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    Code of Business Ethics

KWS SAAT SE & Co. KGaA Code of Business Ethics

KWS is committed to observing the principles of business ethics and complying with international legal requirements. This is why KWS has developed its binding Code of Business Ethics. It has been effective since July 1, 2007. It is backed up by further KWS guidelines for important individual topics, such as antitrust law, insider-trading law, preventing and combating bribery, and the regulation of signatures.

The Code of Business Ethics and KWS guidelines apply without exception to all employees of the KWS Group, and compliance is regularly audited.

We are convinced that preserving our
corporate culture is an indispensable foundation for
our path to the future.
From the Executive Board’s foreword to the Code of Business Ethics

Code of Business Ethics
This Code of Business Ethics commits the KWS Group to compliance with the law. Integrity and ethical conduct are the basis of our business activities. The Code of Business Ethics contains information on particularly important responsibilities and critical ethical issues. All KWS Group employees are obliged to comply with the provisions of the Code of Business Ethics. KWS also expects its business partners to act ethically in accordance with these guidelines for business ethics. Constant compliance with laws is of utmost importance to KWS employees. All KWS employees are obliged to comply with the regulations of the Code of Business Ethics.

All KWS employees should express their compliance-related concerns by contacting

their supervisor,
the compliance officer or
the compliance hotline.

Responsibilities of employees
Always follow the law: Remember that any infringement can lead to significant damage and is not in the interest of the company. Understand the principles
of the Code of Business Ethics and apply them to your everyday work. Whenever you have questions about the applicability of this Code of Business Ethics, ask your supervisor, the compliance officer or another KWS contact person for assistance. Be loyal to KWS - address any ethical concerns.

Fair competition
We are committed to fair competition and fairness in contractual relationships with our business partners. Anticompetitive behavior can seriously damage KWS’s assets and lead to serious damage to its reputation. Due to the serious consequences, even a minor appearance of this behavior should be carefully avoided.

International trade
Follow all relevant provisions on the control of international trade control rules and, in particular, ensure that all requirements for licenses,
transport documents, customs declarations and import/export documents are complied with. You must also respect the reporting and retention obligations for each document. Pay careful attention
to embargoes against countries and individuals and to sanction programs that penalize any business dealings with particular individuals or organizations, such as criminal or terrorist organizations. Note which of the contracting parties is responsible for the accurate documentation of a given transaction.
Make sure that KWS has fully complied with all obligations.

Anti-corruption regulations
KWS employees are required to comply with anti-corruption regulations in every country. Note: Offering, promising or granting an advantage to a customer, supplier or government representative to obtain an advantage is prohibited. Note: Offering, promising or giving a courtesy (such as gifts,
donations or entertainment) is prohibited even if it could give rise to the mere appearance of improper conduct.

Insider trading rules
Always treat insider information as strictly confidential. Do not use insider information to buy or sell shares or to make any recommendations.

Protection of confidential information
Never disclose confidential information to third parties without the express written consent
of the responsible head of department. Confidential information
may only be disclosed to other employees on the basis of a legitimate interest. Make sure
that confidential information does not become known accidentally or through

Safety at work
Follow corporate requirements and guidelines for environmental protection and occupational safety. Avoid dangerous activities and conduct, such as the blocking of corridors and emergency exits, as well as the careless loading of shelves. Immediately report any incidents that could threaten environmental protection and
occupational safety.

Consequences of failure to comply
Violations of the Code of Business Ethics will lead to disciplinary action. Likewise, any intentional misreporting will also result in disciplinary action.

Responsibilities of supervisors and executives
Be a role model and train your employees to behave ethically in business dealings and to avoid even the mere appearance of unethical conduct. Never cover up or ignore any violation of the Code of Business Ethics; if in doubt, ask your supervisor or compliance officer for assistance. Encourage employees to address compliance issues and ensure open communication by encouraging employees to ask questions about compliance issues.