Ethics: Integrity in ethical business conduct

04.1

Our ethical commitment

GRI 2-24 General disclosures
ESRS S1-1 §20 Own workforce
ESRS G1-3 §20 Business conduct

As Hager celebrates 70 years of shaping the electrical world it is a good time to reflect on the things that have enabled our business to thrive. Foremost among these is the importance we place on the ethics that guide our work every day.

For every single one of us, whatever our role or location around the world, our shared ethics are much more than merely fine ideals; they are the practical cornerstones of sustainable prosperity.

Just as much as our technical expertise and commercial acumen, Hager is built on honesty, integrity and trust. These principles apply within our business – every employee is committed to ethical behaviour – and beyond, in our interactions with our customers, partners and stakeholders, and across our supply chain.

Our ethical commitment is embodied in our Ethics Charter, and the accompanying Declaration of Principles on Respect for Human Rights, which clearly define the high standards that every member of the Hager team upholds. Our unwavering affirmation of these ethical principles fosters a safe, collaborative and productive working environment for all our people, and helps to safeguard our business from reputational risk, conflicts of interest, corruption and other complex situations.

Perhaps most significant of all, by making our ethical commitment, and exemplifying it in all we say and do, our customers and other external stakeholders can have confidence that Hager will always be a reliable partner; one that is politically and religiously neutral and unaffiliated, that endorses and upholds internationally-recognised standards of human rights, and is dedicated to equal opportunity, diversity and inclusion for all.

At Hager our ethics show who we are. Driving ethical behaviour strengthens ties among employees, powers our business performance and creates impact for our customers.

For more information on our policies relating to issues including intellectual property, data privacy, fair competition and a range of other topics, please see our Ethics Charter, Declaration of Principles on Respect for Human Rights, and Code of Purchasing Conduct, Ethics and Sustainable Sourcing. Our policy documents also include our Anti-discrimination and Anti-harassment Guideline, the Conflict of Interest Directive, the Gift and Entertainment Guideline, and the Guideline on Antitrust Law.

Hager operates a zero-tolerance policy for unethical behaviour, which is supported by robust integrity procedures and extensive employee training (see later in this section).

04.2

Ethical risk assessment

GRI 3-3 Material topics
GRI 205-1 Anti-corruption

Our proven four-step risk assessment process enables us to identify and evaluate ethical risk within and around our business and the projects we undertake. Successfully understanding risk is the crucial first step in eliminating it, or at least reducing it as far as is practically possible. Reducing and eliminating ethical risk promotes ethical conduct, strengthens our stakeholder relationships and safeguards the reputation of Hager.

In 2025 we conducted an updated assessment of our ethical and human rights risks. The scope of this evaluation covers the entire Hager value chain, from purchasing, via manufacturing and sales operations, through to product use and end-of-life recycling. It also takes into account all relevant stakeholders, including workers, clients, suppliers, communities and shareholders.

The 2025 exercise was carried out in alignment with Cradle to Cradle (C2C) standards and in accordance with United Nations guidelines. We evaluated risk against likelihood and impact in ten categories:

• Discrimination with respect to employment and occupation
• Harassment and abuse
• Forced or compulsory labour
• Child labour
• Excessive working hours
• Restrictions on freedom of association
• Employee health and safety
• Non-compliance with legal minimum wage and benefits
• Restrictions in providing a living wage
• Non-compliance with fair and ethical business practices (including corruption and bribery)

04.3

Driving ethical behaviour

GRI 2-13, 2-16, 2-25 and 2-26 General disclosures
GRI 3-1 and 3-3 Material topics
GRI 205-1 and 205-2 Anti-corruption
ESRS S1-3 §32 Own workforce
ESRS G1-1 §10, G1-3 §18 & §20 §21, and G1-5 §21 Business conduct

Bringing our ethics to life takes more than a written charter and a personal commitment from every one of our people, serious though these things are. It depends on practical policies and procedures which are implemented every day.

The ethical behaviour of Hager people is underpinned by our rigorous approach to ethical risk assessment, ethics training, our whistleblowing and risk mitigation systems, our cybersecurity, compliance and trust protocols, the ethical standards we expect from supply chain stakeholders, and the stringent quality control standards that make the safety of our customers a consideration of paramount importance.

These comprehensive measures help to drive the perception – and reality – of Hager as being dedicated to ethical conduct at all times.

