CODE OF CONDUCT 

Message from the management

Dear partners and suppliers of altec,

our mission statement describes the values we share and how we want to work together – today and in the future. It provides us with a clear vision that must be achieved to secure our joint business successes in the long term. Based on the central idea of “partners”, we can only achieve this goal together. In particular, common values, personal responsibility, openness and transparency, as well as legally compliant and ethically correct behavior at all times, play an important role.

This Code of Conduct brings together for the first time in one document our important basic rules and principles, which are binding for us today and in the future. It provides a framework of orientation and applies equally to all business partners involved – to management, to managers and to each individual team member. It sets a standard for us, but at the same time it is a promise to the outside world for responsible behavior towards business partners and the public, but also in our dealings with each other within the company. Together, we are responsible for the
reputation of our companies. The misconduct of individuals can cause enormous damage to all of us. Therefore, I ask all persons involved in business processes to read this Code of Conduct carefully and to use it collectively as a guide for their daily conduct.

Ingo Karsten | CEO altec CS and altec TP

Preamble

Together with our customers, we solve the challenges of the future.

Customer requirements determine our thoughts and actions. We break new ground and develop innovative products and services for sustainable systems and resource efficiency.

We all set ourselves the highest standards.

We act in an entrepreneurial, confident, courageous and performance-oriented manner – with the goal of achieving the reasonable best. The commitment and skills of each individual are the basis for this. Employee development is particularly important to us. Health and safety in the workplace have top priority.

We live shared values.

We act in the overall interest of the company. Openness and mutual respect characterize our cooperation. We build on strong values: reliability and honesty, credibility and integrity. Compliance is something we take for granted. We take responsibility for our society.

The responsibility for society expressed in our mission statement also includes an active commitment to sustainable development, which we support by signing the ten principles of the United Nations Global Compact. We are also committed to the United Nations Universal Declaration of Human Rights and the core labor standards of the International Labor Organization (ILO).

Concrete rules and regulations for individual situations and circumstances in the professional environment are clearly formulated by the relevant corporate guidelines and agreements. These guidelines and agreements are unrestrictedly valid and binding for all altec TP employees. Any of our employees who do not behave in accordance with the company guidelines and agreements must expect appropriate consequences within the framework of company and legal regulations.

Based on this, the present Code of Conduct summarizes the essential principles and rules for our actions and presents the demands we make on ourselves, also towards our business partners and stakeholders.

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Conduct in the business environment

Compliance with laws and regulations

For us, compliance with laws and regulations is an essential basic principle of economically responsible conduct.

We comply with applicable legal prohibitions and obligations at all times, even if this entails short-term economic disadvantages or difficulties for the company or individuals. If national laws contain more restrictive regulations than those applicable at altec TP, national law shall take precedence.

Avoidance of conflicts of interest

At altec TP, business decisions are made exclusively in the best interests of the company. Conflicts of interest with private interests or other economic or other activities, including those of relatives or otherwise related persons or organizations, should be avoided from the very start. If they nevertheless arise, they must be resolved in compliance with the law and applicable corporate guidelines. The requirement for this is transparent disclosure of the conflict.

Fair competition

The Compliance Commitment issued by altec TP’s management is the guideline for our actions in competition: altec TP stands for technological competence, innovative strength, customer orientation and motivated employees who act responsibly. This is the basis for our high reputation and the sustainable economic success of the company in global competition.

Corruption and antitrust violations threaten these guarantees of success and will not be tolerated (zero tolerance). We do not consider bribes or cartel agreements to be a way of obtaining a contract. We would rather forego business and the achievement of internal goals than violate the law. With its compliance concept, altec TP has taken far-reaching measures to ensure that corruption and antitrust regulations and the corporate guidelines based on them are observed. Violations will not be tolerated and will result in sanctions against the persons concerned. All managing directors, all senior executives and all other employees must be aware of the extraordinary risks that a case of corruption or cartel may pose for altec TP, but also for them personally. Every employee is required to actively participate in the implementation of the altec TP compliance concept in his or her area of responsibility.

Prevention of money laundering

altec TP complies with its legal obligations to prevent money laundering and does not participate in money laundering activities.

In case of doubt, every employee is requested to have unusual financial transactions, in particular involving cash, which may give rise to suspicion of money laundering, checked by the responsible finance, legal or compliance department.

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Conduct towards colleagues and employees

Equal treatment and non-discrimination

A culture of equal opportunity, mutual trust and mutual respect is of great importance to us. We promote equal opportunities and prevent discrimination in the hiring of employees and in the promotion or granting of training and development measures. We treat all employees equally, regardless of gender, age, skin color, culture, ethnic origin, sexual identity, disability, religious affiliation or ideology.

Human and employee right

We respect internationally recognized human rights and support their fulfillment. We strictly reject any form of forced or child labor. We recognize the right of all employees to form trade unions and employee representatives on a democratic basis within the framework of national regulations. The right to adequate compensation is recognized for all employees. Compensation and other benefits are at least in line with the respective national and local legal standards or the level of the national economic sectors/industries and regions.

