Table of contents

1. Preamble
2. Code of Conduct
3. What T-Union stands for
   • What makes T-Union special
   • We are T-Union
   • We share common values
   • Our values and basic principles
   • Openness, culture, risk transparent
   • Value diversity
   • Strong values
   • Comply (inter)national applicable law
   • Compliance is a mindset
4. Socially responsible
   • Our conduct and our responsibility as a member of society
   • Human rights and fair working conditions
5. Environmental and climate protection as well as ecological responsibility
   • Quality standards and product risk management
   • Sustainability in the supply chain
   • Social responsibility and social commitment
   • Political engagement and lobbying
   • Appearance and communication in public
   • Prohibition of corruption and bribery
   • Invitations and gifts
   • Avoidance of conflicts of interest
   • Fair competition: Compliance with antitrust and competition law
   • Data protection
   • Prevention of money laundering and terrorist financing
   • Trade compliance
   • Information security
   • Transparent financial and sustainability reporting
   • Tax and customs compliance
6. Confidential company and insider information
7. Occupational Safety and Health
   • Individual
   • Continuous improvement
   • Fair treatment and freedom from discrimination
   • Cooperation with employee representatives
   • Working hours
   • Remuneration
   • Use of external personnel
   • Protection of company property
   • Our responsibility to implement the Code of Conduct
8. Reporting possible misconduct
   • Bona fide
   • Direct contact
   • Reporting channel
   • Compliance investigations

1. Preamble

Our T-Union mission statement shows the way to act so that we can ensure the sustainable success of our company.

We all bear responsibility for T-Union. It is our common task to protect T-Union and maintain the trust of our colleagues, business partners, customers and our entire community. Our Code of Conduct forms the foundation for this. In particular, personal responsibility, openness and transparency as well as legally compliant and ethically correct conduct at all times play an important role.

Our Code of Conduct brings together our binding basic rules and principles. It thus provides important guidance for members of the Executive Board and management, leaders and all employees.

The Code of Conduct articulates the standards we set for ourselves within the T-Union and defines

how we want to treat each other. At the same time, it is a global commitment to act responsibly towards partners, society and the environment. The behavior of each and every individual at T-Union is important for our sustainable corporate success and the reputation of our T-Union.

2. Code of Conduct

The Code of Conduct is an expression of our shared values and basic principles.

Even if the Code of Conduct does not offer a solution for every situation, it still contains important information and guidelines for us to act in accordance with the rules, with integrity and in an ethically correct manner.

T-Union Regulations and Instructions contain specific rules and requirements for concrete workplace situations and circumstances. They are valid and binding for all T-Union employees without restriction. Employees who do not comply with these rules and requirements must expect appropriate consequences.

Our Code of Conduct summarizes the basic principles and rules that are important to T-Union. It reflects the standards we set for ourselves and for our business partners and stakeholders. It applies to all T-Union companies, employees, leaders and members of the management and the Executive Board.

3. What T-UNION stands for

 

• What makes T-Union special

T-Union is made up of around several individual international employees with different lifestyles and cultures. But what unites T-Union is that we are one team.

We work together, learn from each other and continue to develop together. We are fair. We respect each other and communicate openly.

We say what we do. And we do what we say.

This framework of values unites us and makes us successful. We have set out our values in our mission statement.

It expresses what T-Union stands for today and in the future. Our corporate success depends to a large extent on these values:

• We are T-Union

We create value for customers, partners, employees and shareholders. We meet the challenges of tomorrow together with our customers.

We are customer-focused.

We develop new services that create sustainable infrastructures and promote efficient use of resources.

We hold ourselves to the highest standards possible.

We engage as entrepreneurs, with confidence, a passion to perform, and courage, aiming to be best in class. This is based on the dedication and performance of every team member.

Employee development is especially important. Employee health and workplace safety have top priority.

• We share common values

We serve the interests of the T-Union. Our interactions are based on transparency and mutual respect. We build on strong values: Reliability and honesty, credibility and integrity. Compliance is a must have. We are responsible human beings.

• Our values and basic principles also apply to all our decisions, actions and

We act in the overall interests of T-Union and we protect and promote the reputation and values of T-Union. They are essential for our sustainable and long-term corporate success.

We are aware that unlawful or inappropriate behavior can cause considerable damage to our company. We are committed to meeting the high ethical standards set out in this Code of Conduct.

In the same way, we want to remain true to our values and basic principles, which we have laid down in the mission statement.

We intend to continuously improve and make T-Union more agile and adaptable with a view to future challenges.

• Openness, culture, risk transparent

We value openness, promoting a speak-up culture and making risks transparent in our respective areas of responsibility. Wherever people work, mistakes happen.

Dealing openly with mistakes enables us to rectify them, identify sources of error and take measures to prevent them from happening again. We therefore expressly encourage our employees to communicate openly whenever things are not going smoothly.

