Corporate Governance

Compliance, Ethik und Informationssicherheit

Compliance, ethics and information security

The Executive Board is committed to conducting all business in an ethical and legally sound manner. In addition to compliance with legal and regulatory requirements, our internal guidelines and the requirements of internal stakeholders are taken into account.

AIXTRON does not tolerate any corrupt or criminal behavior and expressly distances itself from human rights violations. In addition to the legal and regulatory requirements, our internal company codes, guidelines, and management systems provide the framework for action.

Since 2006, the AIXTRON Code of Ethics has applied in particular to members of the Executive Board and throughout the company to finance managers and persons in key finance positions. This is intended to ensure that honest and ethical behavior is practiced.

Finance managers and persons in key finance functions confirm annually for their area of responsibility that the Code of Ethics issued by the Executive Board is known and complied with in daily activities.

In addition, a Compliance code of conduct applies to the Executive Board, Senior management team and all employees group-wide, which obliges them to behave responsibly and in accordance with the law. This is specified by the regularly updated Compliance manual and additional compliance rules and regulations with detailed guidelines and is taught provided in training sessions.

Training for the updated compliance guidelines, in particular for the compliance manual, started in the fourth quarter of the 2023 financial year. Participation in compliance training is mandatory for our new employees and remains part of their onboarding program. In addition, further compliance training is addressed and carried out as required

- in the course of risk assessment and/or possible compliance violations. The compliance training process is managed and its implementation monitored by our Compliance department.

Our company-wide Anti-Corruption Policy defines formal and concrete rules and principles of conduct to combat corruption and bribery and is binding for our employees. An elementary component of our company-wide compliance training program is to sensitize our employees to identify potential corruption and bribery risks in their daily activities at an early stage. This also includes preventive anti-corruption measures.

As in the previous year, no incidents of bribery and corruption were reported to us throughout the AIXTRON Group in the 2023 reporting year. In addition, adherence to our compliance requirements is confirmed in writing on a quarterly basis by the senior management team and by employees in key positions.

Reports of possible violations of international and national laws as well as our company- wide compliance guidelines and rules of conduct can be reported directly to AIXTRON's Compliance Department and via AIXTRON's Whistleblowing System.

Responsibility within the supply chain

AIXTRON places the same expectations and conditions on its suppliers as it does on itself. These are defined in a mandatory supplier manual.

This defines the ethical and legal framework for social and ecological standards, e.g. with regard to corruption, or conflict minerals such as raw materials and mineral resources that are mined or extracted in conflict areas.

In addition to the price and quality of the purchased goods, compliance with these standards is a fundamental prerequisite for long-term cooperation (see chapter “Conflict minerals”).

AIXTRON does not currently fall within the scope of the German Supply Chain Compliance Act (LkSG). Nevertheless, AIXTRON endeavors to maintain a compliance program based on the LkSG for the protection of human rights and the environment in AIXTRON's business and supply chain in order to promote compliance with human rights and environmental standards as a basis for sustainable development and to meet AIXTRON's claim to be a reliable and responsible business partner (see also chapter Key figures on supplier relationships).

Conflict Minerals

Competition for natural resources such as minerals, oil, and charcoal promotes the systematic violation of human rights and environmental pollution worldwide. Proceeds from the extraction of raw materials help fuel armed conflicts and finance civil wars. Production or mining of these materials often takes place illegally and outside state control, controlled by groups of rebels or militias, and at the expense of the miners.

AIXTRON is committed to conducting its business fairly and with decency and respect in all countries where the company is present. Therefore, AIXTRON supports the objectives of both the US Dodd-Frank Act and the EU Conflict Minerals Regulations to disclose the origin of risky minerals used in our products. As part of its due diligence, the AIXTRON Group has implemented a management system for this purpose, based on the OECD Guidelines for responsible supply chains of minerals from conflict-affected and high-risk regions.

All direct suppliers who may be supplying materials with potential conflict minerals are contacted and asked to identify the countries of origin of the minerals and report them to AIXTRON. Should this reveal the use of a raw material supplier that is linked to human rights violations and environmental pollution, we react consistently and work to ensure that this supplier critically examines the raw material supplier in question and removes it from the joint supply chain. In order to enable internal and external persons and stakeholders to raise indications, concerns, and complaints in connection with conflict minerals - anonymously if desired - AIXTRON has established a complaints mechanism, which can be viewed on the AIXTRON website, among others.