Comprehensive, group-wide assessments are conducted to ensure that all of our operations are regularly evaluated. This serves to identify any economic and reputational risk and any risk of bribery and corruption, and ensures compliance with all local regulatory requirements.

For example, SAPIN II legal requirements (in France) require the regular assessment of our France-based operations. In a recent assessment (2024) fraud was identified as a corruption-related risk, and vigilance has been elevated accordingly.

The Hager internal Legal and Risk function has also performed risk mapping exercises with stakeholders, covering the wider scope for exposure to bribery and corruption risks. For last year (2024) data security was added into this exercise as a priority consideration.

04.3.1

Ethics training programme

Hager is a business that thrives on continual learning and development. We invest in our number one asset, our people, through programmes of skills and knowledge training that cover a wide range of technical and organisational disciplines (see Employees section for more information). Our ethics training is an important component of this.

Our Business Integrity Training programme includes specialised ethics training modules developed in-house by Hager specialists. These training programmes are available to 100% of connected employees across every business function, including those in roles with an elevated risk of corruption. They enable us to equip our people with the knowledge and skills necessary for navigating the ethical issues which anyone in our business might encounter. All training materials are regularly reviewed and updated to ensure employees have access to the latest topics and insights.

• Core modules include:

  Business Integrity @ Hager (for new employees), our Ethics Risks workshop (for leaders); Ethics and Investigations (for Ethics Ambassadors), and Discrimination and Harassment (for employee representatives).

• Let’s practice!

  Introduced in 2021, Let’s practice! is a bespoke Hager training programme that makes effective use of gamification and is delivered as a “serious game” – an interactive method of teaching and learning which draws on the techniques of game design.

  Participants are familiarised with the principles of business ethics, situational analysis and ethical decision-making, based on real-life scenarios including discrimination, harassment, unfair treatment, racism, and conflicts of interest. Focused initially on managers, this course is now being rolled out globally to support the whole Hager workforce with the best possible ethics guidance. Until 2024, 3.048 executives have competed this training.

• E-learning

  Further standardised compliance integrity e-learning modules are currently being rolled out as part of our overall Business Integrity Training programme. These are: Anti-bribery and Corruption, Fraud and Conflict of Interest, and Discrimination and Harassment. These programmes cover all Hager functions.

By the end of 2024 we successfully delivered these modules for 80% of the connected Hager workforce globally (ie those who have a Hager email address and access to Hager Live), and this programme is ongoing.

Ewa Lubos,
Ethics Ambassador

Since joining the Ethics Ambassadors in November 2022, Ewa Lubos has been instrumental in supporting ethics-related initiatives in Poland, including the coordination of training sessions, active involvement in the reporting and investigation processes.

04.3.2

Ethics Ambassadors

Ethical principles are nothing without people, and at Hager we bring them to life every day through our network of Ethics Ambassadors. Established in 2020, this group, representing a wide range of roles and locations from across Hager, has now grown to 22 people from ten different countries.

Every ambassador is a volunteer and acts both as a powerful advocate for our Ethics function, and as a valuable resource for any colleague encountering an ethics challenge. Ambassadors take on a range of important activities including training delivery, charter promotion, employee guidance, management liaison and support for investigations.

This is a potentially sensitive role, and a crucial one from the perspective of the integrity of our business, so volunteers are accepted as ambassadors based on their high level of familiarity with Hager ethics policies and procedures, their communication skills, and a clear commitment to exemplary standards of behaviour.

The plan from 2025 onwards is to prioritise the structured training and certification of Ethics Ambassadors. This initiative is intended to strengthen our ethical culture by equipping designated employees with the necessary knowledge, tools and credibility to promote integrity, support colleagues and uphold our Code of Conduct across the organisation.

04.3.3

Integrity alert system

We know that the success of our business depends ultimately upon the trust of our stakeholders. That’s why we have in place a robust system for detecting and addressing any challenge to the integrity of our business ethics which might arise, at the earliest possible moment.

The integrity alert system is designed to enable every employee, as well as our partners and other external stakeholders in our value chain, to raise any concern they may have. The Hager Group Ethics Officer is responsible for assessing and actioning each alert expeditiously, to ensure that business integrity is maintained at all times.

To ensure a fair process in the event of an investigation, Hager respects the principles of confidentiality and presumption of innocence. Accordingly, the Group Ethics Officer supervises investigations, which are carried out by a team including regional Ethics Ambassadors and experts who are separate from the chain of management involved in the matter. All investigators sign a confidentiality and conflict of interest declaration.