3.C. We value diversity

Diversity and inclusion are integral parts of our human resources strategy and culture. Our interactions are characterized by mutual appreciation and respect. A culture of mutual trust and respect is of great importance to us. We promote equal opportunities and do not tolerate discrimination. We want to create a working environment that is free from prejudice. Any form of discrimination, harassment or bullying is contrary to the values and basic principles of T-Union.

• T-Union builds on strong values: reliability and honesty, credibility and integrity

We are role models and keep our promises. We take personal responsibility for our decisions, actions and behavior. In matters concerning T-Union, we always act to the best of our knowledge and belief.

Our board of directors are aware that they have a special responsibility. They take their duty of care towards their employees seriously. They fulfil their role model function by setting a good example and fulfilling their entrepreneurial responsibility. In their actions, they are particularly guided by this Code of Conduct. They foster a trust-based workplace and are always available to serve as collegial points of contact.

For T-Union, Compliance is a must and is given the highest priority

 

• Comply (inter)national applicable law

We comply with the law applicable in the respective country and all internal company regulations at all times. This includes compliance with all necessary processes and controls. If national laws contain stricter regulations than those applicable at T-Union, national law takes precedence.

For T-Union, however, Compliance means much more than adhering to all rules and the law.

3.S. Compliance is a mindset

To us, Compliance is a question of mindset – every single day for every single person at T-Union. Always and everywhere. We would rather purposely forgo a business opportunity or fail to reach our internal goals than act against the law.

Violations of internal regulations or of legal or regulatory requirements can have serious consequences for T-Union or its employees, leaders and other individuals. Violations are not tolerated.

4. We are committed to being socially responsible

T-Union is aware of its social responsibility. We are committed to the ten principles of the United Nations Global Compact. In addition to economic considerations, our decision-making processes also take social, ecological and ethical issues into account. T-Union wants to create long-term value together with our customers through innovative technologies and services.

In this way, we want to make a positive contribution to sustainable global development and contribute to a better life for future generations.

To fulfil our high standards for sustainability activities, we actively involcomplyve not only the company management and / but also take into account the interests of other internal and external stakeholders, such as employees, investors, customers, partners, suppliers interests.

• Our conduct and our responsibility as a member of society

T-Union is committed to the highest sustainability standards.

This includes good corporate governance as well as ecological and social responsibility. As an international company, T-Union, handles the storage and transportation of  raw materials, like crude oil but also in Diesel, Jet fuel and Gas, worldwide.

In everything we do, the focus is always on people.

This applies equally to everyone – both our own employees and our suppliers.

In our T-Union “principles of compliance with human rights and environmental due diligence requirements”, we describe what we understand by human rights and environmental due diligence. It also sets out our expectations of our employees, our suppliers and their subcontractors in this regard.

• Human rights and fair working conditions

As an internationally active T-Union, we are aware of our responsibility and make an active contribution to improving human rights standards. We respect and support observance of internationally recognized human rights and fair working conditions.

We respect and support the principles of the United Nations Global Compact, the United Nations International Bill of Human Rights, the International Covenants on Civil and Political Rights and on Economic, Social and Cultural Rights and the core labor standards of the International Labor Organization (ILO). We expect the same from our suppliers. Protection of freedom of expression, personal rights and privacy.

We respect the dignity, privacy and personal rights of every individual. We recognize the right to freedom of opinion and expression.

Forced and child labor

We strictly reject all forms of forced, compulsory and child labor as well as modern slavery and human trafficking.

Human rights at T-Union (e.g. International Framework Agreement, core labor standards of the International Labor Organization, T-Union Modern Slavery Statement).

5. Environmental and climate protection as well as ecological responsibility

Environmental and climate protection as well as ecological responsibility have a high priority at T-Union.

We have set ourselves ambitious, science-based targets to become CO neutral.

These targets are in line with the Paris Climate Agreement. We therefore pay attention to the careful use of natural resources throughout the entire product life cycle, both in the development of new products and services as well as in our operational processes. From duction, to the end of the product life cycle with the reuse of valuable resources in the sense of a complete circular economy.

In this way, we aim to minimize our impact on the climate and environment and make a positive contribution to climate and environmental protection with our products.

In order to live up to our ecological responsibility, we promote energy efficiency measures and the use of renewable energies and protect biodiversity through the careful use of resources.

Compliance with legal and regulatory requirements is just as much a part of our binding obligations as the observance of environmentally relevant duties of care.

 

6.1 Ǫuality standards and product risk management

We aim to always meet legal requirements and customer expectations regarding product safety and product and process quality. We continuously analyse relevant feedback. This helps us to identify errors and product risks at an early stage or to avoid them altogether. It also enables us to improve the quality of our products and our performance.

