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technotrans Investor Relations

compliance - The technotrans code of conduct

About this Code of Conduct

This Code of Conduct is binding for all employees of the technotrans Group.

It defines basic, internationally applicable standards of conduct and describes the conduct that is expected of you. It is the task of management to support their staff in these matters.

An infringement by a single employee can seriously harm the reputation of our company and inflict considerable damage, including financial damage.

technotrans does not tolerate any legal infringements and will not protect anyone responsible for them from sanctions.

Breaches of laws, international standards and internal regulations can result in disciplinary measures (including the end of the employment relationship) and the pursuit of civil or criminal procedures.

Legal infringements can almost always be avoided by seeking early advice. If you are not sure what requirements exist or whether your conduct is perfectly legal and ethical, it is expected that you ask your manager, the relevant department (e. g. Human Resources) or the Compliance Officer.

In addition, all suspected or actual breaches of the law or company guidelines are to be reported.

If in doubt – ask!

  • rights and standards

    Human rights, employment and social accountability standards

    technotrans has the goal of all employees acting in compliance with internationally recognised human rights standards, as well as basic employment and social accountability standards, and is therefore obliged to follow the regulations of the UN Global Compact.

    technotrans champions, in particular, the abolition of any kind of child and forced labour, the principle of non-discrimination, the recognition of freedom of association, collective bargaining and industrial relations, fair pay and benefits, in accordance with local market conditions, reasonable working hours and paid holiday, as well as access to adequate medical care and health insurance.

    technotrans is committed to equal opportunities in the labour market and observes all of the relevant laws, which prohibit disadvantage with regard to age, race, skin colour, gender, sexual orientation, background, religion or disability. This principle applies to all human resources decisions, such as recruitment, hiring, training, job changes, promotion, remuneration, benefits, disciplinary measures and terminations.

    In addition, sexual harassment and other harassment in the workplace is strictly prohibited.

    We act in accordance with internationally recognised human rights, employment and social accountability standards, and strictly observe the applicable laws.

  • health and safety

    Health and safety

    technotrans is particularly concerned about protecting the health of its employees. All employees are obliged to respect the regulations with regard to health protection at all times. You help to avoid dangers to health by following the health and safety at work regulations.

    The statutory, or standard, work regulations for the protection of employees must be observed. A transparent and trustworthy system for recording working hours exists in all of the manufacturing operations of the technotrans Group.

    The statutory driving and rest periods for driving company vehicles must be observed at all times.
    Holidays help employees to stay healthy and must be given every year.

    Each employee is co-responsible for the protection of people and the environment in his or her work environment.

  • cartel law

    Cartel law

    The business policy of technotrans is to promote fair competition. All employees are therefore expected to strictly observe the applicable cartel legislation.

    Agreements between competitors and coordinated conduct between competitors (“horizontal agreements”) are prohibited, if they are intended for or lead to the prevention or restriction of competition. This includes, for example, price agreements, tenders, customer allocations, sales or purchase conditions, production or sales quotations or the division of geographical markets.

    Not only expressly contractual agreements but also concerted actions as a consequence of unilateral statements (e. g. announcements of price increases, which have the goal of causing the same kind of reactions from competitors) are prohibited.

    Every direct or indirect exchange of information between competitors (non-exclusive traders can also count in this connection) is prohibited, e. g. the exchange of information on customers, pricing, costs, salaries, sales conditions, sales methods, market share, production volumes, tender submissions or strategies (e. g. business and research strategies).
    In your contacts with competitors you must take care at all times that no information is accepted or passed on, which allows any kind of conclusions to be drawn with regard to the market conduct of technotrans or its subsidiaries at that time or in the future.

    Particular care should be taken at meetings of associations and other industry meetings, such as trade fairs. The opportunities that are offered there for meetings and discussion may not be used to exchange confidential market and corporate information in order to influence market activity. Even the slightest sign of an infringement is to be avoided.

    In the case of horizontal agreements, the strict regulations of European cartel law must be followed globally – and, indeed, independent of deficient or less strict local legislation.

    Vertical agreements too, i. e. agreements between suppliers and customers or patent holders and licensees are prohibited in the EU, the US and other countries. Such agreements can result in fines or the ineffectiveness of the relevant agreement.
    These include restrictions on the freedom of the customer to set prices or delivery conditions for its business partner (geographical restrictions, restrictions in relation to customers or product applications), certain most-favoured nation clauses, exclusivity ties like total fulfillment of demand or exclusive supply and restraints on competition.

    If in doubt with regard to the admissibility under cartel law of particular conduct, you must refer to your manager or the Legal Department at an early stage.

    Cartel law prohibits agreements between competitors.

  • corruption

    Corruption

    Relationships with all business partners must be based on quality, reliability, competitive prices and the respect of ecological and social accountability standards, and the principles of good corporate conduct.

    Anti-corruption laws in most countries of the world prohibit bribes being given to domestic and international officials, as well as the employees of domestic and international companies in the private sector.

    technotrans therefore prohibits its employees and everyone commissioned by technotrans from being involved in any kind of bribery. When dealing with business partners or officials, you may never demand or accept material benefits (e. g. cash, gifts, entertainment offers or other personal benefits) that can result in the impression of (attempting) to influence business decisions.

