Code of Ethics

Ethical conduct and sustainable business practices are fundamental values at WIWOX GmbH Surface Systems (hereinafter “WIWOX”). WIWOX is not only committed to complying with the law, but also takes responsibility for implementing the standards it has set itself.
We support the implementation of these principles in the fields of human rights, labour standards, the fight against corruption and environmental protection.
The following Code of Ethics is the basis for management, employees and customers to work together to implement those principles. The values and principles defined in this Code of Ethics govern our conduct and behaviour within the company and towards third parties. Personal commitment from each of us is necessary to achieve the standards in this Code of Ethics.

1. Objective and scope
This Code of Ethics is intended to provide all employees at WIWOX with guidance on how to act responsibly, ethically and in compliance with the law at work every day. All our employees must familiarise themselves with the content of this Code of Ethics and must put the Code of Ethics into practice.
This Code of Ethics is constantly being developed and adapted to the current legal, economic and social environment. Specific details may be described in instructions, which must themselves comply with this Code of Ethics.
Given the complexity of the business world, this Code of Ethics cannot cover all issues. Every employee should therefore always ask the following questions before taking any action:

• Am I sure that my actions comply with law and internal policies and that they are morally right?
• Are my actions in the company’s interests, unaffected by any personal interests that are contrary to the company’s interests?
• How would my actions be perceived by the public?
• Could my actions damage WIWOX’s reputation?

2. Acting lawfully and responsibly
WIWOX always complies with applicable law and legislation, with the obligations it has entered into contractually or voluntarily and always with its own internal policies as well. Any failure to comply is not tolerated and employees are never instructed not to comply.

3. Participation in the UN Global Compact
WIWOX is committed to implementing the principles of the UN Global Compact in all its business relationships and expects its business partners to act according to the same principles.

4. Respect and fairness in business relationships
WIWOX treats all business partners with respect and fairness. We choose our business partners on the basis of objective criteria and without discrimination. No business partner may ever be discriminated against or excluded, unless a partner fails to comply with this Code of Ethics.

5. Equal opportunities; discrimination, harassment and bullying
5.1 WIWOX is committed to ensuring equal opportunities for all its employees.
5.2 No one shall be discriminated against or given preferential treatment on the grounds of gender, ancestry, race, language, nationality or origin, marital status, age, disability, faith, religious beliefs or political beliefs. Employees, job applicants and business partners must not be disadvantaged on the grounds of any of the characteristics in the previous sentence and such characteristics must not be used as a basis for decision-making in the course of business.
5.3 Harassment and bullying of employees, job applicants and business partners, including on social networks, is not allowed.
5.4 Any behaviour that disrespects the human dignity of another person, discriminates against another person or harasses another person is prohibited.
5.5 Managers at WIWOX act as role models under this section 5 of the Code.

6. Atmosphere at work and professional development
6.1 At WIWOX, we work in an atmosphere of mutual respect and trust for each other.
6.2 At WIWOX, we require and promote autonomy and innovation in our employees. We set ourselves demanding, clear, objectively achievable and reviewable goals. To achieve our goals, we delegate decision-making powers and associated responsibility to relevant employees. WIWOX provides employees with opportunities for promotion and personal development.
6.3 WIWOX is committed to promoting the professional development of all genders on an equal basis and believes in ensuring equal opportunities between employees of every gender.
6.4 WIWOX supports a working life that is compatible with family live and strives to achieve a balance between work and private life.

7. Anti-corruption and gifts
7.1 Corruption is strictly prohibited at WIWOX. WIWOX shall not enter into business and/or engage in business that is in breach of the anti-corruption regulations or our internal policies.
7.2 Gifts, such as invitations and other benefits, may only be given or accepted if there is no impression or suggestion that they will influence decisions. Invitations and hospitality must serve a business purpose and must be appropriate.
7.3 Gifts to public officials are subject to stricter rules and must therefore be avoided as far as possible. Exceptions are low-value gifts or invitations.

8. Conflicts of interest
8.1 Employees have a duty to be loyal to their employer.
8.2 Conflicts of interest must be avoided. Potential conflicts of interest must be reported as soon as possible.
8.3 Employees must report significant shareholdings (> 5%) in competitor companies or business partners to the Compliance department.

9. Occupational health and safety and environmental protection
9.1 As an employer, we ensure that our employees work in a safe and healthy environment. Accidents and hazards to health must be avoided.
9.2 At WIWOX, the environment requires special protection. Our work must not be harmful to employees or the environment and the impact of our work must be kept as low as possible.

10. Confidentiality and data privacy
10.1 Confidential information and the company’s trade and business secrets must kept secret during and after employment.
10.2 Insider information must not be disclosed to third parties.
10.3 Personal data may only be collected, processed and used for predefined, explicit and lawful purposes. We always follow the principle that only as much information should be collected as necessary, and no more.
10.4 We always comply with the principles of proper bookkeeping and accounting.

11. Communication
11.1 Official statements, in particular to the media, are only made at WIWOX by people authorised to make such statements.
11.2 Employees must always make it clear on social media, internet forums and similar platforms that they are speaking for themselves and not on behalf of WIWOX. As soon as the company name comes up, every employee must engage in dialogue with respect and responsibly.
11.3 Employees must not discredit WIWOX, communicate confidential information or mention the names of employees or business partners.

12. Intellectual property
We respect the intellectual property of third parties and protect it accordingly.

13. Secondary employment
Secondary employment must be reported and requires the approval of management. Approval will be given if there are no legitimate interests to the contrary on behalf of the employer.

14. Breaches and sanctions
14.1 Any breaches of this Code of Ethics can be reported to management at any time via our internal control system.
14.2 Breaches of this Code of Ethics, work instructions or statutory regulations that are also punishable by law must be reported to management (see section 15.1).
14.3 As an employer, we guarantee that any circumstances reported in accordance with sections 15.1 and 15.2 will be promptly investigated.
14.4 If there are potential breaches that are punishable under criminal or administrative law, we shall involve the relevant authorities, as an employer. Regardless of action by the authorities, employees will be held accountable with disciplinary measures under civil and/or labour law (ranging from a warning to dismissal without notice), depending on the severity and extent of the breach.
14.5 Employees who report potential breaches shall not be disadvantaged in any way. In particular, they will not be subject to any disciplinary action. This applies even if the investigation concludes that there has not been a breach. We maintain the strictest confidentiality in such matters.

15. Implementing and final provisions
15.1 Responsibility
Management is responsible for all questions regarding compliance with this Code of Ethics. Management shall advise employees on all matters and cases of doubt regarding the provisions of this Code of Ethics.
15.2 Duty of superiors to provide information and monitor compliance
All supervisors shall ensure that their subordinates are regularly made aware of the contents of this Code of Ethics. Supervisors must demonstrate exemplary behaviour by following and implementing this Code of Ethics. Within their area of responsibility, supervisors shall ensure that their subordinates comply with the provisions of this Code of Ethics.
15.3 Responsibility of all employees
All employees at WIWOX must comply with the provisions of this Code of Ethics.