Code of Conduct of Von Eicken Group

All employees and members of the management of Joh. Wilh. von Eicken GmbH and its affiliated companies (hereinafter referred to as "Von Eicken Group";) are bound by the provisions of this Code of Conduct. It sets out the values, principles and courses of action that determine the actions of the Von Eicken Group. The objective of the company management is to comply with ethical standards and to create a working environment that promotes integrity, respect and fair conduct.

A business policy that is strictly in line with the law and principles serves the long-term corporate interests of the Von Eicken Group.

In all business decisions and actions, Von Eicken Group strives to comply with applicable laws and other relevant regulations at home and abroad. Integrity and honesty promote fair competition, also in relation to our customers and suppliers.

The management of the Von Eicken Group is committed to acting in an economically, socially and environmentally responsible manner. Von Eicken Group is therefore committed to conducting its business competently and ethically and to protecting fair competition in all markets in which it operates by complying with applicable anti-trust, competition and restraint of trade laws. Unfair advantages to customers, suppliers or competitors shall be avoided.

Von Eicken Group expects its employees to be loyal to the company.
All employees must avoid situations in which their personal or financial interests conflict with those of Von Eicken Group. Therefore, in particular, it is forbidden to acquire shares in competitors, suppliers or customers or to enter into business relationships with them in a private capacity, insofar as this may lead to a conflict of interest. Conflict situations must not adversely affect the interests of the Von Eicken Group.
Such conflicts of interest can arise in many situations: For example, no employee may accept benefits - in whatever form - that could reasonably be expected to influence business decisions or transactions of Von Eicken Group. Invitations must remain within the limits of customary hospitality. Employees may not personally gain direct and/or indirect advantages due to their position in the Von Eicken Group and the associated access to confidential information. All employees have a duty to promote the legitimate interests of Von Eicken Group as far as possible. Any competitive situation with the company is to be avoided.
Any actual or potential conflict of interest must be reported and discussed with the superiors concerned.

Von Eicken Group is against corruption and bribery. Conduct in which business is conducted by unfair means will not be tolerated. Von Eicken Group employees must not offer, receive or accept any benefits  from business partners that could compromise or even appear to compromise an objective and fair business decision.

All Von Eicken Group employees must provide a safe and healthy working environment. Safety regulations and practices must be strictly adhered to.

As a socially responsible employer, Von Eicken Group considers its employees to be of great value. The personnel policy of the Von Eicken Group contributes to offering every employee the opportunity for professional and personal development. Open exchange of opinions, own ideas and objective criticism are expressly desired and encouraged.

Mutual respect forms the basis for a working environment characterised by mutual appreciation. Von Eicken Group protects human dignity and respects the human rights and personality of individuals in the workplace. Any kind of discrimination is strictly prohibited and must be avoided. In particular, discrimination on the grounds of race or ethnic origin, gender, religion or belief, disability, age or sexual identity is not permitted. Von Eicken Group does not tolerate sexual harassment in the workplace. Sexual harassment includes unwanted advances and touching, suggestive jokes, otherwise sexually motivated language, unwanted display and visible placement of pornographic images, and demanding sexual favours through the use of pressure or promises.
Von Eicken Group does not accept other discriminatory harassment, threats, intimidation or bullying in the workplace. Work colleagues will not be ridiculed or excluded. Von Eicken Group does not tolerate forced or child labour, whether within Von Eicken Group or at our suppliers and customers.

The consumption of alcoholic beverages and/or other addictive and intoxicating substances (drugs) impair the decision-making ability of individual employees and increase the risk of accidents at the workplace. The general accident prevention regulations prohibit every employee from consuming alcohol and/or drugs that endanger themselves or others and prohibit the continued employment of persons under the influence of alcohol and/or drugs. Von Eicken Group employees start their working day free from the influence of alcoholic beverages and/or drugs. The consumption of alcohol and/or drugs during working hours and work breaks is strictly prohibited. The ban on alcohol and drugs applies both on Von Eicken Group premises and at external workplaces as well as on business trips and journeys outside Von Eicken Group premises. Collective agreements can regulate the existing alcohol and drug ban more strictly and more extensively.

All employees of the Von Eicken Group are obliged to ensure a quick and smooth exchange of information within the company. Information must be passed on correctly and completely to the areas concerned, unless in exceptional cases, in particular due to confidentiality obligations, overriding interests exist. Relevant knowledge may not be unlawfully withheld, falsified or selectively passed on. Dishonest reporting within the company or to organisations or persons outside the company is strictly prohibited. All financial statements and annual reports, business papers and accounting records of Von Eicken Group must accurately present business events and transactions and comply with legal requirements and Von Eicken Group's accounting policies and internal accounting procedures.

All Von Eicken Group employees are responsible for the proper and careful handling of the companys property. Every employee is obliged to protect Von Eicken Group's property against loss, damage, misuse, theft, embezzlement or destruction. Every employee is obliged to inform his or her superior immediately of any use of Von Eicken Group assets that contravenes the above regulations.

Much of Von Eicken Groups business information is confidential or legally protected, so there is a duty of confidentiality. This does not apply if publication of the information has been approved by Von Eicken Group or is mandatory by law or regulation. The duty of confidentiality relates in particular to intellectual property. This includes business secrets, patents, utility models, trademarks and copyrights, but also business and marketing plans, cost and price calculations, customer lists, drafts, business papers, salary data and all other non-published financial data and reports.

All personal information about employees, customers, business partners and suppliers as well as other third parties is used carefully in the Von Eicken Group and treated confidentially in full compliance with data protection laws. The utmost care must be taken to protect this information.

The rules contained in this Code of Conduct form a core part of the Von Eicken Groups corporate culture. Consistent compliance with these principles is essential. Every employee of Von Eicken Group is responsible for this. If an employee has concerns or complaints about the points listed in this Code of Conduct or knowledge of a possible breach of the behavioural guidelines contained herein, he or she should immediately bring this to the attention of his or her superior for clarification. This may also be done anonymously or in a confidential manner. If an employee is not satisfied with the resolution provided by the supervisor or if the concern or complaint involves the supervisor, the employee may also bring the concern or complaint to the attention of the Legal Department, Human Resources Department or the Works Council. Von Eicken Group does not permit retaliation for complaints made in good faith under this Code of Conduct.
This Code of Conduct has been agreed with the employee representatives of the Von Eicken Group. It must be brought to the attention of every employee.

All employees and members of the management of the Von Eicken Group are bound by the rules of this Code of Conduct. Violations of this Code of Conduct will be punished. In serious cases, the consequences for the offending person may extend to termination of employment.

August 2018

The Management                                                                    The Employees Representation