Code of Conduct

1 Preamble

By means of this Code of Conduct, the PROFIL Group commits to their social responsibility towards all employees, customers, business partners and governmental authorities as well as the environment, society and stakeholders.

Our Code of Conduct applies across the company for all activities, internal co-operations as well as those activities involving business partners, governmental authorities and society in general. It lays down the fundamental principles which form the basis for legal and ethical conduct and for the personal integrity of each individual. These are binding for all employees. Due to their leadership position and responsibility towards the employees, each member of management holds a particular role model function.

Similarly the Code of Conduct defines the behavior which we expect of our suppliers and subcontractors of goods and services with respect to their own responsibilities towards people and the environment, competition law and antitrust law, and in international trade.

Our Code of Conduct is dynamic; it does not exclude itself from adapting to the new norms of social behaviour. Legal norms are regularly amended. Our Guidelines can substantiate the Code of Conduct.

2 Our principles

2.1 Social Responsibility and Legal Compliance

We are conscious of our social responsibility. We act in accordance with ethical principles and follow local and international laws and standards. We respect the principles of legality and observe the generally recognized customs of the countries in which we do business, as long as legal standards are not violated. The PROFIL Group’s regulations, guidelines and obligations apply as our minimum standards. This integrity and our respect for the rights of third parties determine our dealings with our employees, business partners and the social environment. We are aware of our responsibility and act accordingly. We respect and support compliance with internationally recognized human rights and we reject all forms of forced labour and child labour.

2.2 Dealings with Employees

Our principle concern in our dealings with each other is respect of all employees. We do not permit any form of discrimination on the grounds of a person’s country of origin, skin colour, sex, age, religion, disability or personal preferences. Each individual is responsible for ensuring the health and safety of all employees. As a minimum standard we follow the applicable regulations regarding working hours and safety at work.

2.3 Integrity

We expect all employees to actively work for our company, this includes efficient use of available resources, continuously striving for improvement and furthering of their skills. We think inter-divisionally and trans-nationally; we do not accept partial optimization which would burden the whole. Accordingly our guiding principles are based on the principles of empowerment and co-operation based on trust. This includes all employees of the PROFIL Group being adequately informed of all important matters concerning their work and also that they independently seek out this information.

2.4 Competition Law and Antitrust Law

It is strictly prohibited for any employee to take advantage of benefits, or accept preferential treatment specifically during the negotiation, procurement, delivery, processing and payment of orders. The accepting and giving of gifts and other gratuity is only admissible if its value is negligible and within legally permissible limitations. The giver as well as the receiver of such gifts should not be made dependent of each other.

2.5 Corruption, Gifts and Gratuity

Allen Mitarbeitern sind Vorteilsnahme und Begünstigung sowie die Vergabe von Vergünstigungen, vor allem im Zusammenhang mit der Vermittlung, Vergabe, Lieferung, Abwicklung und Bezahlung von Aufträgen untersagt. Die Annahme und Vergabe von Geschenken und sonstigen Zuwendungen ist nur dann zulässig, wenn ihr Wert zu vernachlässigen ist und sich in den rechtlich zulässigen Rahmenbedingungen bewegt. Schenker wie Beschenkter dürfen nicht in eine Abhängigkeit zueinander gebracht werden.

2.6 International Trade

Compliance with international trade agreements, national laws and regulations in place to control international trade and financial transactions, such as the laws and regulations concerning import and export controls, are essential for us. Our employees directly responsible for such matters must know, understand and adhere to all relevant laws, regulations, guidelines and procedures.

2.7 Environmental Protection

The necessary conservation of resources and protection of the environment is illustrated by our corporate practice. Through the active involvement of all our employees, we promote environmentally friendly thinking. Our provisions for environmentally suitable design incorporates our entire product range and all production processes. We take the complete life cycle of the products into account; from the use of raw materials through to product development, production and use of the product and further to disposal and recycling.

2.8 Data Protection

We observe privacy protection regulations when using confidential data and respect the need for security when processing business data, customer and supplier information and industrial and trade secrets. All our employees are obligated to protect these secrets and in no way make them available to any unauthorized third party. All legal and contractual requirements are taken into consideration.

2.9 Relationships with Business Partners

Agreements with our business partners are made thoroughly and unambiguously. Suppliers and service providers are selected purely on a competitive basis. All transactions are conducted exclusively in the interests of the PROFIL Group and not on the basis of personal or private relationships or motivations. We maintain internal procedures to this end (e.g. confidential discussions). We consider our values and Code of Conduct to be essential to long term, successful co-operation.