    In the same way, employees of other companies or officials may never promise or grant personal benefits with the intention of receiving an order, to secure a business transaction or to create an advantage for technotrans without legal cause.

    All employees are obliged to notify their managers if a business partner or official offers or demands a personal benefit.

    Moreover, so-called “facilitation payments” (i. e. relatively small amounts of money or payments in kind to officials to simplify or accelerate administrative processes or official acts such as customs clearances) are not allowed.

    You may never accept or grant material benefits, which can result in the impression of (attempted) improper influence.

  • gifts and invitations

    Gifts and invitations

    Gifts and invitations may be granted or accepted only if they correspond to a courtesy gesture as part of general business practice and the question of improper influence on a business decision or an official act can be excluded from the outset.

    This also applies to gifts and invitations on the occasion of or as part of official corporate events or business conferences.

    If it is not possible to reject unacceptable gifts tactfully, they can be accepted. In such cases, you must subsequently notify the manager, who must decide how to proceed (e. g. make a donation to a charitable organisation).
    The offering, granting, demanding, or acceptance of cash or contributions that have the nature of cash is never admissible.

    In most countries, gifts and invitations over a certain value are regarded as taxable benefits. You must ensure that the applicable tax regulations are strictly observed. If in doubt, you should refer to your manager or the Human Resources Department.

    Accept gifts or invitations only if they can be seen as a courtesy gesture.

  • conflicts of interest

    Conflicts of interest

    Personal relationships or interests may not influence your business activity. This means that your personal interests may not conflict with the interests of technotrans, nor influence your decision-making, nor create such an impression.

    For example, you must not make any investments, take advantage of interests or represent any organisations, which could cause third parties to doubt your fairness, integrity or objectivity.

    You must notify your manager of every existing or possible conflict of interest and together with him or her seek a solution to avoid the conflict of interest or at least to minimise it.

    Private business interests must be kept strictly separate.

  • IT security and data protection

    IT Security

    All employees are obliged to observe the protection and security regulations issued by the IT Department.

    Data Protection

    technotrans is obliged to respect the privacy and integrity of employees and business partners. Strict standards are observed when the personal data of employees or business partners are processed.

    All personal data that technotrans collects and stores are processed comprehensibly, carefully and exclusively for specific purposes in accordance with the relevant applicable data protection legislation.

    Access to personal documents is limited to technotrans employees and persons who have valid authorisation to do so and have a legitimate business interest in such an inspection. Confidential employee data may not be shared with anyone outside of the company without relevant authorisation or unless there is a statutory reason.

    In case of doubt, the Data Protection Officer or the Legal Department must be consulted for advice.

    Data protection has high priority at technotrans. Personal data are processed for specific purposes only and in accordance with the relevant applicable data protection legislation.

  • export controls

    Export controls

    On the basis of the resolutions of the Advisory Board on Human Security of the United Nations to combat international terrorism, many countries and international communities have issued laws that prohibit any trade with persons, organisations or companies, which are under suspicion of supporting terrorism. With the help of sanctions lists, international terrorism is to be deprived of an economic basis through the prevention of any financial transactions and the use of economic resources. Along with the sanction lists, the EU embargo regulations and the EU dual-use regulation must be followed.

    technotrans has automated systems in place to ensure as far as possible the observance of the trade prohibitions mentioned. All employees are forbidden to make any delivery or payments to addresses that are not in the system and checked. If in doubt, or if the matter is urgent, speak to the Compliance Officer.

    All employees must observe the trade control laws for production or marketing of goods and technologies when buying and selling.

  • money laundering

    Money laundering

    Money laundering is the infiltration of assets (not just cash), which results from criminal acts, into the regular financial and economic cycle. Money laundering is a criminal act in the member states of the EU, the US, China and various other countries.

    No employee may alone or in collaboration with third parties take actions that infringe the applicable anti-money laundering laws.

    If dubious financial transactions are demanded, which have as their object the handing over of cash or other assets, they must be checked and receive clearance from the Board.

    Be alert to dubious financial transactions and if in doubt insist on clearance.

  • protection of property

    Protection of company property and the property of business partners

    Every employee must handle company property responsibly and protect the assets of technotrans against loss, damage, theft, misuse, and unauthorised use. Intangible assets such as proprietary information, intellectual property rights and copyright-protected works also count as company property.

    Confidential information on business partners and their expertise must also be observed and protected. This applies in particular if such information has been entrusted to us as part of a joint venture.

    Company computers and other equipment are for business purposes and are not intended for personal use. No company property may be used for private purposes or removed from the company premises without the express consent of the relevant department.

    All employees must observe the relevant company guidelines on the protection of company property.

  • protection of the environment

    Protection of the environment

    The protection of resources and climate protection are amongst the central challenges of our time. With the recognition of the principles of the Global Compact, technotrans is obliged to give high priority to environmental protection.

    The goals of the waste management concept at technotrans are „avoid“, „reduce“ and “utilise”. For this purpose, an integrated disposal concept for the raw material economy was developed. If possible, reusable materials are deployed. Recyclables and waste are collected separately and disposed of in accordance with the technotrans disposal concept.
    With our own products, too, we pay attention to the acceleration of the development and dissemination of environmentally-friendly technologies.

    Each employee is co-responsible for the protection of people and the environment in his or her work environment.


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