AuHandel’s policies are overseen by senior management of Balmeringa GmbH. Management is accountable for:

• Setting expectations for ethical conduct and responsible sourcing.
• Ensuring policies are implemented through procedures and controls appropriate to AuHandel’s operations.
• Providing resources and oversight proportionate to risk.
• A designated role (e.g., Compliance Lead / Responsible Sourcing Officer) is responsible for maintaining policy documentation and related procedures.
• Coordinating training and awareness for relevant personnel.
• Managing escalation processes and documenting decisions.
• Monitoring implementation and reporting material issues to management.

All published policies are:

• Approved by management prior to publication.
• Communicated internally to relevant personnel.
• Made available to counterparties and stakeholders through the website where appropriate.

AuHandel reviews its policies at least annually, and whenever there is a material change in:

• Legal/regulatory requirements.
• Operating footprint or transaction types.
• Sourcing risk profile (including CAHRA exposure).
• Risk intelligence or credible incident reporting.
• Lessons learned from implementation or grievances.
• Updates are made to ensure policies remain current, effective, and aligned with evolving good practice.

AuHandel implements its policies through a risk-based control framework that may include:

• Counterparty onboarding and due diligence.
• Transaction screening and escalation.
• Contract-led execution controls.
• Record-keeping and audit readiness practices.
• Training and awareness.
• A grievance mechanism with non-retaliation protections.
• Where required, AuHandel may refuse, suspend, or disengage from transactions or relationships that cannot meet policy expectations.

AuHandel provides a channel for stakeholders to raise concerns about:

• Responsible sourcing.
• Human rights.
• AML/CTF.
• Bribery/corruption.
• Fraud or misrepresentation.
• Other compliance matters.
• Grievance contact:complaints@auhandel.com
• Reports are handled discreetly and without retaliation for good-faith reporting.

This statement should be read together with AuHandel’s published policies, including:

• Responsible Sourcing Policy
• Human Rights Policy
• Supply Chain Due Diligence Policy
• CAHRA Policy
• AML/CTF Policy
• Anti-Bribery & Corruption Policy
• Environmental Policy
• Health & Safety Policy
• Whistleblower & External Grievance Mechanism Policy

AuHandel’s policies are published to describe our commitments and approach. They do not create contractual rights for third parties and do not constitute an offer, quotation, or solicitation. Any transaction is subject to due diligence, internal approvals, and contractual agreement.