1 CHG-MERIDIAN CODE OF CONDUCT Efficient Technology Management
2 CHG-MERIDIAN FOREWORD The code of conduct sets out the core principles of our corporate culture for our employees, business partners, and customers. It is intended to provide guidance and to help prevent misconduct. The behavioral requirements that it describes are mandatory for all employees of the CHG-MERIDIAN group of companies with immediate effect. The philosophy set out in the code of conduct applies equally to all staff members in our company, regardless of the country where they work. It is the foundation for the success of our business and it should continue to guide us in the future. We expect our business partners to adopt similar principles for their business practices and conduct. Weingarten, January 2017 Dr. Mathias Wagner Frank Kottmann Joachim Schulz Oliver Schorer
3 PAGE LEGAL COMPLIANCE AND INTEGRITY We consider it self-evident that the laws and official regulations in force in each of the markets in which we operate must be respected and obeyed. Every employee is responsible for ensuring that we comply with legal, official and internal requirements. Our employees behave professionally and with integrity. For us, behaving with integrity includes treating our business partners fairly, as well as complying with the law.
4 PAGE BRIBERY AND CORRUPTION We seek to conduct our businesses ethically and efficiently and we are constantly working on improving our business processes. For this reason, we support all inhouse and external activities aimed at the prevention of bribery and corruption. We adopt rigorous measures to combat attempted bribery and corruption, regardless of whether they involve our business partners or our own employees. Every offer or commitment we make must comply with the laws in force and any impression of dishonesty or impropriety must be avoided. No payments may be made if they could be interpreted as attempts to influence a public official or corporate representative or to bribe a business partner in order to obtain advantage for the company.
5 PAGE GIFTS AND BENEFITS IN KIND Our employees may not receive, request or implicitly accept promises of any direct or indirect monetary donations, gifts (except customary, low-value gifts to mark occasions) or other benefits or favors from persons with whom they have a business relationship. Contracts awarded by our customers and business partners may never be linked to payments or benefits in kind. Concessions agreed in the hope of receiving future business are prohibited. The purchase or acquisition of goods is only permitted at normal market prices and conditions. It is our policy to keep business and personal expenses separate. If a precise delineation of the two would prove too difficult, particularly where invitations and contributions are concerned, the costs should be met out of personal expenditure.
6 PAGE INDEPENDENCE AND COMPETITION We seek to act independently at all times in our relationships with business partners. Consequently, our sole criteria for entering into business relationships with suppliers or other partners are objective and commercial. Recommendations and commercial or HR-related decisions made in the course of everyday business must not be influenced by personal interests or relationships or motivated by material benefits or benefits in kind. We endeavor to maintain cooperative relationships characterized by transparency with all competent authorities and public-sector clients, and we attach great importance to complying with the procedures required by law for public-sector procurement. Even in competitive environments, we ensure that we compete fairly and do not harm the reputation of other companies or institutions.
7 PAGE TRANSPARENCY AND DATA PROTECTION We firmly believe that transparent communication helps with staff and customer retention. For this reason, we communicate openly with one another and share information among ourselves within the boundaries set by law, by authorities or within the company. We stringently apply these provisions to prevent price fixing as well as other violations. Data-related procedures are part of day-to-day business. We guarantee our customers that we handle their data responsibly and provide high standards of data protection because the use and destruction of data must be transparent and reliable for all involved. Personal data may only be collected if it is clearly necessary for operational purposes and the law that applies at that time allows it. All employees are under an obligation not to disclose to third parties any business secrets, correspondence, and contracts or the contents thereof. They must comply with these provisions indefinitely, including after their employment contract has ended. This applies, in particular, to any non-disclosure agreements (NDAs) that they have signed.
8 PAGE RESPECT AND APPRECIATION Respect, trust, and tolerance define the way we treat one another. We communicate openly and honestly with each other. We consider employee diversity to be a benefit and we show all employees understanding, appreciation, and respect regardless of their ethnicity, gender, age, disability, nationality, or social background. This includes endeavoring to familiarize ourselves with and to understand the ideas and needs of others at all times. We punish all forms of discrimination in accordance with the law.
9 PAGE RESPONSIBILITY AND SUSTAINABILITY As a company, we see ourselves as responsible for our employees, the environment and society, and act accordingly. We would like our commercial activity to make a positive contribution to sustainable development. We integrate environmental considerations into our operational procedures and include them in our business decisions. We provide our employees with a healthy, safe working environment and offer them opportunities for continued professional development. Wherever possible, we incorporate our self-defined role as a responsible company into the general parameters of our business.
10 PAGE COMPLIANCE AND INFORMATION This code of conduct applies to all the companies in the CHG-MERIDIAN group. Every employee is responsible for compliance with it. Internal company systems and policies support compliance with its standards. The managers at our company act as role models for staff and raise awareness of the issues described above. Breaches of this code of conduct are unacceptable and will be subject to disciplinary procedures. Any employee who is aware of or suspects any infringement of statutory, official, or internal regulations is encouraged to report it to their line manager, the directors, or the Compliance department. Data protection regulations will apply to the handling of all such instances. Equally, assurance is given that no such report will be considered to be a breach of confidence and will not lead to adverse consequences for the person making the report, as long as he or she has made it in good faith. We expect this code to be used responsibly and with integrity.