Code of Ethics

Preamble

Ethical and sustainable conduct are fundamental values of WIWOX GmbH Surface Systems (hereinafter referred to as “WIWOX”). WIWOX is committed not only to complying with applicable laws and regulations but also to fulfilling the standards and principles it has set for itself.

We support the implementation of the principles relating to human rights, labour standards, anti-corruption, and environmental protection.

This Code of Ethics forms the basis for the cooperation between management, employees, and customers. The values and principles defined in this Code of Ethics govern conduct and interactions within the company as well as with third parties. Compliance with this Code of Ethics can only be achieved through the personal commitment of every individual.

1. Purpose and Scope

This Code of Ethics is intended to provide all WIWOX employees with guidance for responsible, ethical, and legally compliant conduct in their daily work. Every employee is required to familiarize themselves with the contents of this Code of Ethics and to implement its principles in practice.

The Code of Ethics is continuously reviewed and updated to reflect current legal, economic, and social developments. It may be supplemented by work instructions, provided that such instructions are consistent with the principles set out in this Code of Ethics.

• Given the diversity and complexity of business activities, this Code of Ethics cannot address every possible situation. Therefore, before taking any action, every employee should ask themselves the following questions:
• Am I certain that my actions comply with applicable laws, regulations, and internal policies, and that they are ethically appropriate?
• Am I setting aside any personal interests that are not aligned with the interests of the company
• How would my actions be perceived by the public?
• Could my actions damage the reputation of WIWOX?

2. Lawful and Responsible Conduct

WIWOX always complies with applicable laws and regulations, contractual and voluntary commitments, as well as its own internal policies. Violations of these requirements will not be tolerated, and no instructions contrary to them will be issued.

3. Commitment to the UN Global Compact

WIWOX always complies with applicable laws and regulations, contractual and voluntary commitments, as well as its own internal policies. Violations of these requirements will not be tolerated, and no instructions contrary to them will be issued.

4. Respect and Fairness in Business Relationships

WIWOX treats all business partners with respect and fairness. The selection of business partners is based on objective criteria and the principle of equal treatment. No business partner shall be discriminated against or generally excluded unless they violate this Code of Ethics.

5. Equal Opportunity; Prohibition of Discrimination, Harassment, and Bullying

5.1 WIWOX is committed to ensuring equal opportunities for all employees.

5.2 No person shall be disadvantaged or favoured based on gender, ancestry, race, language, national or social origin, marital status, age, disability, religion, or political beliefs. It is prohibited to treat employees, job applicants, or business partners unfavourably based on any of the above characteristics or to use such characteristics as a basis for business decisions or interactions.

5.3 Harassment and bullying of employees, job applicants, or business partners—including through social media—are prohibited.

5.4 Any conduct that violates the dignity of another person or discriminates against or harasses another individual is prohibited.

5.5 WIWOX managers are expected to act as role models regarding the principles set out in this Section 5.

6. Working Environment and Employee Development

6.1 WIWOX fosters a working environment based on mutual respect, trust, and integrity.

6.2 At WIWOX, we encourage and promote personal responsibility and the innovative capabilities of our employees. We set ambitious, clear, objectively achievable, and measurable goals. To achieve these goals, decision-making authority and the corresponding responsibility are delegated to the respective employees. WIWOX provides employees with opportunities for career advancement and personal and professional development.

6.3 WIWOX is committed to promoting equal opportunities for the professional development of people of all genders and to ensuring equal opportunities for employees regardless of gender.

6.4 WIWOX supports a healthy work-life balance and promotes the compatibility of professional and family life.

7. Anti-Corruption / Gifts and Hospitality

7.1 Corruption is strictly prohibited at WIWOX. WIWOX would rather forgo the conclusion and/or execution of a business transaction than violate anti-corruption laws or internal policies.

7.2 Benefits, including gifts, invitations, hospitality, and other advantages, may only be offered or accepted where there is no appearance of influencing business decisions. Invitations and hospitality must serve a legitimate business purpose and be appropriate in nature and value.

7.3 Benefits offered to public officials are subject to particularly strict scrutiny and should be avoided wherever possible. Exceptions may only be made for low-value gifts or invitations, where permitted by applicable law.

8. Fair Competition

WIWOX complies with all applicable competition and antitrust laws. WIWOX does not enter into anti-competitive agreements or arrangements with competitors, suppliers, customers, or other third parties. WIWOX also ensures that no competitively sensitive information is exchanged and that no other conduct takes place that could unlawfully restrict or distort competition.

9. Export Controls and Economic Sanctions

9.1 WIWOX complies with all applicable laws and regulations governing the import and export of goods, services, and information.

9.2 WIWOX observes all applicable sanctions and restricted-party lists.

10. Conflicts of Interest

10.1 Employees are expected to act loyally toward WIWOX and to safeguard the Company’s legitimate interests.

10.2 Conflicts of interest must be avoided. Any actual or potential conflict of interest shall be disclosed at an early stage.

