1. Conduct in the Business Environment

a) Avoiding conflicts of interest
The companies of Gienanth GmbH make business decisions exclusively in the Company's best interests. Such decisions are based upon high technical, qualitative, and organizational standards as well as the principles of respect and trust. Conflicts of interest with private matters or other commercial activities should be avoided from the outset or should be disclosed.
We also observe the following principles in our dealings with partners, customers, and employees:

•  No orders may be obtained to the customer's detriment

• Fair formation of contracts and partnerships based upon long-term collaboration in a spirit of integrity
   
• Expectations for partners are based upon the same high standards that we set for ourselves

b) Fair competition (including antitrust law)

We are committed to free and fair competition and we respect our competitors. We make no arrangements and contracts that impermissibly restrict, limit, or preclude competition. Our reputation is based upon our self-imposed standards for quality and performance.

c) Anti-corruption
The core of the Company’s anti-corruption concept is the separation of the Company's interests from the private interests of Gienanth GmbH employees when dealing with business partners and government institutions.
In the course of business transactions, no one involved with the Company may offer, promise, demand, grant, or accept gifts, payments, invitations, or services made in order to impermissibly influence a business relationship, or which may endanger the business partner's professional independence. This is generally not the case for gifts and invitations made within the context of typical business hospitality, custom, and courtesy. In case of doubt, the matter must be reviewed by the Compliance Officer.

d) Combating corruption
Employees should report any corrupt behavior by their colleagues or business partners to the Compliance Officer. All such reports will be treated confidentially. No employee who reports suspected corruption or other behavior to the Compliance Officer in good faith should fear any disadvantages as a result, even if the suspicion turns out to be unfounded.
The Compliance Officer is available to employees for consultation, support on compliance-related issues, protection of employees against unjustified accusations and proactive action to prevent misconduct. All employees are requested to make suggestions and provide input to the Compliance Officer to ensure clear and transparent workflows and organizational structures.

2. Conduct towards Colleagues and Subordinates

a) Equal treatment
Mutual respect and appreciation are of fundamental importance to us. No colleague may be put at a disadvantage or discriminated against based upon his or her origin, ethnicity, religion, predisposition, disability, skin color, sex, or his or her relationship to other persons. This applies to day-to-day working relationships,  the promotion of colleagues, and the recruitment of new employees.

b) Occupational safety
Our employees are the key to our success. Protecting their health and maintaining their productivity is therefore extremely important to us. Through clear workplace safety rules and verification of compliance with these rules, we create an accident-free and ergonomically sound work environment. In doing so, we consider compliance with statutory regulations to be the minimum standard.

3. Conduct within the Company

a) Sponsoring
We are aware that in addition to our economic role, we also have a social duty to fulfill within the society. We fulfill this duty by supporting associations and charitable institutions.

b) Public appearances and communication
We respect the right to freely express opinions and protection of privacy. Each employee should therefore be aware that even in his or her private sphere, he or she is always a part and a representative of the Company. When expressing opinions privately, every employee must take care to protect the reputation of Gienanth GmbH. This applies in both private conversations and in the media.

c) Gifts and gratuities
Accepting gifts and gratuities is generally prohibited if their value exceeds EUR 35. We respect country-specific and organization-specific rules and regulations. If the value of a gift or gratuity exceeds this amount, the Compliance Officer decides upon its further use. A decision must be made as to whether the gift is to be surrendered to the authorities or can be returned to the party who gave it. If neither alternative is possible, then the gift must be sold and the proceeds donated to a charitable organization.
Approval must be obtained from the employee’s supervisor and the Compliance Officer prior to accepting invitations to customer events, recreational activities, and the like. The employee must be informed of the monetary benefit of a visit to such an event, which may be subject to taxation. Occasional business entertainment within the customary scope is permitted (no luxury restaurants, no excessive alcoholic beverages, etc.). The employee shall report to the Compliance Officer afterward concerning the circumstances of the business entertainment, the reason, the persons invited, and the location.

d) Sustainable protection of environment and climate
We assume responsibility for the environment by acting in a sustainable fashion. Our approach to environmental protection focuses on an efficient use of all resources. Compliance with the applicable laws is a matter of course with us. In addition, we have made a voluntary commitment to obtain certification in accordance with environmental and energy guidelines, and to monitor compliance at regular intervals.