Cooperation with employee representatives

For altec TP, a trusting and close cooperation with the employee representatives is an essential part and a proven cornerstone of the company’s policy. The basis of mutual trust and cooperative cooperation is an open and constructive dialogue characterized by mutual respect.

Occupational health and safety

Alongside the quality of our products and our economic success, the safety and health of our employees are equally important corporate goals.

Occupational safety and health protection are an integral part of all operating processes and are included in the technical, economic and social considerations right from the start – as early as the planning phase.

Each of our employees promotes health and safety in his or her work environment and complies with occupational health and safety regulations. Every manager is obliged to instruct and support his or her employees in fulfilling this responsibility.

Employees of subcontractors working on behalf of altec TP are subject to the same safety standards as our employees. This is taken into account in the selection and cooperation.

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Behavior within society

Sustainable environmental and climate protection

Sustainable environmental and climate protection and resource efficiency are important corporate goals for us. In the development of new products and services as well as in packaging and logistics, we ensure that any resulting impact on the environment and climate is kept to a minimum and that our products make a positive contribution to environmental and climate protection for our customers.

Every employee has a responsibility to use natural resources responsibly and to help protect the environment and climate through his or her individual behavior.

Donations

We see ourselves as an active member of society and therefore get involved in various ways. We make donations and other forms of social commitment solely in the interests of the company.

We do not make any financial contributions, in particular donations and sponsoring measures, to political parties in Germany or abroad, party-affiliated or party-like organizations, individual elected officials or candidates for political office.

Political representation of interests

We represent political interests centrally, openly and transparently.

We comply with the legal requirements on lobbying and avoid undue influence on politics and legislation under all circumstances. We observe the EU Code of Conduct.

Public appearance and communication

We respect the right to freedom of expression and the protection of personal rights and privacy. Every employee should be aware that he or she can be perceived as a part and representative of altec TP also in the private sphere and is therefore requested to protect the reputation and standing of the company by his or her behavior and appearance in public, especially towards the media. In the case of private expressions of opinion, we take care not to place the respective function or activity in the altec TP company in a context with the private expression.

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Dealing with information

Reporting

altec TP is built on strong values: reliability and honesty, credibility and integrity. Thus, we emphasize open and truthful reporting and communication about the company’s business operations to investors, employees, customers, business partners, the public in general, and government institutions. Every employee ensures that both internal and external reports, records and other documents of the Group are in compliance with the applicable legal rules and standards and are therefore always complete and accurate, and are made in a timely and system-compatible manner.

Confidential corporate information/insider information

We take the necessary steps to protect confidential information and business documents from access and insight by non-involved colleagues and other third parties in an appropriate manner. Employees of the company who possess concrete information about circumstances that are not publicly known, and whose public disclosure is likely to significantly influence the market price of financial instruments in the altec TP company, may not trade in shares or other financial instruments of the altec TP company on the basis of this insider information or pass on this information, regardless of whether the communication of the insider information is done willingly or with gross disregard for proper care.

Data privacy and information security

The protection of personal data, in particular of employees, customers and suppliers, is of particular importance to altec TP. We collect or process personal data only if this is absolutely necessary for the performance of the respective work task or if it is required by law. No personal data may be collected or processed without the consent of the person concerned or without being legally permitted to do so. The collection, processing and deletion of personal data is governed by altec TP’s privacy policy.

Protection of company property

We use the company’s property and resources properly and carefully and protect them from loss, theft or misuse. The intellectual property of our company represents a competitive advantage for altec TP and thus an asset worth protecting, which we defend against any unauthorized access by third parties.

We use tangible and intangible property of the company exclusively for company purposes and not for personal purposes unless expressly permitted. Our employees, together with their supervisors, are responsible for ensuring that the nature and extent of business trips are always in reasonable proportion to the purpose of the trip and are planned and carried out economically, taking into account time and cost aspects. More detailed information is provided in altec TP’s travel expense guidelines.

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Implementation and contact persons

altec TP actively promotes the communication of the corporate guidelines and agreements underlying the Code of Conduct. The company ensures that they are implemented and that no employee suffers any disadvantage as a result of complying with the guidelines or agreements.

Our managers have a special role model function and measure their actions against the Code of Conduct to a particular extent. They are the first point of contact for questions on understanding the regulations and ensure that all employees know and understand the Code of Conduct. As part of their management duties, they prevent unacceptable behavior or take appropriate measures to prevent breaches of the rules in their area of responsibility. Trusting and good cooperation between employees and managers is reflected in honest and open information and mutual support.

The central e-mail address codeofconduct@altec-tp.com is also available to all employees and third parties (customers, suppliers, etc.) for further questions relating to the Code of Conduct. Information on possible violations of laws or guidelines in the areas of antitrust law and corruption that affect persons and companies of altec TP can be reported directly to the management at codeofconduct@altec-tp.com. All information will be treated strictly confidential.

altec TechnologyPartner GmbH, Bayernstrasse 10, 30855 Langenhagen, Germany, Phone +49 (0)511 983 81 41

Fax +49 (0)511 983 81 49, codeofconduct@altec-tp.com www.altec-tp.com