Code of Conduct. Code of Conduct. SIGNUM Consulting GmbH

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1 Code of Conduct

2 Introduction has compiled a Code of Conduct that is valid and binding for all employees and contractual partners. Its acceptance and observance are a premise for their tenure. The principles and guidelines entailed in our Code of Conduct depict values that are valid for all. Honesty, respect, trust and integrity towards our employees, vendors and clients build the core of our Code of Conduct. The German Corporate Governance Codex, international agreements and guidelines of the Universal Declaration of Human Rights, the conventions of the International Labour Organization (ILO) and the Global Compact of the United Nations shape the framework for our Code of Conduct. SIGNUM Consulting stands for a rule-compliant and honest behaviour in everyday business. Following rules and norms ultimately leads to sustainable economic success. Our Code of Conduct provides a basis for strong and lasting trusted relationships. With its introduction we want to raise awareness of Corporate Social Responsibility of all of our employees and contractual partners. Eckhard Neumann Managing Director info@signum-consult.com office.ulm@signum-consult.com 1

3 Code of Conduct prepared this Code of Conduct to present its values in terms of honesty, respect, trust and integrity in a transparent manner, both internally and externally. In general, we expect our employees to fully comply with applicable legal requirements in all their activities. This Code of Conduct lays the legal ground for all our activities and defines the ethical behaviour of each of our employees. Conflicts of interest If an employee s own concerns conflict with the company s, then a conflict of interests is at place. Our employees are steered by SIGNUM s interests during the fulfilment of their professional commitments. They are requested to avoid activities that are contrary to SIGNUM s business interests or their professional obligations. They are not allowed to use their position within the company or company information for personal use or for the improper advantage of third parties. Corporate Information Information and data available or made available to SIGNUM Consulting represent one of its most valued assets and therefore to be particularly protected. In accordance with applicable provisions, SIGNUM Consulting handles both customer as well as employee data with the utmost care. These are protected from unauthorized access. SIGNUM Consulting is expressly committed to the protection of personal data. A Data Protection Officer was appointed, who is responsible for data security and compliance with relevant legislation. Discrimination Every employee has to be treated with dignity and respect. Our employees shall not engage in or support discrimination, especially not in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, disability, gender, sexual orientation, membership of associations, or political affiliation. Our employees shall not allow behavior, including gestures, language or physical contact that is sexually coercive, threatening, abusive or exploitative. Any form of infringement is not accepted by SIGNUM Consulting. info@signum-consult.com office.ulm@signum-consult.com 2

4 Health and Safety SIGNUM Consulting agrees to appoint a Safety Officer who is responsible for the awareness of health and safety at work. All personnel have to receive regular and recorded health and safety training, and such training is repeated for new and assigned personnel. A safe, clean and healthy working environment is provided by SIGNUM Consulting. All personnel meet occupational health and safety regulations in their workplace. They are encouraged to report unsafe working conditions to the appointed Safety Officer or to the Managing Director. Protection of the Environment SIGNUM Consulting s employees are expected to comply with all applicable environmental laws. Likewise, it is expected that they perform their activities in a way that natural resources are used as efficiently as possible and environmental impacts are minimized. Prohibition of bribery and corruption SIGNUM Consulting rejects any corrupt and detrimental conduct to business and supports national and international efforts not to influence or distort competition through bribery. None of our personnel may use the business connections of the company for their own benefit or for that of another or to the disadvantage of the company. This means, in particular, that none of our employees is allowed to grant or accept impermissible personal benefits (e.g., money, tangible assets or services) that are intended to influence a fact-based decision. All of our employees are obliged to seek help or advice upon suspicion or legal uncertainty about the existence of white-collar crime or corruption. In this case contact persons are immediate supervisors or the Managing Director. info@signum-consult.com office.ulm@signum-consult.com 3

5 III. Corrective Actions sets binding standards that our employees are expected to meet. This Code of Conduct is intended to help avoiding rights violations and is contributed to letting SIGNUM do its business fair and legally compliant. It is very important for SIGNUM to initiate corrective actions immediately, insofar as the standards are not met

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