Compliance

Compliance Guidelines of sth-systeme GmbH

(sth-systeme GmbH is abbreviated below as “sth-systeme”)

Objectives

This policy serves to prevent violations of legal provisions, in particular competition law, and of the internal policies of sth-systeme.

Its aim is to inform about the most important prohibitions of competition law and to set out clear requirements for conduct in order to prevent violations. It concentrates on the essential prohibitions that matter for day-to-day work.

Basic requirements for conduct

Every employee is obliged to:

• comply with the laws, regulations and internal instructions that apply in their area of responsibility
• behave fairly, respectfully and reliably in business dealings
• respect and promote the reputation of sth-systeme
• avoid conflicts of interest between business and private matters
• not obtain unlawful advantages for themselves or others
• comply with the provisions on occupational safety, environmental protection and data protection
• report compliance violations to the management without delay

Every supervisor is also obliged to:

• assess employees solely on their performance
• ensure compliance with this policy in their area of responsibility

Discrimination

Our appreciation is equally high for all employees. No one may be disadvantaged because of nationality, gender, religion or belief, disability, age or sexual orientation.

We are all obliged to respect the personal dignity of others and expect friendly and fair treatment among ourselves and towards third parties.

Cooperation with business partners and third parties

In working with customers and business partners, sth-systeme expects employees to ensure

• compliance with all applicable laws
• refraining from corruption
• respect for human rights
• compliance with laws against child labour
• observance of the legal provisions of international trade
• protection of the health and safety of all employees
• compliance with the relevant national laws and international standards on occupational safety, environmental protection and data protection.

Conflicts of interest

sth-systeme expects absolute loyalty to the company from its employees.

All employees must avoid situations in which their personal or financial interests conflict with those of the company. Unavoidable personal conflicts of interest must be disclosed openly to the management. In case of doubt, consultation with the management is required.

To avoid a conflict of interest, the following orders may only be placed or accepted, and the activities only carried out, if they have been approved in advance by the responsible managing director:

• Orders to or from closely related persons (e.g. spouses, relatives, friends and private business partners)
• Orders to and from companies in which closely related persons work
• Orders to and from companies in which closely related persons hold a stake
• Secondary employment for competing companies
• Secondary employment for business partners

Invitations, gifts and other personal benefits

As a matter of principle, employees may not demand, be promised or accept personal benefits for themselves or for persons close to them. Employees may accept personal benefits

(e.g. invitations to restaurants or sporting events, or gifts) only if this does not create the impression that something is expected in return.

The benefit must be within generally accepted business practice and must not violate any law. In Germany, gifts to business partners with a total value of 35 euros per person per year are permissible and can be claimed as a business expense (Section 4 (5) EStG, German Income Tax Act). In addition, promotional items (calendars, ballpoint pens, folding rulers, etc.) costing less than 10 euros each may be handed out. The decisive factor is the purchase or production cost.

Prohibition of bribery and corruption

To ensure fair competition, bribery and corruption are prohibited without exception. No employee may accept, offer or grant bribes.

It is also prohibited to support, conceal or solicit unlawful acts by third parties.

Environmental protection, occupational safety and health

In the interest of the health and safety of all employees and visitors, every employee must comply at their workplace with the applicable laws, regulations and standards on occupational safety. Employees must comply with regulations and laws on environmental protection.

Data protection

Protecting employees’ privacy includes protecting personal data. Only data that is needed for business tasks and required by law is collected. Access to this data is limited to the employees who need it to perform their tasks, e.g. the HR department. The same applies to data of customers, business partners and other persons.

Employees who have access to personal data must handle this data carefully. It is ensured that this data cannot be lost, published or misused by third parties. The management is available for questions on data protection.

Company-related access data for IT programs, internet platforms, social media platforms and other connections must be protected and must not be noted down where it is publicly visible. Passing it on to third parties (e.g. IT service providers) is only permitted with the approval of the management.

Data protection with external IT service providers is regulated in a separate data protection agreement.

Conduct towards competitors

Competition law and antitrust law must be observed. No information on prices and conditions may be exchanged or agreed with competitors. Likewise, agreements with competitors on dividing up markets are not permitted. These rules also apply to association work.

Consequences of compliance violations

Violations of these rules can make employees, and also sth-systeme as a company, liable to prosecution.

For employees and managing directors, compliance violations can have the following consequences:

• Formal warning
• Dismissal
• Claims for damages by third parties and by sth-systeme GmbH
• Fines
• Imprisonment

For sth-systeme, compliance violations can have the following consequences:

• Claims for damages by third parties
• Reports to the authorities and resulting legal proceedings
• Administrative fines
• Damage to reputation

Contact | Compliance officer

Compliance with the compliance guidelines is of central importance to the management. If compliance violations become known or are suspected, please inform the management directly.