically, ZF does not tolerate:

• Anticompetitive contracts, agreements, or conspiracies with current or potential competitors, including, but not limited to, agreements aimed at fixing prices or premiums, limiting the type, quantity, or quality of products or services delivered, bid rigging, customer allocation, or market division.
• Abusive use of a dominant market position.
• Vertical restrictions or contracts (with suppliers or customers) that establish, or actually achieve, the impediment or restriction of fair and free competition in violation of applicable laws.

Export Control

ZF business partners are expected, without exception, to strictly comply with all applicable international trade regulations and to adhere to rules and regulations for the control of imports and exports, including current economic embargoes.

Human Rights and Social Responsibility

Respect for the dignity, privacy, and personal rights of every individual is ZF's top priority. Therefore, ZF business partners must respect and comply with all applicable laws and internationally recognized human rights standards. Furthermore, they must ensure that human rights are respected, and particularly that human dignity is preserved in all business activities. ZF expects all business partners not to tolerate any form of human trafficking, forced labor, or child labor. Business partners must respect the minimum age for employment as established by the respective national labor legislation, and all labor services of business partners' employees must be provided voluntarily. Business partners must respect freedom of association and the right to collective bargaining within the parameters of the laws and regulations in their respective countries.

Business partners should actively strive to improve and promote human rights in their workplaces, prevent negative impacts on human rights, and, if necessary, eliminate problems.

ZF presumes that its business partners are aware of their social responsibility towards their employees, offering fair and appropriate remuneration and working hours. Business partners should also promote the qualification and training of employees to ensure a high standard of performance.

Equality in the Workplace

ZF does not tolerate any discrimination based on race, gender, religion, age, nationality, pregnancy, special needs, sexual or political orientation, and trade union activity, as well as other characteristics protected by applicable law, and expects its business partners to prohibit discrimination for such reasons.

Business partners must comply with and implement all applicable legal requirements for a safe and healthy working environment. ZF requires business partners to ensure that they and their employees take measures to ensure compliance with this legislation. ZF is committed to the health and safety of its employees and is dedicated to working towards the elimination of workplace accidents, and expects its business partners to do the same.

Environmental Protection

It is essential to respect the natural environment of our planet, protect resources, and reduce environmental pollution. Therefore, ZF requires its business partners to share the commitment to ecological product design, reducing the environmental impact of business processes, and continuously improving energy utilization and contributing to conscious climate management of their businesses.

Product Compliance

ZF adheres to the highest production standards and is committed to producing high-quality products that comply with both safety requirements and all applicable laws, regulations, and standards. ZF expects its business partners to maintain the same level and to supply products that are fully compliant with the same high level of quality and safety. ZF does not tolerate illegal or unethical conduct by its business partners concerning its products.

Use of Information and Data Protection

When conducting business with ZF, business partners must ensure that commercial, technical, and financial information, know-how, and trade secrets are duly protected regarding confidentiality, availability, and integrity, and are not disclosed without proper authorization and in compliance with applicable legal requirements.

Furthermore, it may be necessary for ZF business partners to demonstrate they have an advanced Information Security Management System in accordance with ISO27001 or TISAX, and they must protect data privacy rights in accordance with applicable laws in all business processes to prevent data protection violations and cyberattacks.

Communication of Possible Violations

ZF expects its business partners to report possible legal or ethical infringements that may affect ZF. The ZF Trustline can also be used anonymously, if desired. (www.bkms-system.net/Trustline)

Business partners of ZF must also have systems and controls in place to ensure that unethical and illicit business practices can be reported within their own company. ZF does not tolerate any retaliatory measures against individuals who report possible violations in good faith and expects the same from its business partners.

Cooperation with ZF

Trust and cooperation form the basis of the relationship between ZF and its business partners. Therefore, ZF has specific processes in place to ensure that its business partners comply with the core values defined in this document. ZF verifies its business partners to identify potential compliance and ethical risks. In this context, ZF has the right to request its business partners to provide adequate and useful support for these efforts, for example, by providing specific information.

Contact

For any questions regarding these Business Partner Principles and their implementation, business partners can contact the ZF Compliance department directly at any time.

Corporate Compliance
ZF Friedrichshafen AG
Löwentaler Straße 20
88046 Friedrichshafen
Email: compliance@zf.com