Whistleblowing and Speak-Up Channel

At Black Semiconductor, integrity, transparency, and responsible conduct are fundamental to how we operate. We are legally required to operate an internal reporting office ("interne Meldestelle") inline with the requirements of the EU Whistleblower Protection Directive (2019/1937) and the German Whistleblower Protection Act ("Hinweisgeberschutzgesetz" or "HinSchG") with respect to certain violations of applicable laws. In accordance with our ethical standards and our commitment to integrity, transparency, and responsible conduct, we are extending the competence of our internal reporting office beyond the scope of the legal requirements with the aim to create standards for the reporting and handling of other serious misconduct and / or unethical behavior. In addition to this, Black Semiconductor opens the internal reporting office also for reports of third parties.

We encourage anyone who becomes aware of potential suspected violation of applicable laws, serious misconduct, and / or unethical behavior (together referred to as "Breach") to report their concerns through our confidential reporting channel.

This reporting channel is provided in accordance with the EU Whistleblowing Directive (2019/1937) and its implementation into German law by the German Whistleblower Protection Act (“Hinweisgeberschutzgesetz” or HinSchG). This document serves information purposes. Nothing herein shall be construed as limiting or restricting any person’s rights under the Hinweisgeberschutzgesetz or any other applicable law.
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Who Can Use This Channel

The whistleblowing channel may be used by individuals who have obtained information about a potential Breach in a work-related context with Black Semiconductor. This includes, but is not limited to:

• Current and former employees
• Job applicants
• Contractors and subcontractors
• Suppliers and business partners
• Shareholders
• Trainees, interns, and volunteers
• Individuals working under the supervision of contractors or suppliers
• Temporary agency workers assigned to BLK

What Can Be Reported

This channel is intended for reporting serious concerns related to potential Breaches, including matters such as:

• Fraud, bribery, corruption
• Financial misconduct
• Harassment, discrimination or bullying
• Conflicts of interest
• Breaches of data protection or privacy laws
• Cybersecurity violations
• Environmental violations
• Product safety concerns
• Health and safety risks
• Legal or regulatory noncompliance
• Breaches related to public procurement or competition law
• Anti-money-laundering violations
• Retaliation against Whistleblowers
• Other serious misconduct that violates our company policies or Code of Conduct

This channel should not be used for general inquiries or routine HR matters. Employees are encouraged to address such matters through their usual internal communication channels where appropriate.

Confidentiality and Protection

Reports can be submitted confidentially and, where permitted by law, anonymously. Black Semiconductor is committed to protecting individuals who report concerns in good faith from retaliation or disadvantage.

All reports will behandled in a confidential manner and reviewed in accordance with applicable legal requirements.

Reporting Process

Upon receipt of a report, confirmation will be provided within the legally required timeframe. Reports will be reviewed and investigated as appropriate, and feedback will be provided in accordance with applicable legal provisions.

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