Code of Conduct
Controlware Rules of Conduct

Foreword
Dear customers, partners, employees,
Since Controlware was founded, our actions have been characterized by respect, trust and appreciation towards our customers, business partners and employees. We are convinced that the value-oriented, responsible and sustainable entrepreneurial actions of every employee form the basis of our long-term business success. As a management team, we create the environment for this.
Our goal is to deliver the highest quality to our customers. That is why we offer scope for individual initiative. We thrive on our employees actively recognizing opportunities, evaluating them and implementing them together as a team with a high degree of individual responsibility.
This code of conduct reflects our culture and values, describes our guiding principles and helps us to make the right decisions in our day-to-day work. For this reason, and in order to make it easier for all employees to understand our current practices, we have clarified our guidelines.
Your management
Bernd Schwefing, Michael Küchen, Marc Wilczek
1 We strive for long-term positive and stable business relationships with our customers, suppliers and stakeholders.
1.1 We are independent.
Our business relationships are characterized by integrity and competence. High quality and excellent customer service are our key to success. For this reason, customers value us as a preferred partner throughout innovation cycles. We impress with our performance through customer orientation, innovative strength, technological expertise and motivated, responsible employees.
In short: We always make innovations economically viable for our customers time and again. This is the basis of our excellent reputation and the resulting sustainable economic success of the company.
1.2 We stand for fair competition.
We comply with all applicable anti-corruption laws and regulations. Any form of corruption, bribery, theft, extortion and unauthorized cash flows to illegally obtain advantages in the decision-making process of a business activity is prohibited.
Benefits, for example in the context of invitations or in connection with advertising measures that serve the purpose of promoting business relationships or presenting products or services, are permitted - provided they are moderate and ethically impeccable. However, such benefits may only be accepted or granted if they serve a legitimate business purpose and are not accepted or granted in return for an unlawful advantage. The benefit must not be of an unreasonably high value and must not exceed the limits of normal business practice.
With regard to the giving and receiving of gifts and donations, we adhere to the relevant statutory regulations or to the individual contractual arrangements made with specific customer groups or customers. Donations are only approved by the management and are only made to organizations with which we or our customers have no business relationship.
We are committed to fair competition and responsible marketing. We deal honestly and fairly with our customers, suppliers, authorities and manufacturers as well as the existing competitive market. We do not harm competitors through unfair practices such as damage to reputation or discriminatory statements.
1.3 We comply with laws and regulations.
We naturally comply with all applicable national laws and regulations of the countries in whose territory we do business. In this context, we make explicit reference to compliance with the provisions of foreign trade law through an export control system established within the company. Business transactions are only concluded with legally compliant business partners. Controlware does not tolerate any illegal or irregular behavior.
Within Controlware, all internal guidelines issued by the management must be followed. All guidelines can be viewed by all employees on the Controlware intranet and training is provided at regular intervals.
2 With our entrepreneurial activities, we make a positive contribution to the society in which we live and work.
2.1 We respect and promote human rights.
Respect for human rights and the applicable social standards are principles of human coexistence. Working conditions that violate such rights and standards contradict this principle. They will not be tolerated.
With regard to international conventions, we comply with the applicable core labor standards of the International Labor Organization (ILO) in our business activities. The freedom of association of employees within the framework of national regulations is safeguarded. Trusting and targeted cooperation with employee representatives is an integral part of our corporate policy. Child and forced labor are strictly rejected. Discrimination in employment and occupation is prohibited. Controlware supports the 10 principles of the Global Compact. They support the vision of an inclusive and sustainable global economy for the benefit of all people, communities and markets, today and in the future. Within the scope of our possibilities, we ensure that our business partners are guided by the principles of the ILO and the Global Compact.
We support people with disabilities by offering them a working environment that promotes their skills.
2.2 We preserve the environment.
Controlware is committed to environmental and climate protection at various levels of its activities on site and in the supply chain. We comply with applicable environmental laws and regulations. The use of modern, innovative technology and the optimization of business processes help to conserve resources. In this way, we reduce the impact of our business activities on the environment, increase efficiency and make sensible use of innovations. Every employee also helps to protect the environment and climate through resource-conscious behavior in their daily work.