Conflict Minerals

Competition for natural resources such as minerals, oil, and charcoal promotes the systematic violation of human rights and environmental pollution worldwide. Proceeds from the extraction of raw materials help fuel armed conflicts and finance civil wars. Production or mining of these materials often takes place illegally and outside state control, controlled by groups of rebels or militias, and at the expense of the miners.

AIXTRON is committed to conducting its business fairly and with decency and respect in all countries where the company is present. Therefore, AIXTRON supports the objectives of both the US Dodd-Frank Act and the EU Conflict Minerals Regulations to disclose the origin of risky minerals used in our products. As part of its due diligence, the AIXTRON Group has implemented a management system for this purpose, based on the OECD Guidelines for responsible supply chains of minerals from conflict-affected and high-risk regions.

All direct suppliers who may be supplying materials with potential conflict minerals are contacted and asked to identify the countries of origin of the minerals and report them to AIXTRON. Should this reveal the use of a raw material supplier that is linked to human rights violations and environmental pollution, we react consistently and work to ensure that this supplier critically examines the raw material supplier in question and removes it from the joint supply chain. In order to enable internal and external persons and stakeholders to raise indications, concerns, and complaints in connection with conflict minerals - anonymously if desired - AIXTRON has established a complaints mechanism, which can be viewed on the AIXTRON website, among others.

AIXTRON's ability to work towards completely conflict-free smelters worldwide as part of its supply chain is limited. In order to maximize the influence and impact of conflict-free sourcing, we decided to join the Responsible Minerals Initiative (RMI) many years ago.

Privacy compliance

Handling the personal data of our customers, employees and other important stakeholders in a legally compliant and trustworthy manner is our top priority. For many years, data protection has been anchored in our company through forms of guidelines, standards, and processes. The requirements of the European Union's General Data Protection Regulation (EU GDPR), which has applied in all member states since May 2018, are taken into account in our data protection guidelines. These data protection guidelines are subject to regular review and further development, such as our overarching data protection guideline.

In implementing the legal requirements, we are supported and advised by an external, independent data protection officer. We did not report any incidents to our data protection officer or the relevant authorities for the reporting year 2023.

Information Security

The protection of our business and trade secrets as well as the protection of sensitive data is of very high importance to us as a global technology company with high innovative strength. In times of advancing digitization and networking in our society, the threat of cyber espionage and sabotage is also growing. Information security has played an essential role for years and enjoys a very high priority because attacks on our IT infrastructure can lead to the loss or violation of the integrity of this sensitive and confidential data. Our "Information Security" department is part of the independent corporate governance organization and is tasked with continuously identifying, analyzing, and evaluating potential vulnerabilities in our organization and infrastructure together with our IT department and other specialist departments. Based on these results, suitable protection mechanisms are integrated into our existing information security environment and their effectiveness is monitored.

In addition to technical and organizational measures, our employees and their awareness in dealing with sensitive and confidential data play a very important role. Our company- wide training program and the mandatory participation of our employees in regular Information security training sessions are key components in promoting awareness. Our existing information security environment is subject to continuous further development in order to protect our business and trade secrets as well as sensitive data in the best possible way. In fiscal year 2023, we were not aware of any incidents relating to breaches of our information security.

Quality management and product safety

German Sustainability Award 2023 - Pioneer of transformation

AIXTRON was a finalist in the Mechanical Engineering category in 2023. The certificate stated that AIXTRON is one of the companies "that demonstrate particularly effective, successful and exemplary contributions to transformation in their fields [...]".

We enjoy a leading position in the market, resulting from a great deal of trust placed in us by our customers. For us, it is both an obligation and an incentive to ensure our technical excellence, first-class service and high-quality standards at all times.

We consistently pursue a zero-defect strategy in our promise of quality and the safety of our equipment. This is the claim we make on ourselves, as well as on our suppliers. It is not only our self-image to comply with all legal product requirements, standards and norms as well as safety aspects and proper labelling.

It is also part of our self-image to implement all local requirements in our customer markets. For this reason, product safety begins with our product development and accompanies the entire procurement and production process.

Formal, overarching responsibility for product safety and quality lies with the Executive Board, which has assigned the goals and tasks to the Head of Quality Management. Our Quality Department is responsible for the further development of our quality management system, issues company-wide regulations and regularly checks compliance with them. The quality manual and the quality policy describe the core of our actions and are publicly available.

Guidelines and processes ensure both our product safety and product development and regulate the handling of possible defects at appropriate escalation levels. Our Head of Quality Management regularly informs the Executive Board about significant developments and possible quality incidents that could be classified as critical.

