Foreword

Dear customers, partners, employees,

Since Controlware was founded, our actions have been characterised 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 initiative on the part of each individual. We thrive on our employees actively identifying 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 thus supports us in making the right decisions in our day-to-day activities. For this reason, and in order to make the practices we have followed so far easier to understand for all employees, we have specified our guideline in more detail.

Your management
Bernd Schwefing, Michael Küchen

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 defined 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 across innovation cycles. We convince through performance by means of customer orientation, innovative strength, technological competence and motivated, responsibly acting employees.

In short: we 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 illicit flows of money to illegally obtain advantages in a decision-making process of a business activity is prohibited.

Benefits, for example in the context of invitations or in connection with advertising measures, which serve the purpose of promoting business relationships or presenting products or services, are permissible - insofar as 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 may not have an unreasonably high value and it may not exceed the limits of customary business practice.

With regard to the issuing and acceptance of gifts and donations, we comply with the relevant statutory provisions or the individual contractual provisions agreed with specific customer groups or customers. Donations are only approved by our management and are only made to organisations with which we or our clients 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 with the existing competitive market. We do not inflict damage on competitors that may result from unfair practices such as damage to reputation or discriminatory statements.

1.3 We comply with laws and guidelines.
We will, of course, comply with all applicable national laws and regulations of the countries in whose territory we do business. Business is only conducted with legally compliant business partners. Controlware does not tolerate any illegal or irregular behaviour.

Within Controlware, all internal guidelines set by the management must be followed. All guidelines are available to all employees on the Controlware intranet and are trained at regular intervals.

2 With our entrepreneurial actions we make a positive
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 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 observe the applicable core labour standards of the International Labour Organisation (ILO) in the context of our business activities. The freedom of association of employees within the framework of national regulations is respected. A trusting and purposeful cooperation with employee representatives is a set component of the company's policy. Child labour and forced labour are strictly rejected. Discrimination in employment and occupation is prohibited. Controlware supports the 10 principles of the Global Compact. They carry the vision of an inclusive and sustainable global economy for the benefit of all people, communities and markets, today and in the future. Within our means, we ensure that our business partners align with the principles of the ILO and the Global Compact.

We support people with disabilities by providing them with a working environment that promotes their competence.

2.2 We preserve the environment.
Controlware is committed to environmental and climate protection at various levels of its operations. We comply with applicable environmental laws and regulations. The use of modern innovative technology and the optimisation of business processes help to conserve resources. In this way, we reduce the impact of our business activities on the environment. Efficiency is increased and innovations are used sensibly. Every employee contributes to the protection of the environment and climate through resource-conscious behaviour in his or her 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 competitive service environment. Only with committed and highly qualified employees are we able to fulfil our claim to quality leadership and excellent customer service. For this reason, gaining highly qualified specialists and managers and retaining employees are essential prerequisites for achieving our goals. For this reason, Controlware offers its employees conditions that are in harmony with their needs - a high degree of creative freedom, an adequate income, attractive development opportunities, both professionally and personally, and the compatibility of career and family. Controlware promotes the training of highly qualified professionals through study programmes, 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 atmosphere provides colleagues, customers and business partners with an atmosphere of fruitful exchange. The basis for this is trust and appreciation.

In an environment of trust, the personal dignity, privacy and personal rights of each individual are respected.

Our employees and business partners are treated independently of nationality, skin colour, social origin, ancestry, gender, age, appearance, any disabilities, religion, ideology, political views, sexual orientation or other legally protected characteristics. We do not tolerate discrimination and harassment.

A fact-oriented and requirements-related approach is cultivated, as is 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 daily work, we address it.

3.3 We promote health.
Occupational health and safety for employees is an essential part of our corporate principles. We place great emphasis on compliance with health and safety regulations, which are managed in an organised manner through 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 through health maintenance and health promotion measures.

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. Therefore, we communicate openly and truthfully about the company's business transactions to employees, customers, business partners, the public in general and government institutions.

We ensure that both internal and external reports, records and other documents are in compliance with the applicable legal rules and standards and are therefore always complete, accurate and timely and system-compatible.

In doing so, we also openly address errors and stand by the consequences so that we can learn from them together.

4.2 We ensure confidentiality and data protection.
Controlware commits itself and also its business partners to protect all confidential business information and trade secrets and to use them in accordance with the applicable laws. Confidential information shall be 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 obliged accordingly in writing to treat all documents and information that they receive during and in the performance of a contract as confidential.

Information security is a fundamental part of Controlware's business, which we take into account to the best possible extent through organisation, technical measures and training. All applicable laws and regulations on data protection and IT security are observed. Confidential and personal data are protected by suitable organisational measures and by targeted process-related implementation. Data is collected, used and processed exclusively in accordance with the applicable law. Secret documents, regardless of the storage medium, are stored securely, i.e. only authorised persons have access to them.

4.3 We take care of our resources.
We invest our resources consciously and in the interests of our company. In doing so, we treat the tangible and intangible company assets provided with care and responsibility and use them within the scope of business activities. We protect the company assets from theft, loss or misuse.

5 Binding nature
This Code of Conduct is a binding guideline for every employee of Controlware. Every employee is aware that failure to comply with the Code of Conduct is a breach of our values.

If you perceive or suspect a violation in your daily work encounter with an employee or business partner, we ask you to address this directly, openly and appropriately, in order to bring it to their attention. In doing so, they create the positive possibility of a change in behaviour. If this is not possible, please contact the management, the works council or the human resources department. In addition to the personal approach, it is also possible to write an email to compli-ance(at)controlware.de. The management and the personnel department assure each employee confidential and sanction-free treatment. Reports can also be made anonymously. The anonymised reports should contain sufficient information to enable adequate processing.