Fair play at the highest level

Our employees must inform themselves about the laws, regulations, guidelines, voluntary commitments and internal instructions that apply to their areas of responsibility. In the event of doubt, advice must be obtained from their supervisors.

Basic conduct requirements

All employees are obliged to:

• Comply with the laws, regulations, guidelines, voluntary commitments and internal instructions that apply to their areas of responsibility
• Be fair, respectful and trustworthy in all activities and business relationships
• Respect and foster the company’s reputation
• Avoid conflicts of interest between business and private matters
• Not gain any unlawful advantage for themselves or others
• Comply with occupational health and safety, environmental protection and data protection regulations
• Report compliance violations immediately to the contact persons listed at the end of this document

Supervisors are also obliged to:

• Comply with the company’s management principles
• Assess employees in a non-discriminatory manner according to their performance
• Ensure compliance with this policy in their area of responsibility

Equal treatment

Disadvantages for reasons of race as defined by the General Act on Equal Treatment (AGG), ethnic origin, sex, religion, ideology, disability, age or sexual identity are strictly prohibited. This applies in particular to dealings with colleagues, employees and business partners as well as to the recruitment, promotion or dismissal of employees.

Ban on bribery and corruption

It is strictly forbidden to:

• Offer, promise or grant a personal advantage to German and foreign public officials for the performance or non-performance of an official act
• Offer, promise or grant illegal personal advantages to employees or representatives of German or foreign companies
• Carry out bribery actions with the help of others, for example relatives, friends, agents, advisors, planners and intermediaries
• Support other people’s wrongful actions

Prevention of conflicts of interest

All employees must strictly separate their private interests and the interests of the company. The appearance of a conflict of interest should be avoided. In particular, the following are not permitted:

• Orders to associated people (such as spouses, relatives, friends and private business partners)
• Orders to companies where associated people work
• Orders to companies in which associated people have a stake of 5% or more
• Secondary activities for competitors
• Secondary activities for business partners

Exceptions can only be permitted by the company management.
Employees who would like to invest directly or indirectly in a competitor with 5% or more or are already invested must report this to the company management. It will be verified whether a conflict of interest exists.

Combatting money laundering

The company only cooperates with reputable business partners who operate within the framework of legal regulations and do not use illegal financial resources. All employees must comply with the law against money laundering and report suspicions of money laundering to the respective accounting management and compliance contact persons without delay.

Collaboration with customers and suppliers

The company expects employees, customers and suppliers to:

• Comply with all applicable laws, regulations, guidelines, voluntary commitments and internal instructions
• Not engage in corruption
• Respect human rights
• Comply with child labour laws
• Comply with international trade legislation
• In particular, comply with export and import bans and embargo regulations
• Protect the health and safety of all employees
• Comply with relevant national laws and international standards on occupational health and safety, environmental protection and data protection
• Ensure that these points are also implemented and adhered to in their own supply chain

Invitations, gifts and other personal advantages

In principle, employees should not demand, be promised or accept personal advantages for themselves or for people who are close to them. Employees should only accept personal advantages (for example, invitations to restaurants or to sporting events or gifts) if this does not create the impression that something is expected in return.

The advantage must be in the context of generally common business practices and must not violate any laws. In Germany, gifts worth a total of 35 euros per person per year are permitted to business partners and can be claimed as a business expense (Section 4(5) of EStG). In addition, promotional items (calendars, pens, keyrings, etc.) of less than 10 euros per item can be distributed. The procurement or manufacturing costs are decisive.

Occupational health and safety, environmental protection and data protection

In the interests of the health and safety of all employees and visitors, all employees at their workplace must comply with the applicable laws, regulations and standards regarding occupational health and safety. All employees are jointly responsible for environmental protection in their area of work and are obliged to comply with the laws, regulations and standards regarding environmental protection. Personal data may only be collected, used and stored in accordance with applicable data protection laws. Company and business data must be treated confidentially and may only be used within the scope of the task.

Protection of company assets

Supervisors need to establish an organisation within their area of responsibility that protects the company’s assets from loss and abuse. The company’s assets may not be used for private purposes. The purchase and sale of corporate assets must be transparent, comprehensible, economical and at fair market conditions. The personal interests of individual employees must not influence decisions and economic transactions.

Conduct towards competitors

• Competition law and antitrust law must be observed
• No prices, quantities or conditions can be agreed with competitors
• Agreements with competitors regarding market sharing are not permitted
• In general, contact with competitors must be kept to the absolute minimum necessary.

Donations

The company makes monetary and non-cash donations for non-profit and charitable purposes such as education, science, art, culture and social issues within the limits of a planned budget. Donations are effected exclusively by the company management; employees are free to make appropriate proposals.

Consequences of compliance violations

Compliance violations can have the following consequences for employees:

• Formal warning
• Termination
• Compensation claims by third parties
• Financial penalties, imprisonment
• Fines and ancillary measures

Compliance violations can have the following consequences for the company:

• Compensation claims by third parties
• Costly court cases
• Financial penalties, fines
• Loss of image

Contact persons

In addition to your supervisors, the following contact persons are available to you for questions regarding compliance and to report any violations of the Compliance Guidelines applicable within the company by company employees:

• General legal matters: Head of the Legal department
• Labour law issues: Human Resources Manager
• Technical regulations: Head of Quality Management
• Finance & Risk Controlling: CFO