4. Handling Information

a) Confidential company information/Insider knowledge
We take the necessary steps to protect confidential information against access by third parties. Company employees who possess specific information concerning circumstances that are not publicly known may not divulge this information under any circumstances, regardless of whether this is done voluntarily or through a gross disregard of the need for reasonable care.

b) Data protection and information security
The protection of personal data is of particular importance for Gienanth GmbH. We collect data only when needed for direct order fulfillment or as statutorily required. Data may not be collected or processed without the consent of the affected persons.

5. Protection of Company Property

We always use the Company’s property and resources in a proper and responsible manner. We protect it against loss, abuse, and theft. We use the resources entrusted to us exclusively to fulfill tasks that are directly related to the Company’s success. Our employees are responsible for ensuring that travel undertaken in connection with achieving business goals is economically planned and carried out. In doing so, we protect our Company’s intellectual property as well as its physical property.

6. Compliance Officer

A Compliance Officer agreed upon by Company management and the Works Council will be appointed for implementation of the guidelines.
The Compliance Officer must ensure the independent and objective handling of all matters with which he/she is entrusted. He/she may not be subjected to any disadvantage because of this activity.
If the Compliance Officer establishes sufficient initial suspicion of a violation of Company rules, he/she shall notify Company management and the Works Council. The Compliance Officer shall maintain confidentiality regarding the names of informants, unless the informant explicitly gives consent for the disclosure of his/her name to Company management and the Works Council.

7. Company’s Duty of Implementation

The Company is obligated to ensure that all employees as well as Company management work in compliance with the Code of Conduct. Should the Company order employees to undertake actions in violation of the Code of Conduct, or should it tolerate such actions, particularly despite notification of violations by the Compliance Officer, the Works Council shall be entitled to a claim against the Company for compliance with this guideline and with the Code of Conduct.

8. Conduct within the Company

a) Sponsoring
We are aware that in addition to our economic role, we also have a social duty to fulfill within the society. We fulfill this duty by supporting associations and charitable institutions.

b) Public appearances and communication
We respect the right to freely express opinions and protection of privacy. Each employee should therefore be aware that even in his or her private sphere, he or she is always a part and a representative of the Company. In expressing private opinions, every employee must take care to protect the reputation of Gienanth GmbH. This applies in both private conversations and in the media.

c) Gifts and gratuities
Accepting gifts and gratuities is generally prohibited. We respect country-specific and organization-specific rules and regulations.

d) Sustainable protection of environment and climate
We assume responsibility for the environment by acting in a sustainable fashion. Our approach to environmental protection focuses on an efficient use of all resources. Compliance with the applicable laws is a matter of course with us. In addition, we have made a voluntary commitment to obtain certification in accordance with environmental and energy guidelines, and to monitor compliance at regular intervals.

9. Handling Information

a) Confidential company information/Insider knowledge
We take the necessary steps to protect confidential information against access by third parties. Company employees who possess specific information concerning circumstances that are not publicly known may not divulge this information under any circumstances, regardless of whether this is done voluntarily or through a gross disregard of the need for reasonable care.

b) Data protection and information security
The protection of personal data is of particular importance for Gienanth GmbH. We collect data only when needed for direct order fulfillment or as statutorily required. Data may not be collected or processed without the consent of the affected persons.

10. Protection of Company Property

We always use the Company’s property and resources in a proper and responsible manner. We protect it against loss, abuse, and theft. We use the resources entrusted to us exclusively for fulfilling tasks that are directly related to the Company. Our employees are responsible for ensuring that travel undertaken in connection with achieving business goals is economically planned and carried out. We protect our Company’s intellectual property through a comprehensive data protection plan.