Anti Corruption Policy

The purpose of this policy is to provide all employees of Röhlig an overview of the US Foreign Corrupt Practices Act (FCPA) and its application to the business activities of Röhlig. The members of all Röhlig divisions, subsidiaries, affiliates as well as of Röhlig agents shall comply fully with the provisions of the FCPA. This guide is intended to assist Röhlig employees in carrying out their responsibilities. It should assist them in recognizing potential areas of concern so that they may consult with the CHRO in conjunction with the CFO before any action is taken.