Code of Conduct

Ostseestaal GmbH & Co. KG's code of conduct for corporate behaviour

Preamble

All employees of OSTSEESTAAL GmbH & Co. KG are bound by the provisions of this Code of Conduct. It sets out the values, principles and procedures that govern the corporate and operational behaviour of OSTSEESTAAL GmbH & Co. KG. The aim of the management is to comply with ethical standards and to create a working environment that promotes integrity, respect and fair behaviour. A business policy that complies with the law and principles serves the long-term interests of the company and its stakeholders such as customers, employees and suppliers. This Code of Conduct was adopted by the management of OSTSEESTAAL GmbH & Co. KG and approved by the shareholders.

Compliance with laws and other regulations at home and abroad

In all business decisions and actions, OSTSEESTAAL GmbH & Co. KG must comply with the applicable laws and other relevant regulations in Germany and abroad. Integrity and honesty should promote fair competition in relation to our customers and suppliers.

Commitment of the company management

OSTSEESTAAL GmbH & Co. KG considers it its duty to act economically, socially and environmentally consciously. All employees of OSTSEESTAAL GmbH & Co. KG are therefore required to conduct their business competently and ethically and to protect fair competition in all markets in which we operate by complying with the applicable laws on anti-trust, competition and other restrictions on competition. Unfair advantages over customers, suppliers or competitors must be avoided.

Conflicts of interest

OSTSEESTAAL GmbH & Co. KG expects its employees to be loyal to the company. All employees must avoid situations in which their personal or financial interests conflict with those of OSTSEESTAAL GmbH & Co. KG come into conflict. In particular, it is therefore prohibited to participate in companies of competitors, suppliers or customers or to enter into business relationships with them in a private environment if this could lead to a conflict of interest. Conflict situations as such should not jeopardise the interests of OSTSEESTAAL GmbH & Co. KG as such. Such conflicts of interest can arise in many situations: For example, no employee may accept benefits - in any form whatsoever - that could reasonably be expected to influence or affect business decisions or transactions of OSTSEESTAAL GmbH & Co. KG or could influence them. Invitations must be within the scope of customary business hospitality. Employees should not jeopardise their position at OSTSEESTAAL GmbH & Co. KG through direct and/or indirect access to confidential information. All employees are obliged to protect the legitimate interests of OSTSEESTAAL GmbH & Co. KG without restriction. Possible competitive situations with the company are to be avoided. Any actual or potential conflict of interest must be reported and discussed with the responsible line manager.

Prohibition of corruption

OSTSEESTAAL GmbH & Co. KG does not tolerate corruption and bribery. Behaviour in which business is to be conducted by improper means is not accepted. The employees of OSTSEESTAAL GmbH & Co. KG employees may not offer or accept any unfair advantages from business partners if these could compromise an objective and fair business decision. All employees are required to inform the management of any endeavours by third parties.

Fair working conditions

All employees of OSTSEESTAAL GmbH & Co. KG are obliged to orientate their actions towards a safe and healthy environment. All statutory safety regulations and their adequate implementation in corresponding company rules must therefore be strictly adhered to. This also applies in principle to compliance with third-party rules, insofar as this is necessary for the fulfilment of contracts and the provision of services. In these cases, the rules of third parties supplement the company's own rules. As a socially responsible employer, OSTSEESTAAL GmbH & Co. KG considers its employees to be very valuable and bears a high level of responsibility as part of its duty of care. It demands a high level of commitment from its employees and shares its business success with them in return. The personnel policy of OSTSEESTAAL GmbH & Co. KG contributes to offering every employee the opportunity for professional and personal development. The open exchange of opinions, criticism and ideas is encouraged. OSTSEESTAAL GmbH & Co. KG condemns unlawful discrimination or harassment of any kind.

Dealing with internal knowledge

All employees of OSTSEESTAAL GmbH & Co. KG are obliged to ensure a rapid and smooth exchange of information within the company. The information must be passed on correctly and completely to the departments/employees designated for this purpose, unless in exceptional cases, in particular due to confidentiality obligations, there are overriding interests. Relevant knowledge must not be unlawfully withheld, falsified or selectively passed on. Dishonest reporting within the company or to external organisations or persons is strictly prohibited. All annual financial statements and annual reports, business papers and books of OSTSEESTAAL GmbH & Co. KG must correctly reflect the business transactions and records and comply with the statutory provisions and the accounting principles and internal bookkeeping of OSTSEESTAAL GmbH & Co. KG. and its shareholders.

Dealing with assets

All employees of OSTSEESTAAL GmbH & Co. KG are responsible for the proper and careful handling of company property. Every employee is obliged to protect the property of OSTSEESTAAL GmbH & Co. KG against loss, damage, misuse, theft, misappropriation or destruction. This also applies in principle and without restriction to the property of third parties. Every employee is obliged to inform their superior immediately of any use of assets to the contrary.

Discretion and data protection

A large proportion of the business information of OSTSEESTAAL GmbH & Co. KG is confidential or legally protected, so that a duty of confidentiality exists. This does not apply if the information is published by OSTSEESTAAL GmbH & Co. KG or is required to be published by law or regulation. The duty of confidentiality applies in particular to intellectual property. This includes business secrets, patents, trademarks and copyrights, but also business and marketing plans, drafts, business papers, salary data and all other unpublished financial data and reports. All personal information about employees, customers, business partners, suppliers and other third parties stored at OSTSEESTAAL GmbH & Co. KG is used carefully and treated confidentially in compliance with data protection regulations. The protection of this information must be carried out with the utmost care.

Implementation and monitoring

The rules contained in this Code of Conduct are a central component of the corporate culture of OSTSEESTAAL GmbH & Co. KG. Compliance with these principles is essential. Every employee is responsible for this. If an employee has concerns or complaints about the points listed in this Code of Conduct or is aware of possible violations, they must immediately ask their line manager for clarification. This can also be done anonymously or confidentially. If an employee is not satisfied with the clarification, he or she can submit the concern or complaint not only to his or her superior, but also to the management. OSTSEESTAAL GmbH & Co. KG does not permit reprisals on the basis of complaints made in good faith within the framework of this Code of Conduct. OSTSEESTAAL GmbH & Co. KG. will regularly update this Code of Conduct if this is necessary due to changes in business circumstances or legislation.

Responsibility

All employees and members of the management of OSTSEESTAAL GmbH & Co. KG are bound by the rules of this Code of Conduct. Violations of this Code of Conduct will have consequences. In serious cases, this can lead to termination of the employment relationship.

Status: 04.2020