We thus make an active contribution to the conservation of natural resources.
3 Our employees and their competence are our capital.
3.1 We promote development.
We operate in a challenging and competitive service environment. Only with committed and highly qualified employees are we in a position to fulfill our claim to quality leadership and excellent customer service. The recruitment of highly qualified specialists and managers and the retention of employees are therefore an essential prerequisite for achieving our goals.
This is why Controlware offers its employees conditions that are in line with their needs - a high degree of creative freedom, an adequate income, attractive opportunities for professional and personal development, and a good work-life balance. Controlware promotes the training of highly qualified specialists through courses of study, apprenticeships and contact with professional associations.
3.2 We promote diversity.
Diversity provides the framework for innovative ideas and new developments. A friendly, open and fair working environment creates an atmosphere of fruitful exchange between colleagues, customers and business partners. The basis for this is trust and appreciation.
In a trusting environment, the personal dignity, privacy and personal rights of every individual are respected.
Our employees and business partners are treated regardless of nationality, skin color, social origin, ancestry, gender, age, appearance, any disabilities, religion, world view, political views, sexual orientation or other legally protected characteristics. We do not tolerate discrimination or harassment.
We cultivate an objective and requirements-oriented approach as well as cooperation based on trust. We promote equal opportunities and prevent discrimination in all areas, from the recruitment of employees, salary development and promotion to the granting of training and further education measures.
Wherever we encounter discrimination in our day-to-day work, we address it.
3.3 We promote health.
Occupational health and safety for our employees is an essential part of our corporate principles. We attach great importance to compliance with health and safety guidelines, which are organized and controlled by a certified occupational health and safety management system (AMS). Everyone is obliged to follow the applicable regulations and work instructions. All employees are trained in this respect.
We contribute to the health of our employees and their families by taking measures to maintain and promote their health.
4 Sensitive handling of information, data and property is a matter of course for us.
4.1 We communicate openly and truthfully.
We stand for respect and honesty towards our employees, customers and partners. That is why we communicate openly and truthfully about the company's business transactions with employees, customers, business partners, the public in general and government institutions.
We ensure that both internal and external reports, records and other documents comply with the applicable legal regulations and standards and are therefore always complete, correct, timely and system-compliant.
We also address mistakes openly and accept the consequences so that we can learn from them together.
4.2 We ensure confidentiality and data protection.
Controlware undertakes itself and its business partners to protect all confidential business information and trade secrets and to use them in accordance with the applicable laws. Confidential information is used exclusively for the purpose of fulfilling an existing contractual relationship. We regularly train all employees on how to handle this information. Both Controlware and the contractual partner are accordingly obliged in writing to treat all documents and information that they receive during and in fulfillment of a contract as confidential.
Information security is a fundamental part of Controlware's business, and we take the best possible account of this through organization, technical measures and training. All applicable laws and regulations on data protection and IT security are observed. Confidential and personal data is protected by suitable organizational measures and targeted process implementation. Data is collected, used and processed exclusively in accordance with applicable law. Confidential documents, regardless of the storage medium, are stored securely, i.e. only authorized persons have access to them.
4.3 We take care of our resources.
We invest our funds consciously and in the interests of our company. We treat the tangible and intangible company assets provided to us with care and responsibility and use them in the course of our business activities. We protect company assets from theft, loss or misuse.
5 Liability
This Code of Conduct is a binding guideline for every Controlware employee. Every employee is aware that non-compliance with the Code of Conduct is a violation of our values.
If you notice or suspect a violation in your day-to-day work in an encounter with an employee or business partner, we ask you to address this directly, openly and appropriately, in order to draw their attention to it. This creates a positive opportunity for a change in behavior. If this is not possible, please contact the management, the Works Council, the Corporate Governance Risk Compliance Team or the HR department. In addition to the personal approach, it is also possible to write an email to compliance(at)controlware.de.
The management and the HR department ensure that every employee is treated confidentially and without sanctions. Reports can also be made anonymously. The anonymized reports should contain sufficient information to enable adequate processing.