Preamble

Our anti-corruption policy is intended as a guideline for the entire bartolome röder AG and therefore applies equally to all of us. Specifically, it is aimed at top management, executives and all our employees and suppliers. On the one hand, it represents the demands we place on ourselves to live up to the values and principles set out therein and, at the same time, signals responsible conduct towards our business partners, customers and employees to the outside world.

bartolome röder AG considers it its duty to conduct its business competently and on an ethical and moral basis and to compete fairly in all markets in which it operates. This includes compliance with applicable laws and the acceptance of antitrust prohibitions and restrictions on competition. We want to avoid gaining undue advantages over customers, suppliers or competitors.

1. acceptance of gifts

1.1 Gifts to our employees

Our employees do not demand or accept any personal benefits from customers or suppliers that could influence or affect their own behavior with regard to their work for the company.

If gifts are offered by third parties, they may only be accepted if they are common practice and can be recognized as a courtesy or favor (promotional gifts with the logo of the giving company, such as calendars or pens).

The management must be informed of gifts with a value exceeding the usual amount. If this is not possible, these gifts must always be refused.

1.2 Gifts from our employees

Gifts on our part may also only be offered within the usual framework for the business relationship and to a materially appropriate extent. The person receiving the gift must not be able to associate it with any obligation that would influence their business decisions.

2. donations

As a matter of principle, bartolome röder AG does not donate to political parties, individuals or organizations whose goals contradict our corporate philosophy or damage our reputation. The allocation of donations is always transparent.

3. bribery and corruption

We do not tolerate any form of corruption or bribery, regardless of whether it damages our company assets or the assets of third parties. We use control mechanisms to ensure that bribery, theft, embezzlement, fraud, tax evasion and money laundering are prevented.

Our employees are prohibited from accepting or granting favors of any kind (cash, trips, gifts, etc.) that are linked to an improper advantage (awarding of contracts, project bonuses, etc.).

Our business partners are also required to avoid conflicts of interest that entail a risk of corruption.

4. compliance with applicable law

We require our managers to familiarize themselves with the laws, regulations and rules that are relevant to their area of responsibility and to comply with them without exception. Our managers in particular bear a high level of responsibility in fulfilling the anti-corruption guidelines.

The business practices of our business partners and their suppliers must also comply with the applicable laws. This applies in particular to the import, export and domestic trade in goods, technologies or services, but also to payment and capital transactions.

Violations of economic embargoes and trade, import and export control regulations by our business partners must also be ruled out, as must the financing of terrorism.

5. commitment of the company management

bartolome röder AG undertakes to make the necessary efforts to comply with the principles and values described in this Anti-Corruption Policy.

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