The identity of whistleblowers is also confidential during any investigation process. The identity of a whistleblower is not revealed to the participants of an investigation, nor stated in the investigation report.

04.4

Reporting integrity alerts

GRI 2-27 – General disclosures
GRI 2-16 and 2-17 – General disclosures
GRI 205-3 – Anti-corruption
ESRS G1-1 §10, G1-3 §18 and G1-4 §24 & §25 Business conduct
ESRS S1-17 §102 to §104 Own workforce

As already highlighted, the Hager integrity alert system is in place to protect the safety and well-being of our people, the reputation of our business, and the trust of our stakeholders. Multiple measures are deployed, and foremost among these is Let’s talk! – our system for reporting alerts.

04.4.1

Report handling

Hager is committed to acknowledging 100% of integrity alert reports within 48 hours; in 2024 we achieved an average of less than one day (0,69). All reports are assessed for seriousness and an investigation allocated within 15 working days.

Internal investigations were closed on average within four months in 2024. The Hager Board of Directors monitors the integrity alert reporting system on a monthly basis.

Let’s talk governance

04.4.2

Let’s talk!

Reporting integrity alerts via Let’s talk! is open to all employees, both permanent and temporary, as well as customers, suppliers and any other external stakeholder with concerns. The system can be used anonymously, confidentially, in any language, at any time.

Reports can be raised through a variety of reporting channels, including Safecall (by phone or online), which makes use of an external, impartial, third-party organisation to ensure that no conflict of interest can occur.

It is also possible to launch a report internally via a manager, a Human Resources Business Partner (HRBP), employee or occupational health representative, an Ethics Ambassador, or directly to the Ethics team.

In 2024 we observed an increase in the number of reports, particularly concerning workplace interactions such as harassment and discrimination. All reported cases were thoroughly analysed, investigated if necessary, and appropriate actions were taken in line with our internal policies. Where allegations were substantiated, disciplinary measures have been enforced, including dismissal in severe cases.

Where alerts have been made relating to dishonest behaviour, including corruption, conflict of interest, theft, fraud or integrity, further investigation has shown no confirmed cases of corruption.

Overall, 11 alerts resulted in disciplinary action, out of which four resulted in dismissal during the last year.

Actions taken when found guilty¹

In 2024 process improvements relating to integrity alert reporting have included validation of investigation procedures by the Compliance Committee, enhanced follow-up and conflict of interest declarations, and enhanced support for victims of harassment and discrimination. The certification of investigators is also planned.

Ethical reports

82

total number of reports in 2024

Workplace interaction allegations in 2024

04.5

Digital trust and data security

04.5.1

Digital trust

In many respects the modern world is already fully digital-first. The embrace of digital technology is vital for our business; both as a product platform and as a communications channel, digital is a driver of prosperity. But for all its benefits, the advent of digital technology brings risks too.

Maintaining robust data security, for our people, our business and our customers, is imperative for Hager. Every stakeholder must have confidence in the integrity of our data systems.

The process of developing, implementing and refining our proactive security protocols, to ensure a high level of data protection, is supported by external security audits, in the form of IT penetration tests carried out by third-party data security specialists. The most recent audit (2024) involved a comprehensive analysis of Hager data systems, a resulting risk assessment, and technical recommendations for action.

Hager cybersecurity measures are also supported by training. In 2025 we launched mandatory training on data protection for all employees whose role makes them vulnerable to a cybersecurity attack. This training introduces employees to the principles of data protection, helping them to understand legal requirements and adopt best practice.

As part of our broader commitment to digital responsibility Hager has also established an AI Charter, to guide the ethical and transparent use of artificial intelligence across the organisation. The Charter provides clear principles for identifying relevant AI use cases, applying best practice, and managing emerging risks such as data privacy, compliance, and ethical concerns.

Our AI Charter supports our ambition to foster innovation while safeguarding the interests of our employees, customers and the wider community, thereby reinforcing trust in the digital tools we rely on every day.

We view sustainability as an integral part of how we understand and manage business resilience.

By embedding environmental and social factors into our risk assessments we ensure that our decisions today are aligned with long-term value creation and stakeholder trust.

Stephanie Kleinmann
Group Risk Manager

04.5.2

Data security

In 2024 Hager recorded the greatest number of high-risk incidents since implementation of our monitoring framework began. This is an important reminder that persistent vigilance remains essential.

