Rules of procedure (Section 8 (2) LkSG) for PSI-Group (located in Germany)

1. What is the purpose of these rules of procedure?
   On January 1, 2023, the German Act on Corporate Due Diligence to Prevent Human Rights Violations in Supply Chains (Lieferkettensorgfaltspflichtengesetz - LkSG) came into force in Germany. The aim of the law is to improve the protection of human rights and the environment in companies' own business areas - including the PSI-Group - and along the corporate supply chain. To this end, the law has also established a series of due diligence obligations for us. Among other things, the LkSG requires companies to have an appropriate complaints procedure in place through which both internal (i.e. employees) and external persons (such as suppliers) can contact us to report human rights and environmental risks or violations. In addition, companies must publish a grievance policy that describes the grievance procedure in more detail.
2. What is the function of the complaints procedure?
   The complaints procedure should fulfill two functions:
   a) Firstly, the complaints procedure should serve as an early warning system to enable us to identify problems in the supply chain at an early stage and ideally to resolve them promptly, especially before people or the environment are actually harmed.
   b) On the other hand, we can be made aware of imminent or existing violations of legal interests via the complaints procedure. The company can then take effective remedial action.
3. For which companies of the PSI-Group apply these Rules of Procedure?
   These Rules apply for all German PSI-Group companies, these are in particular:
   
   • PSI Software SE
   • PSI Automotive & Industry GmbH
   • PSI Energy Markets GmbH, Hannover
   • PSI FLS Fuzzy Logik & Neuro Systeme GmbH
   • PSI GridConnect GmbH
   • PSI Logistics GmbH
   • PSI Metals GmbH
   • PSI Metals Non Ferrous GmbH
   • PSI Transcom GmbH
   • PSI Prognos Energy GmbH

4. What can be reported?
   The complaints procedure can and should be used to draw PSI's attention to human rights or environmental risks or violations in our own business area and in our supply chain. The term "supply chain" is broad and includes both direct suppliers of PSI, with whom PSI has a contractual relationship, and indirect suppliers, i.e. the "suppliers' suppliers".
   The most relevant human rights and environmental risks are in particular:
   
   • All forms of slavery, economic exploitation and forced or child labor;
   • Endangerment or violation of occupational health and safety regulations, for example due to inadequate safety standards, lack of protective measures or insufficient training and instruction;
   • Unjustified unequal treatment in the employment relationship, for example due to national or ethnic origin or gender;
   • Violation of minimum wage regulations;
   • Improper storage or disposal of hazardous waste.
     

   The above list is for clarification purposes only and is of course not exhaustive.
   NOTICE:
   If you wish to draw attention to risks or injuries, it is better in case of doubt to provide the information and leave the assessment of whether the information falls within the scope of the law to the responsible team in the PSI.

5. Who can make use of the complaints procedure?
   Firstly, all PSI employees can make use of this complaints procedure. In addition, it is also open to external persons, e.g. our direct and indirect suppliers and their employees. People who are not directly affected by risks are also expressly free to use the complaints procedure. Use of the complaints procedure is therefore free of charge.
6. To whom / where can I address my complaint?
   The PSI-Group has appointed a Human Rights Officer for the German companies who is responsible for introducing and monitoring the requirements of the Supply Chain Due Diligence Act. She is therefore also the office that receives your reports and follows them up. The Human Rights Officer can be contacted as follows:
   Cornelia Adam
   Head of the Compliance Department
   Syndicate Lawyer
   
   PSI Software SE
   Dircksenstraße 42-44
   10178 Berlin (Mitte)
   Deutschland
   Telefon: + 49 30 2801-2721
   Telefax: +493028012312721
   menschenrechtsbeauftragte@psi.de
   
   You also have the option of submitting your comments via a multilingual contact form.
7. Am I protected against discrimination if I make such a complaint?
   Of course it is the case. This is an important concern for the PSI-Group. We will not tolerate discrimination in any form; if necessary, PSI-Group will take legal action against the person(s) who discriminates you because of the notice.
   The human rights officer is appropriately trained and will investigate your complaint impartially and independently. She is not bound by instructions and is obliged to maintain confidentiality.   All this guarantees a professional handling of your complaint, which minimizes the risk of your identity being inadvertently disclosed to unauthorized persons and thus also the risk of discrimination.
   You are also welcome to contact the Human Rights Officer after the procedure has been completed to ensure that you are not disadvantaged afterwards.
8. What happens after I have submitted a complaint?
   After submitting a complaint, you will first receive a confirmation of receipt. Afterwards, the Human Rights Officer respectively Compliance Department will check whether the subject of your complaint falls within the scope of the complaints procedure. If it does not, you will be informed of this, including a brief explanation.
   If your complaint falls within the scope of application, you will be informed promptly about the next steps and the likely timeline for the procedure. The Human Rights Officer will also discuss the facts with you in order to better understand your complaint.
9. Final provisions
   a) Review of the effectiveness of the complaints procedure
   The effectiveness of the complaints procedure is reviewed at least once a year and, if necessary, on an ad hoc basis. Findings and identified potential for improvement from the information received to the date and the respective procedures as well as from the risk analyses will be taken into account. The BAFA guidelines on the complaints procedure are taken into account.
   b) Languages
   These Rules of Procedure will initially be published in German and English. Other languages will follow after the risk analysis has identified further relevant target groups.
   c) Entry into force / Publication
   These Rules of Procedure shall enter into force on 01.01.2024 and shall be published.

PSI Software SE