In fiscal 2023, no significant quality defects were identified that had a material impact on the health and safety of our customers.

Key figures of supplier relations

Due to the high value added contribution in the supply chain, the procurement process is of high importance for AIXTRON's long-term success. We do not manufacture mechanical and electrical systems and components ourselves, but focus on development, configuration and final assembly.

We place a high value on working in partnership with our suppliers. This is expressed, for example, through development partnerships in which we jointly develop components and assemblies with suppliers. Decisive factors for the selection of suppliers are primarily quality, manufacturing competence, delivery reliability, and price.

Furthermore, we require compliance with applicable laws, regulations, and the provisions of our supplier manual. In addition, we demand that international minimum standards in the area of sustainability, such as the core labor standards of the International Labor Organization (ILO), are met. We do not tolerate the use of conflict minerals within the supply chain.

We currently work with 1,385 suppliers from 28 countries (2022: 1,202 suppliers from 28 countries).

The risk analysis process as part of the compliance program for the protection of human rights and the environment in the supply chain, which is based on the German Supply Chain Due Diligence Act (LkSG), is carried out at AIXTRON in a multi-stage process and uses the methodology of the LkSG, in which a large number of quantitative and qualitative data sources are used to assess human rights and environmental risks.

The aim of the multi-stage process is to identify and prioritise risks in the company's own business area, at direct suppliers and, in the event of substantiated knowledge, at indirect suppliers at an early stage. The structured prioritisation enables a structured filtering out of risk-free business areas and suppliers as well as a focus on a more in-depth examination of critical business areas and suppliers. The process enables AIXTRON to derive effective and appropriate preventive and remedial measures for prioritised risks or risk areas.

17 supplier audits had been conducted in the current reporting year 2023 (2022: 32 audits)

We encourage our suppliers to establish management systems in the areas of quality, energy and environment, risk management, data security, sustainability and social and labour law standards.

The cooperation extends to suppliers, e.g. from the mechanical and plant engineering sector, and the electrical engineering sector, but also engineering service providers as well as suppliers of technical gases or even energy suppliers. AIXTRON is an international company but still has local roots.

Despite global purchasing, local value creation plays a very important role for us. The reason for this is, among other things, the high technical demands on our suppliers and the short communication channels. In Germany, for example, 53% (2022: 59%) of the purchasing volume is procured. The decisive factor for the selection is always that the supplier meets our high-quality requirements, has the necessary manufacturing expertise, and offers competitive prices.

Associations and initiatives

We are involved in a variety of organizations and associations to further promote ecologically sustainable development and resource efficiency in photonics and semiconductor technology. We are a founding member of Photonics21, now a Private Public Partnership (PPP) with the European Commission and the International Solid State Lighting Alliance (ISA) in China, and actively promote their further development.

Carbon Disclosure Project (CDP) / MSCI

Since 2010, as part of our participation in the Carbon Disclosure Project (CDP), we have reported once a year on the environmental impact of our business activities and our corporate strategy to reduce CO₂ emissions. In this way, AIXTRON promotes transparency for investors, companies, political decision-makers, and the media. AIXTRON achieved a D rating in the current reporting year 2023. In the MSCI rating, we were able to keep the score on high level AA.

Part of the national initiative „Energy-Efficiency-Network“

Since 2016, we have been involved in the "Energy Efficiency Network" as a founding member together with five other companies in the Aachen region. The aim of the network is to identify and realize economic energy-saving potential in companies. In recent years, more than 60,000 megawatt hours of energy have already been saved, avoiding more than 18,000 tons of CO₂ emissions. AIXTRON has also been able to leverage the benefits of the network, with its quarterly meetings, for its energy and climate footprint. In 2022, we renewed our membership in the Energy Efficiency Network and plan to continue our participation in the coming years. The network is part of the nationwide "Energy Efficiency Networks" initiative launched by the German government and leading German industry associations and organizations. The goal of the initiative was to save up to 75 PJ of primary energy or 5 million tons of GHG emissions by 2020 through the initiation and implementation of around 500 new energy efficiency company networks. In September 2020, the German Federal Ministry for Economic Affairs and Energy (BMWi) commissioned the continuation of the project until 2025, now under the title "Initiative Energy Efficiency and Climate Protection Networks". By the end of 2025, the initiative aims to establish 350 new networks, saving nine to eleven terawatt hours of final energy and five to six million tons of GHG emissions.

Memberships in organizations and associations