This code of conduct is binding for all employees, directors and officers, and companies of the Schober Group, hereinafter referred to as employees.

Each employee is obliged to comply with high ethical standards and all applicable national and international laws. Every employee must act fairly, respectfully and trustworthily in all activities and business relationships and uphold and promote the reputation of the Schober Group. Every employee is obliged to respect human rights and actively support their protection. Every employee should ensure that they do not participate in human rights violations. Any form of discrimination, harassment or other dishonest behavior based on gender, age, race, skin color, ethnic or national origin, religion, ideology, sexual identity or orientation, marital status, disability or any other legally protected characteristic is prohibited. Any form of child or forced labor is prohibited, as are working conditions or treatment that violate national laws or international agreements. The right to freedom of association and collective bargaining is recognized.

Environmental protection is a high priority for the Schober Group. This is why we handle resources and pollutants in a responsible manner and take the development and prevalence of environmentally friendly technologies into account.

Each employee has an obligation to protect corporate assets from abuse and loss. As a matter of principle, corporate assets may only be used for business purposes unless private use is authorized. Each employee is also obligated to protect the intellectual property of the Schober Group, e.g. patents, brands and expertise, from attacks or loss. The intellectual property of others is to be respected.

Business secrets and other sensitive information must be handled confidentially and protected from disclosure to unauthorized persons. This also applies for inventions and other expertise. Employees that have access to business secrets and other sensitive information may not pass them on to third parties without authorization or use them for purposes other than business purposes. Business documents and IT systems are to be protected from unauthorized access by third parties. Personal data may only be collected, used and stored according to the applicable data protection regulations.

Antitrust law is intended to secure and maintain free and genuine competition in the interest of all market participants. Each employee is thus obligated to observe the applicable antitrust laws and other laws intended to regulate competition.

Corruptions including extortion and bribery, is rejected in any kind of business dealings both domestically and abroad. We shall forego a business transaction and the achievement of internal targets if such can only be achieved by breaking the law. The following are prohibited in particular:

• Offering, promising or granting a domestic or foreign officeholder a personal, financial or other advantage for the performance or omission of an official act
• Offering, promising or granting members or representatives of domestic or foreign companies personal, financial or other advantages
• Allowing acts of corruption to be carried out with the help of others, e.g. with the help of relatives, friends, dealers, advisors or brokers
• Supporting the illegal actions of other individuals
• Encouraging or accepting personal, financial or other advantages from business partners or their employees.
• Gifts and invitations within the scope of business relationships with business partners that stay within the framework of common business hospitality, customs and politeness and do not violate any laws are exempted from the above bans.

The employees of the Schober Group are obligated to avoid activities that could lead to a conflict of interest. As a matter of principle, there is to be no awarding of contracts to closely affiliated individuals (e.g. spouses, domestic partners, relatives and friends) or to companies at which closely affiliated individuals are employed in a key function or in which they hold a significant share or for which they act as our negotiation partner.

The Schober Group only works together with reputable business partners that act within the guidelines of legal regulations and do not use illegal funds. Each employee is obligated to comply with the laws against money laundering and immediately report suspicious moments that may indicate money laundering.

Every employee must adhere the European regulations and laws that limit free trade between nations for security and foreign policy reasons. Export bans and limitations as well as sanctions against countries, organizations and persons, including limits in means of payment, must be adhered according the European regulations.

The Schober Group will ensure that the code of conduct is observed in an active and ethically responsible manner. All employees of the Schober Group must support this code. Actions that do not comply with this code should be reported to compliance@schober-gmbh.de in order to be investigated and corrected immediately. Violations are subject to appropriate disciplinary measures that could lead to termination of the employment contract without notice and claims for damages.