PURPOSE OF THE CODE OF CONDUCT

The Code of Conduct lays out the guidelines for worldwide activities of all employees of Bauwerk Group and its group companies (hereinafter referred to as “BG”).

PRINCIPLE

BG is aware of its economic, environmental and social responsibility to its investors, employees, customers, business partners, the local authorities, the company and the environment. BG believes that ethical conduct is vital for a business to be successful in the long term and in all of its business operations.

Engagement, responsibility, reliability, respect, trust and cooperation are values all employees are committed to and is part of the “BG way”. In daily contact with internal and external partners, the application and implementation of these values, attitudes and related behaviors, is a part of the corporate culture practiced at BG, based on mutual respect.

BUSINESS INTEGRITY

Compliance with laws

Compliance with applicable laws in all countries where BG operates, as well as the relevant international standards.

Corporate governance

Effective corporate governance is vital for a sustainable and successful business. BG ensures that corporate governance practices are up to date, reviewed regularly and adapted, when required.

Cooperation with business partners based on trust

BG maintains a continuous partnership with its customers and suppliers based on openness and mutual trust. BG expects sustainability, social responsibility and compliance with laws and standards from its suppliers.

Fair competition

BG is committed to fair competition based on performance. BG, neither engages in anti-competitive practices, nor does it participate in arrangements that violate antitrust law.

Bribery and accepting an advantage

BG tolerates neither active nor passive bribery. BG does not give any unjustified advantages to members of the government or government authorities or to employees of private companies in order to influence their decisions, nor does BG accept them from third parties either. No one that works for BG may give, request or accept unjustified advantages, such as excessive gifts or benefits, i.e. ones that exceed a customary value. Giving gifts or benefits is in particular prohibited, when business decisions are influenced in an illegal manner, as a result or only left with the impression that such is the case. All donations made by BG must be transparent. Further details described in the BG “anti-corruption guidelines”.

Conflicts of interest

BG strives to prevent conflicts of interest of the management and of the employees wherever possible. All employees are expected to act in the best interests of BG and to put aside personal interests or benefit. All employees are obliged to disclose fully their personal or financial interests in conflict with BG’s interests.

Confidentiality and data protection

BG protects its confidential information and personal data and prevents inappropriate or their unauthorized disclosure. BG employees may neither internally, nor externally, pass on or utilize BG’s trade secrets and industrial secrets during or after their employment. In cooperation with external partners, a suitable non-disclosure agreement to be entered in advance.

Intellectual property

BG protects its intellectual property and respects the applicable intellectual property rights of third parties. BG expects its employees to enforce the intellectual property rights of BG, ensure their protection and use them in a responsible manner.

Product safety

BG is committed to the quality and safety of its products. BG assures the conditions for customers faith in BG’s products in regards to reliability, quality and performance. All BG products comply with national and international statutory standards, as well as internal quality assurance guidelines.

RESPONSIBILITY TO INVESTORS

Suitable return on investment

BG is aware of its responsibility towards private and institutional investors. BG is committed to paying its investors suitable dividend on their investment and adequate compensation for their risk. However, BG refrains from using the prospects of short-term profits as the basis for its decisions. Instead, it uses the long-term and sustainable well-being of the company.

RESPONSIBILITY TO EMPLOYEES

Respectful cooperation

The commitment of its employees and the ability to develop their skills are vital for the success of BG. Therefore, BG is particularly careful to ensure that employees in all countries work with respect, fairness, politeness, honesty and trust.

Employee development

Creating an attractive working environment is very important to BG. This includes the provision of modern workplaces, subject-specific training, as well as individual development and career planning.

Discrimination prohibition

Equal opportunity is a key value for BG and evaluates employees on their performance, skills and conduct. BG does not tolerate discrimination or harassment on gender, race, religion, national origin, age, disability, sexual orientation, marital status or other characteristics protected by law, following the “Human Rights Rules of BG”.

Health and occupational safety

BG promotes the physical and mental well-being of all its employees and sees the employees as the most valuable capital.  Therefore, BG conducts needed actions to prevent their health and ensure their personal safety.

Social partnership

BG respects the promotion of dialogue between BG and its employees and is committed to a functioning social partnership with employees and their representatives.

Compensation

BG provides fair compensation and benefits to employees, in compliance with applicable local laws.

RESPONSIBILITY TO SOCIETY

Dialogue with society

BG recognizes the importance of cooperation with government authorities and associations to make its business ethics a reality. BG strives to maintain an ongoing dialogue with representatives of government authorities and associations.

Human rights and child labor

BG assumes the responsibility being a global business entails with regard to respecting human rights and in particular, the challenges associated with child labor, as set in the “BG Human Rights Rules”.

RESPONSIBILITY TO THE ENVIRONMENT

BG is aware of the environmental impacts of its business operations. BG complies with local and international environmental standards and is committed to continually improve its environmental performance. BG focuses on environmental responsible and sustainable behavior in favor of natural resources within it`s direct and indirect business context.

Sparing use of resources

BG orients all of its activities − from procurement to production and disposal − toward maximum conservation of resources and minimization of emissions. With its products and solutions, BG is committed to deal with the environment in a responsible economic and environmental manner.

RESPONSIBILITY AND IMPLEMENTATION

This Code of Conduct is mandatory for all employees in BG. Each employee is individually responsible for compliance with and implementation of the Code of Conduct. Superiors are role models and set an example of the Code of Conduct, ensuring it is communicated to all employees and is internalized and implemented by the employees. BG has specified further details of this Code of Conduct in internal directives. BG oversees compliance with the Code of Conduct and the directives and adapts them as needed. All employees of BG are called upon to report breaches of the Code of Conduct. When assessing whether a specific practice could constitute a breach of the Code of Conduct, employees shall apply reasonable ethical and moral criteria, use common sense and apply country-specific customs and conventions. In the event of violation of the law, it exists no margin of discretion.

Three internal reporting offices (HR departments of BGLT, BGCH and BGHR) and the Chief Human Resources Officer of BG are available for assistance.

Employees that report breaches in good faith enjoy the full support and discretion of BG and need not to fear any negative consequences. Abusive reports will not be pursued, and may result in disciplinary action. In the event of a breach of this Code of Conduct, disciplinary consequences to be expected. In addition, violations of the law may also result in civil law consequences, such as recourse claims and claims for damages.

ASSISTANCE AND CONTACT PERSONS

If employees are unsure about the application of the Code of Conduct or its directives, BG encourages all employees to seek advice from their superior, managing director or the Head of Legal & Compliance.