• Sustainability in the supply chain

Sustainability is an integral part of our corporate strategy. It also plays an important role at T-Union when it comes to selecting suppliers. We have established responsible business practices as an integral part of our procurement processes. Our supplier expectations are set forth in the T-Union Supplier Code of Conduct and in the principles of compliance with human rights and environmental due diligence requirements of T-Union AG. In accordance with legal requirements, we regularly review our requirements for suppliers and our supplier’s fulfilment. We expect our suppliers to fulfil their due diligence obligations to promote responsible raw material supply chains and to comply with all applicable legal regulations on conflict products. Oil products must be acquired from conflict-free sources. Should a product contain a so-called conflict origin we expect our suppliers to be able to provide transparency upon request about their supply chain up to the point of origin of the product.

7.1   Social responsibility and social commitment

Supporting the community is of particular importance to us. Our social engagement shows in the form of donations, sponsorship and memberships.

We expressly welcome the voluntary engagement of our employees to make our “future” better for all of us.

• Political Engagement and Lobbying

T-Union does not engage in political and lobbying activities.

• Appearance and communication in public

We are aware that we can also be perceived as part of T-Union in the private sphere. We preserve the image and reputation of T-Union with our behavior and appearance in public – especially towards the media. We take care not to associate our function and activities at T-Union with any private expression of opinion. We protect ourselves and T-Union by avoiding inappropriate disclosure of personal, confidential or proprietary information. Our employees are also ambassadors for T-Union on social media platforms – and are therefore as well jointly responsible for the company’s public image.

7.4. Prohibition of corruption and bribery

Our business success is based on the quality of our products and services. We comply with the UN Global Compact and support the United Nations Convention against Corruption. We expressly reject corrupt behavior.

Personal gain is never a motive for a business relationship. We demand the same level of integrity from our customers and suppliers. We strictly reject any form of corruption, bribery, theft, embezzlement, fraud or extortion, whether in relation to public officials or in the private sector.

7.5 Invitations and gifts

Good business relationships with our customers are important to us. The same applies to suppliers and other stakeholders. Invitations and gifts can strengthen these relationships, but we never use them to unfairly influence business relationships or decisions.

7.6 Avoidance of conflicts of interest

We make business decisions free of personal interests and motives and exclusively in the best interests of T-Union in order to avoid conflicting decisions.

7.7 Fair competition: Compliance with antitrust and competition lawsWe compete on fair terms and comply with applicable antitrust and competition laws.

We do not participate in agreements that violate antitrust laws or other business practices that restrict competition. We do not participate in the exchange of competitively sensitive information with competitors, nor do we abuse a dominant market position.

7.8 Data protection

The protection of personal data, in particular that of employees, customers and suppliers, is of particular importance to T-Union.

We respect the right of our employees, customers and suppliers to informational self- determination.

We process personal data only to the extent permitted by law.

7.9 Prevention of money laundering and terrorist financing

At T-Union we are working to ensure we are not misused or exploited for money laundering activities or even terrorist financing. With the help of our internal control systems, we endeavour to prevent such abuse.

• Trade compliance

We comply with the foreign trade regulations of the countries in which we do business.

T-Union regulates responsibilities and processes in such a way that only lawful business that is compatible with T-Union’s principles is conducted in compliance with applicable trade regulations.

• Information security

We are aware of the importance of information assets and ensure their appropriate technical protection against unauthorized access.

We regard the data and information required for our business activities as essential productivity drivers. We therefore protect them against alteration, falsification or loss.

To this end, we regularly train our employees and constantly review our systems and processes to identify any need for action.

• Transparent financial and sustainability reporting

Due to our global business activities, we are subject to accounting and reporting requirements nationally and internationally. Correct and complete records by all employees are also essential for the strategic planning and further development of the T-Union. The records not only help us to comply with regulatory requirements, but also help us to improve our processes.

Open and truthful reporting and communication on the company’s sustainability performance to investors, employees, customers, business partners, the public in general and government institutions are also part of a matter of course for us.

7.13. Tax and customs compliance

Our global business activities trigger a wide range of tax and customs obligations.

In addition to tax laws, we also comply with all relevant internationally recognized standards and principles. Furthermore, we do not engage in any aggressive tax or customs avoidance activities and do not use any artificial arrangements.

Taxes are paid where the actual economic value is created.

8. Confidential company and insider information

We take all necessary steps to protect confidential information and business secrets from being accessed and viewed by uninvolved employees and other third parties in an appropriate manner.

This also applies to the use of artificial intelligence which brings us new opportunities, but is also associated with great responsibility. In addition to the careful handling of company information, we also ensure that it is used transparently. We ensure that the data is correct and respect the rights of data subjects.

Employees who have access to insider information do not trade in shares or other T-Union financial instruments and do not pass on this information outside their work for T-Union.

