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Avoiding Conflicts of Interest

Behavior which could bring employees or a commissioned person acting on behalf of the company (e.g. commercial agent, consultant or cooperation partner) into conflict with their obligations to the corporate well-being of Rheinmetall will not be tolerated.

For this reason, the selection of business partners, initiation of new business, personnel decisions, submission of tenders, approval procedures and comparable commercial decisions must be made exclusively on the basis of transparent commercial factors / objective criteria and the applicable processes.

Financial or other involvements in business partner companies of the Rheinmetall Group which could result in benefits for the employee in question in the event of the conclusion of a transaction must be disclosed in due time in order to exclude conflicts of interest.

Secondary activities must be declared promptly by employees in the context of the applicable HR processes, and must generally be organized such that they do not come into conflict with the primary service obligations under the employment contract. Competition with the primary activity is prohibited. The applicable regulations concerning working hours must be observed.

In cases of doubt, the Compliance Organization should be consulted.

There is a detailed outline of different procedures applied in the company to detect, cope with, avoid and monitor conflict of interests under par. 1.7 of the Code of Conduct (p.14). In addition, a specific policy on handling Conflicts of Interest is currently under development.

The third party assessment as part of the business partner approval process includes a dedicated area of investigating conflicts of interest entailed by new relationships with business partners, freelancers or key employees (including ex-PEPs). It goes without saying that the hiring or contracting of active PEPs is strongly prohibited! Legally applicable grace or cooling-off periods for public officials and politicians are strictly adhered to before hiring or contracting any such party.

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