Although all incidents were addressed promptly in accordance with risk-based protocols, they also highlight the increasing sophistication of cyber threats targeting industrial and digital infrastructures.

We also recorded 12 data breach incidents in 2024. While no breaches resulted in large-scale exposure of stakeholder data, each case triggered a detailed root cause analysis, escalation procedures, and follow-up actions, including policy updates and the reinforcement of access controls.

Risk level

Count of data breach incidents

04.6

Ethics in our supply chain

GRI 414-2 – Supplier social assessment
ESRS G1-2 §15 – Business conduct

04.6.1

Supply chain – data security

Our concern for cybersecurity naturally extends to our supply chain too. Issues such as data breaches, ransomware attacks and regulatory non-compliance represent a risk to the whole value chain, and as such have the potential to compromise trust in Hager data systems. Because of this our Cybersecurity function works closely with counterparts in stakeholder organisations to ensure robust security practices are in place, enhance resilience, strengthen compliance with GDPR and other regulatory requirements, and minimise risk.

Our data security supply chain

04.6.2

Supply chain – ethics

Thanks to the nature of our business Hager is in a position to positively influence behaviour across a large group of external stakeholders. Indeed, we have a responsibility to do this, so our customers can be confident that no aspect of their interaction with us is ever ethically compromised.

To this end we have implemented a range of initiatives designed to embed the highest possible ethical standards in the Hager supply chain. Our Code of Purchasing Conduct, which all suppliers sign up to, focuses on sustainability, ethical conduct, and the protection of human rights.

Our reporting and compliance management tool, Sphera, enables us to proactively monitor socio-environmental compliance across more than 2.000 supplier organisations. In 2024 a total of 61 potential violations were identified globally (down from 170 in 2023), with only three deemed to constitute a high reputational risk.

In each case we have been able to intervene early, taking action with business partners to rectify situations successfully.

04.7

Product safety

GRI 3-3 Material topics
GRI 2-25 General disclosures
GRI 416-1 and 416-2 Customer H&S
ESRS S4-3 §25 and §26 Consumers and end-users
ESRS S4-4 §25 Consumers and end-users

In line with our commitment to customer-centricity, and aligning with our “safe+simple” ethos, the integrity of our products must also be addressed. It might seem like an obvious thing to say, but it is worth reiterating: every single Hager product purchased by our customers must be trusted by them to be completely safe and reliable.

The physical health and safety of our customers, and their trust in the quality of our products, are of paramount importance. Any faulty product, or the possibility of a product recall, would present significant risk of financial and reputational damage.

During product, solutions and service development, Hager implements Advanced Product Quality Processes (APQP). These identify potential failure modes, allowing corrective and preventive actions to be implemented before market introduction.

During engineering, sourcing, and manufacturing, in compliance with consumer health and safety regulations – including the Low Voltage Directive (2014/35/EU) and Restriction of Hazardous Substances (RoHS) Directive (2011/65/EU) – products are assessed for customer health and safety risks using systematic Failure Mode and Effects Analysis (FMEA) and Quality Assurance/Quality Control (QA/QC) processes, to ensure long-term safety and environmental compatibility.

Our products are assessed prior to market release. Extensive performance testing, including field test routine and follow up tests, is also undertaken. For the reporting year 2024 no incidents of non-compliance with regulations or voluntary codes concerning the health and safety impacts of products and services on customers and end-users.

Nevertheless, customer issues may still occur. To ensure open, honest and fully transparent customer dialogue we maintain systems to track, monitor and respond to customer concerns, including recording grievances, investigations and outcomes.

We proactively gather and evaluate feedback across multiple touchpoints. These include interactions with our technical support teams, responses to customer satisfaction surveys, and feedback provided through digital platforms such as product review channels, website forums and social media.

Through all of these integrated mechanisms Hager ensures the full remediation of negative consumer impacts in order to maintain complete customer satisfaction in the safety, quality and performance of our products.

Behind every technical specification is a simple question – how do we protect the people who use our solutions? At Hager product safety is not negotiable.

It is built into our development process, from design to delivery, ensuring that we meet the highest standards of reliability, compliance and care.

Dariush Shahbaz
Senior Director, Development Quality

04.8

Corporate citizenship

Giving back to the communities which are the bedrock of our success is something which Hager has always been proud to do. The Peter und Luise Hager Foundation was created in 2010 to provide us with a way to take a more structured, constructive and impactful approach to charitable giving.

