Compliance guidelines

Behaviour code for Ethical Company Behaviour within the Reintechnik Group

Preamble

All employees of the companies in the Reintechnik Group are bound by the regulations in this Compliance Guidelines. They stipulate the values, fundamentals and behaviour methods that determine the company dealings of the Reintechnik Group of companies.

The aim of the company management is the maintaining of ethical standards and the creation of a working environment that promotes integrity, respect and fair behaviour. A strict legal and fundamental compliance in the company policy serves the long-term interests of the company.

These Compliance Guidelines have been laid down by the company management at Reintechnik GmbH and have been approved by the shareholders’ meeting.

Compliance with laws and other stipulations domestically and abroad

In all its business-related decisions and dealings, the Reintechnik Group of companies strives to observe the applicable laws and other decisive stipulations both domestically and abroad. Integrity and sincerity promote fair competition, and this applies also to our relationship with our customers and suppliers. Commitment of the company management

The Reintechnik Group of companies is committed to dealing economically, socially and in an environmentally-friendly manner. The Reintechnik Group of companies therefore strives to operate its business competently and ethically and, in all the markets where they are active, to protect fair competition by complying with the applicable laws governing the prohibition of cartels, competition and competition limiting. Unfair advantages with regard to customers, suppliers and competitors must be avoided.

Conflicts of interest

The Reintechnik Group of companies expects loyalty to the company from its employees.

All employees must avoid situations where their personal or financial interests conflict with those of the Reintechnik Group. For this reason, it is particularly prohibited to enter into participation with competitors, suppliers or customers or to deal with them in private if this could lead to a conflict of interests. Conflict situations must not be capable of impairing the interests of Reintechnik Group of companies.

Conflicts of interest such as these can arise in many situations: This means that no employee is allowed to accept any benefit – irrespective of the form – that, when considered in a proper and reasonable manner, it can be assumed that the business decisions or transactions of the Reintechnik Group of companies could be influenced. Invitations must remain within the limits of common business hospitality. Employees must not, as a result of the position in the Reintechnik Group of companies, acquire personal benefits as a result of their access to confidential information, directly or indirectly. All employees have the obligation to promote, as far as possible, the legitimate interests of Reintechnik Group of companies. Any competitive situation with the company is to be avoided.

All actual or possible conflicts of interest must be reported and discussed with your relevant superior.

Corruption prohibition

The Reintechnik Group of companies is against corruption and bribery. Dealings where unfair competition is involved will not be tolerated. Employees of Reintechnik Group of companies must not offer business partners any kind of privileges, and not receive or accept any privileges from them, that could lead to impairment of an objective and fair business decision, or even just awaken the appearance of so doing.

Fair working conditions

All employees of Reintechnik Group of companies are responsible for ensuring a safe and healthy environment. For this reason, safety regulations and safety practices must be strictly adhered to.

As a socially-responsible employer, the Reintechnik Group of companies considers their employees to be of great value. It requires serious commitment from its employees and, in turn, shares its business success with them. The personnel policy at Reintechnik Group of companies contributes to offering every employee the possibility of professional and personal development. We promote an open interchange of opinions, criticism and ideas.

The Reintechnik Group of companies condemns illegal discrimination or harassment of any sort.

Handling internal knowledge

All employees of the Reintechnik Group of companies are obligated to ensure rapid and friction-free exchange of information within the company. Information must be forwarded, correctly and completely, to the relevant departments, unless there are overriding interests in exceptional cases, particularly as a result of confidentiality obligations. Relevant knowledge must not be withheld wrongfully, falsified or forwarded selectively.

Dishonest reporting within the company or with regard to organisations or persons not within the company is strictly prohibited. All annual accounts and annual reports, business papers and business books belonging to the Reintechnik Group of companies must represent the business events and transactions accurately and must comply with the legal requirements and the fundamentals of accounting and the internal accounting system at the Reintechnik Group of companies.

Handling assets

All employees of the Reintechnik Group of companies are responsible for the proper and careful handling of company property. Each employee is obligated to protect the property of the Reintechnik Group of companies from loss, damage, misuse, theft, misappropriation or destruction. Every employee is obligated to inform his superior without delay of any use of assets contrary to the above.

Confidentiality and data protection

The majority of the business information in the Reintechnik Group of companies is confidential or legally protected, so that there is an obligation to retention of confidentiality. This does not apply if publication of the information has been approved by the Reintechnik Group of companies or is obligatory for legal reasons or as a result of regulations.

The obligation to confidentiality refers particularly to intellectual property. This includes business secrets, patents, brands and copyright, and business and marketing plans, draft designs, business papers, salary details and all other unpublished financial data and reports.

All personal information about employees, customers, business partners and suppliers and other third parties are used carefully and confidentially within the Reintechnik Group of companies under full compliance with the data protection legislation. The protection of this information must be fulfilled with the greatest of care.

Implementation and monitoring

The regulations that are included in this code of behaviour form the core of the company culture of the Reintechnik Group of companies. The consistent compliance with these principles is indispensable. Every employee is responsible for this.

If an employee has an issue or complaint concerning the items covered in this code of behaviour, or has knowledge of a potential infringement of the behaviour guidelines contained herewith, they should make these known to their superior for clarification, without delay. This can also be undertaken anonymously or in a confidential manner. The Reintechnik Group of companies does not allow any reprisals based on complaints that are made, in good will, in the framework of this code of behaviour.

Responsibility

All employees and members of the company management team and the shareholders of the Reintechnik Group of companies are bound by the regulations in this code of behaviour.