The CMS’s internal policies are built upon the Hilti How we embed business ethics in our Code of Conduct for Employees and the Code of Conduct processes for Suppliers We uphold , further detailed in the Sustainable Sourcing Policies ourselves and the and process. Accepting and adhering to the Comprehensive and target group-oriented compliance Code of Conduct for Suppliers is a mandatory part training concepts ensure that we inform our team industry to the of all direct supplier contracts and indirect supplier members about our compliance requirements that relationships based on a risk matrix. In the reporting are relevant for them. Besides the online component, highest standards year, we signi昀椀cantly enhanced and automated our our on-site training and case studies are an supplier monitoring procedures, harnessing a range essential part of our compliance training strategy. in business ethics. of software tools to comprehensively evaluate and The training courses provide a general introduction proactively manage supply chain risk data driven from to compliance issues and more in-depth handling both a top-down and bottom-up perspective. We of individual aspects. A monthly topic-speci昀椀c additionally conduct in-person audits through a third- communication by the compliance department in party service provider. our internal communication platforms, with concise, Topics covered in our CMS: Supplier Sustainability: p. 31 easy-to-remember content, is intended to increase awareness of current and relevant compliance topics. • Antitrust Law The Code of Conduct training for team members, It also serves as a reminder for completed or optional • Corruption Prevention initially introduced in 2021 and 2022, has been followed e-learning courses. Furthermore, all new general • Con昀氀ict of Interest Management by an anti-corruption (2022) and anti-trust e-learning managers at our local organizations are trained in • Anti-Money Laundering campaign (2023), achieving a 90 percent adoption compliance issues in their area of responsibility as • Anti-Discrimination and Anti-Harassment rate. In 2024, we will be moving to an integrated part of their comprehensive training immediately • Product Regulatory Compliance e-learning onboarding experience for new colleagues. after taking the position. • Human Rights / Prevention of Forced and Child Labor We maintain a commitment to continuously review and • Export Control and Sanctions Law update our Code of Conduct to ensure its relevance In the context of compliance management, we and effectiveness. undertake a great effort to make any con昀氀icts of The extended responsibility of the compliance interest transparent. New team members must department also covers: We oversee various aspects within the CMS via a new disclose all relevant con昀氀icts during the recruitment comprehensive dashboard, encompassing reporting and onboarding process and existing team members • Health & Safety and Environmental Protection (HSE) metrics such as the overall risk score, protective must participate in a con昀氀ict of interest survey at least • Data Privacy measures such as training coverage and behavior- every three years, or more frequently if required by local regulations. in昀氀uencing initiatives, and our incident reporting. The dashboard is regularly presented to the audit committee.