Educational Support in South Africa – In 2024, the Peter and Luise Hager Foundation supported the association 'Mon Coeur – Ein Band für Bildung e.V.' in building a new daycare centre, Kusangana, to provide children in Cape Town with a safer space for learning and care.

From relatively humble beginnings – just like the Hager business itself – the Foundation has grown to the point where, today, they support over 45 projects with a combined budget (in 2024) of more than €615.000.

From small-scale local endeavours to large international projects, these are all dedicated to fostering meaningful engagement in five main fields: education and learning, arts and culture, the environment, social projects, and science and research. Many of these projects have been initiated and brought to life by the Foundation itself.

In addition to the ongoing project work through the Peter und Luise Hager Foundation, Hager colleagues are encouraged to get involved too. Every team is welcome to submit proposals for projects in their local area that align with the Foundation’s values, and we receive a wide range of ideas every year; from supporting food banks, to organising litter picking, or facilitating tree planting initiatives.

The beauty of these projects is that they are implemented by people who know exactly what their local area needs, and what can have the most positive impact on the ground. The Foundation co-ordinates with local employees and management to fund and deliver projects, and the results are always enriching – improving the life of local communities and strengthening the bond between Hager and the places we take great pride in being part of.

Some of the great activities delivered in 2024 include:

• In August the Sales Management department distributed food to two initiatives for people in need, the Scheidter Tal parish in St Ingbert-Rentrisch, and the St Ingbert food bank.
• In October a team from the HR department in Blieskastel visited Saarbrücken Zoo with a group of children from the Hanns-Joachim-Haus children’s home. The children were given an educational tour and everyone received a small souvenir too.
• Also in October, trainees in Blieskastel carried out renovation work at the Saarbrücken site of the SOS Children’s Village, together with the trade fair construction team. The changing rooms were completely renovated in a day, providing new flooring, cupboards and wallpaper.
• In November the Customer Service team from Blieskastel supported the Love in a Box campaign by packing over 600 Christmas presents for children in Ukraine.
• Throughout the year Hager colleagues from across Germany and France have been making small monthly donations to the Foundation. At the end of the year the Foundation triples the sum collected and donates the proceeds to charitable organisations.
• In Germany, this year, donations went to food banks in Homburg and Pirmasens, the Balthasar hospice for children and teenagers in Olpe, and the Gesamtkunstwerkverein-ev in Dortmund. In France, donations went to Petit Coeur de Beurre, Familles Solidaires Alsace and Observatoire du Partage.
• And to round off a fantastic year, in December, a beautiful Christmas market was organised for employees in Blieskastel. A fundraising event was organised on the day, and the money raised went to three charitable organisations in the region: Kinderinsel Homburg e. V., Kinderhospiz- und Palliativteam Saar and Stiftung Lebenswert(e) in Blieskastel.

A big thank you goes out to everyone that participated in all these campaigns and activities in 2024.

2024 highlights

Holiday childcare with an environmental flavour

The Peter und Luise Hager Foundation joined forces with the Stadtbauernhof Saarbrücken e.V. city farm to provide holiday care for primary school children. Great outdoor fun included harvesting vegetables fresh from the field, looking after the chickens and a bit of bee-keeping too! In the spirit of sustainability the youngsters also learned about food waste, food origins and seasonal and regional food – all in an age-appropriate way.

Meister-Gründerpreis 2024

Once every two years we honour three outstanding young people in the German electrical industry. This year’s winners were Jan Ochterbeck from Elektrotechnik Ochterbeck GmbH, Adrian Gloss from Eddison Electrics GmbH, and Leik-Kilian Valkai from IEV-Industrieservice & Elektroinstallation Valkai. All three impressed the judges with their professionalism and entrepreneurial flair – well done and congratulations!

Meister-Gründerpreis 2024 in Berlin – Three young entrepreneurs were honoured at the Saarland State Representation for their outstanding achievements in the electrical trade. Each received €10.000 in prize money, supported by the Peter and Luise Hager Foundation.

A new educational centre for Cape Town

Working with Mon Coeur – Ein Band für Bildung e.V. – an organisation that promotes education for children in South Africa – we are helping to develop a new space for children’s afternoon care. This will enable local youngsters to receive education in a safe and comfortable environment where they can thrive. Giving back to the communities which are the bedrock of our success is something which Hager has always been proud to do.