9. Occupational Safety and Health

• Individual

For T-Union, the focus is on the individual. All employees should be able to work and return home safely. It is therefore our goal to create safe and healthy working conditions as part of a preventive approach.

Together, we strive for a progressive safety and health culture. Occupational safety, health protection and health promotion are leadership tasks. The employees take personal responsibility, are actively involved and help to shape the company.

• Continuous improvement

We work systematically for continuous improvement. We always comply with applicable law and other requirements. This also applies to obligations that we have given ourselves. We take appropriate action in the event of infringements.

Occupational safety, health protection and health promotion are an integral part of all operational processes. They are included in the technical, organizational, economic and social considerations right from the start. This applies right from the planning phase. Our guiding principle always applies to everything we do: “Zero compromise on safety and health”.

• Fair treatment and freedom from discrimination

All employees are entitled to work in an environment that is free from discrimination, favoritism, or harassment on the basis of characteristics such as age, ethnic origin and nationality, gender and gender identity, physical and mental abilities, religion and belief, sexual orientation and identity, social origin, political or other beliefs or union membership. We do not tolerate unacceptable treatment of employees or the threat of any form of negative treatment. This includes mental or physical coercion, discrimination, sexual or personal harassment, abuse, verbal abuse, bullying or other personal attacks.

• Cooperation with employee representatives

We recognize the right of all employees to form or join trade unions and employee representative bodies on a democratic basis and to conduct collective bargaining within the frameworks of applicable national and local laws and regulations. For T-Union, close and trusting cooperation with employee representatives is a key component and proven cornerstone of corporate policy. The basis for mutual trust and cooperation is an open and constructive dialog characterized by mutual respect.

• Working hours

We comply with the applicable national and local laws on working, rest and recovery times. If there are no national legal or local regulations, the standards of the International Labor Organization (ILO) apply.

9.6. Remuneration

The right to appropriate remuneration is recognized for all employees.

Remuneration and other benefits correspond at least to the respective national and local legal standards or the level of the national economic sectors, industries and regions.

• Use of external personnel

Regardless of the type of contract, the applicable national and local laws are complied with in contractual and labor relations when using external personnel (e.g. security personnel). We take appropriate measures to sensitize and monitor external personnel, particularly with regard to human rights risks.

• Protection of company property

We use the company’s property and resources appropriately and carefully and protect them from loss, theft or misuse. Our company’s intellectual property in the form of patents and other property rights, e.g. brands and designs, is one of our most important corporate resources. We defend this valuable asset against any unauthorized access by third parties. We also avoid the unauthorized use of third-party intellectual property.

9.9. Our responsibility to implement the Code of Conduct

We are all responsible for implementing and complying with this Code of Conduct.

T-Union actively promotes the communication of those binding documents that concretize the Code of Conduct.

T-Union ensures their implementation. In addition, they must ensure that no employee suffers any disadvantage as a result of complying with the binding rules of T-Union.

Our leaders are the first point of contact for employee questions about understanding the provisions. They ensure that all employees know and understand the Code

10of Conduct. As part of their leadership role, they prevent unacceptable behavior. If necessary, they take appropriate measures to prevent breaches of the provisions in their area of responsibility.

Trusting and good cooperation between employees and leaders is demonstrated by honest and open communication and mutual support.

For further questions about the Code of Conduct, all employees as well as third parties (customers, suppliers, etc.) can also contact the Compliance officer in charge

Lawyer Mr C. Brandt e-mail address: >q5legal@xs4all.nl< All information will be treated in strict confidence.

10. Reporting possible misconduct

• Bona fide reports help to counteract violations at an early This can prevent damage to T-Union, our employees and business partners. All T-Union employees have the opportunity to submit reports or complaints on all topics listed in the Code of Conduct and beyond. The same applies to customers and suppliers. Several channels are available for this purpose – anonymously if desired, of course.

• Direct contact with superiors or business partners

An open communication culture is an essential component of our cooperation and our corporate culture. Employees must be able to address mistakes openly and, above all, at an early stage. The primary point of contact should therefore always be the respective line manager. If you are a third party, please contact your business partner at T-Union.

• Reporting channel

T-Union and his compliance officer protect the interests of whistleblowers not only by setting up secure reporting systems, but also by promising to treat incoming reports confidentially and to protect whistleblowers acting in good faith from any disadvantages resulting from a report by all necessary means. When investigating reports, however, we also take into account the legitimate interests of the persons affected by a report. Please bear in mind that suspicions and accusations against a person can have serious consequences for that person. We therefore ask you to use the whistleblowing channels listed below responsibly.

• Compliance Investigations

The Compliance Officer receives the reports on compliance violations with a focus on anticorruption, antitrust law, data protection, anti-money laundering and trade compliance as well as environmental and human rights-related infringements in the supply chain. Incoming reports are checked and processed by the T-Union Compliance Officer.