10.3 Any significant ownership interest (more than 5%) held by an employee in a competing company or a business partner must be disclosed to the Compliance Department.

11. Occupational Health and Safety; Child Labor; Forced Labor

11.1 As an employer, WIWOX is committed to providing its employees with a safe and healthy working environment. Workplace accidents and health hazards must be prevented.

11.2 Child labour is prohibited. WIWOX complies with the minimum legal age requirements for employment in accordance with applicable laws and regulations.

11.3 WIWOX ensures that young workers do not perform overtime or night work. WIWOX protects young workers from working conditions that may be harmful to their health, development, safety, or moral well-being.

11.4 Employment at WIWOX is voluntary. WIWOX does not engage in any form of forced or compulsory labour and rejects all forms of modern slavery and human trafficking.

12. Working Hours; Wages; Social Benefits

12.1 Working hours at WIWOX comply with applicable legal requirements and, where relevant, with the minimum standards of the respective industry sector.

12.2 The wages and social benefits provided to WIWOX employees are at least equal to the minimum requirements established by applicable laws and regulations.

13. Freedom of Association and Collective Bargaining

WIWOX recognizes the right of all employees to establish and join employee representative bodies and trade unions, as well as the right of trade unions to engage in collective bargaining.

14. Environmental Protection

14.1 Environmental protection is of particular importance to WIWOX. During all work activities, every effort shall be made to prevent harm to the environment or, where this is not possible, to minimize environmental impacts as far as reasonably practicable.

14.2 WIWOX is committed to minimizing environmentally and/or health-hazardous air emissions, including greenhouse gas emissions, in all its activities and continuously works to improve air quality. Furthermore, WIWOX strives to minimize water consumption and to improve water quality.

14.3 WIWOX is committed to promoting energy efficiency in all its activities and to taking renewable energy sources into consideration wherever possible.

14.4 WIWOX is committed to preventing and reducing waste in all of its activities. Sustainability is a key concern for WIWOX. The company promotes the reuse and recycling of materials and ensures the safe and environmentally sound disposal of residual waste, chemicals, and wastewater.

15. Confidentiality; Data Protection

15.1 Confidential information as well as business and trade secrets of the company must be kept strictly confidential both during and after the termination of the contractual relationship.

15.2 Insider information must not be disclosed to third parties.

15.3 Personal data may only be collected, processed, and used for specified, explicit, and legitimate purposes. The principles of data minimization and data avoidance shall be observed.

15.4 The principles of proper accounting and financial reporting shall be complied with.

16. Communication

16.1 Official statements, particularly those made to the media, may only be issued by persons authorized to do so by WIWOX.

16.2 When using social media, internet forums, or similar platforms, employees must always make it clear that they are speaking on their own behalf and not on behalf of WIWOX. Whenever the company name is mentioned, employees shall conduct themselves in a respectful and professional manner.

16.3 Any disparagement of WIWOX, the disclosure of confidential information, or the publication of the names of employees or business partners is prohibited.

17. Intellectual Property

We respect and protect the intellectual property rights of third parties. WIWOX strictly rejects any infringement of intellectual property rights, including, but not limited to, plagiarism.

18. Secondary Employment

Any secondary employment must be disclosed and requires the prior approval of the Management. Such approval shall be granted unless legitimate business interests of the employer conflict with the proposed secondary employment.

19. Whistleblowing; Violations and Sanctions

19.1 Reports of violations of this Code of Ethics, internal work instructions, or applicable laws and regulations may be submitted to the Management at any time through our internal control system.

19.2 Violations of this Code of Ethics, internal work instructions, or applicable laws and regulations that also constitute criminal offences must be reported to the body referred to in Section 19.1.

19.3 As an employer, we ensure that every matter reported pursuant to Sections 19.1 and 19.2 is investigated promptly.

19.4 In the event of suspected violations that constitute criminal or administrative offences, WIWOX will involve the competent authorities where appropriate. Regardless of any official proceedings, employees may be subject to civil or employment-related disciplinary measures, depending on the nature and severity of the violation, ranging from a formal warning to summary dismissal.

19.5 Employees who report suspected violations to a competent authority or through the designated reporting channels shall not suffer any form of disadvantage or retaliation, including disciplinary action. This protection also applies if a report ultimately proves to be unfounded, provided it was made in good faith. All reports will be treated with the strictest confidentiality to protect the reporting employee from retaliation.

20. Implementation and Final Provisions

20.1 Responsibility
The Management is responsible for all matters relating to compliance with this Code of Ethics. The Management shall advise employees on any questions or uncertainties concerning the interpretation or application of this Code of Ethics.

20.2 Information and Supervisory Responsibilities
All managers and supervisors shall ensure that their employees are regularly informed about the contents of this Code of Ethics. Managers are expected to lead by example by complying with and implementing the provisions of this Code. Furthermore, they shall ensure, within their area of responsibility, that their employees comply with the requirements of this Code of Ethics.

20.3 Obligation of All Employees
All WIWOX employees are required to comply with the provisions of this Code of Ethics.