1. Relationships with government and administration

Regardless of the Country, we will always comply with Government-related laws and regulations and will not give or promise donations to any individual politicians, or other political organizations/parties, beyond the scope of that permitted by law.

Furthermore, with respect to public officials (including deemed public officials) and/or politicians, etc. who have influence over business negotiations and similar matters, we will not enter into any relationship that entails the provision of advantages, such as business entertainment or gifts, etc. that may be construed as bribery or that shall infringe relevant laws and regulations or equivalent provisions, or foreign laws and regulations, conventions or other similar requirements.

2. Maintaining and promoting Free and Fair Competition
We will not behave in a manner that creates obstacles to free and fair competition in compliance with relevant laws and regulations.

3. Handling of Intellectual Property Rights
We will respect the intellectual property rights of others and make every effort not to infringe upon such rights.

4. Handling of Confidential Information
Trade secrets – We will always protect the trade secrets of our company.

We will strictly protect confidential information of others acquired through business transactions with them and we will not pass such information to other parties, nor will we illegally seek access to trade secrets of others.

Personal data/information – We will strictly and adequately protect personal information in compliance with relevant laws, regulations and internal rules
Insider information– We will not deal in financial instruments of any kind (for example stock) based on insider information, nor make insider information public in any way or utter respective recommendations.

5. Handling of Tangible Assets
We will handle any company equipment, documents and other company properties carefully and responsibly. We will take care that these means are treated in accordance with company procedures and guidelines.

If temporarily entrusted with third party company assets as part of our business transactions we will aboid any damage, loss or carless handling thereof.
We will never – especially in connection with investigations or inquiries alter, hide, or destroy important or confidential business documents, as long as this is not permitted by law or internal regulation.

The company’s computer systems are the property of our company. Any utilization outside of the company’s interest is executed in compliance with internal regulations.

6. Stance to Anti-social Individuals/Groups
We will shut out any relationship with corrupt individuals and entities that pose a threat to social order and safety.

7. Relationship between the Company and Employees

Respect for Human Rights

We will respect fundamental human rights and will not behave in a manner that might imply discrimination or abuse of the dignity of individuals.

We will actively and strongly advocate equal opportunity employment and prevent discrimination against race, ethnic background, gender, religion or weltanschauung, disability, age or sexual identity. This is also true for other inappropriate discriminations for example based on social standing.
We will not misuse the power of a superior position nor behave in a manner that might be considered as discriminatory practice or mental abuse or physical violence or sexual harassment.

Exclusion of Unfair Labor Practice

We will abide by labor laws and regulations and will never commit illegalities such as unfair labor practice, forced labor, or child labor in any aspect of our corporate activities.

Safety and Health at the Workplace

We will abide by the related laws and regulations and create good working conditions for our employees to protect any adverse effects with regards to mental as well as physical wellbeing.

Respect for the Opinions of Others

We will respect the individual personality and opinions of others. We will explicitly ask our employees to express criticism (positive and negative remarks).

We will express proposals, concerns, and complaints in a manner which respects the rights and dignity of others.

No employee may be discriminated in any way due to having expressed his personal opinion.

Responding to Illegal or Unethical Conduct

We will inform our immediate superior or the Compliance Officer in case we encounter any conduct that we suspect illegal or a violation of our ethics policy.

We will refuse any order to commit illegal or unethical acts. We will refer such incidents directly to the Compliance Officer when put at a disadvantage for our refusal to commit such acts.

8. Complying with Laws and Regulations Aimed at Contributing to World Peace

We will comply with all laws and regulations aimed at maintaining world security and peace. We will not engage in any business transaction that threatens the maintenance of world peace.

We will strictly control our export activities, both goods and services in compliance with relevant laws, regulations and our internal export control program.

9. Environmental Protection

We will make every effort, including internal education of employees, to fulfil existing requirements for environmental protection and reduce detrimental effects on the environment for every aspect of our business activities upfront.

We will strictly adhere to the respective company regulations.

We will promote our environmental preservation activities.

10. Conflict of Interest

(a) Employees will not engage in any activity that might create a conflict between interests of the company and their own individual interests

11. Politics, Communication, Marketing, Events

We strive to keep our business dealings politically unbiased and as a general rule do not support any party political activities- neither by participation nor by contributions of any kind.

With regards to external communication the employees will strictly adhere to the regulations of the “Code of Conduct Guideline” and other internal company rules.
All our activities in the areas of marketing / sales / promotion will be carried out in a fair, honest and lawful manner and will be checked for compliance with statutory regulations.

When organizing or participating in a gathering of competing companies we will always observe our internal rules to secure lawful conduct and to avoid any misconduct of participants especially with regards to fair competition.

12. Accountancy, Controlling

All our business transactions will always be duly approved and justifiable, legitimate and coherent. Internal company guidelines, especially internal approval procedures for processing and recording business transactions and investments will always be applied. We will ensure that employees act solely within the realm of their personal authority.

We will support the fight against illegal money-laundering as an important element for battling organized crime and terrorism by appropriate internal provisions.

The contact persons for queries and doubts with regards to lawfulness are the immediate superiors or the Compliance Officer.

With regards to controlling financial transactions we observe applicable embargo regulations and measures for fighting terrorism.