Code of Conduct

Preamble

All employees and members of the management board of d-log GmbH are bound to the regulations of this Code of Conduct. It states the values, principles and procedures that define the business conduct of d-log GmbH. The objective of the executive management is the observance of ethical standards and the creation of a work environment that promotes integrity, respect and fair conduct. A strict business policy in compliance with laws and convention serves the long-term interests of the company.

This Code of Conduct has been passed by the executive partners of d-log GmbH.

Observance of Rules and Other Specifications Domestically and Abroad

In all executive decisions and actions, d-log GmbH strives to take into account the applicable rules and other relevant specifications domestically and abroad. Integrity and sincerity promote fair competition, also in relation to our clients and suppliers.

Obligation of the Executive Management

d-log GmbH considers it an obligation to conduct itself in an economically, socially and environmentally conscious manner. d-log GmbH, therefore, strives to conduct its business competently and ethically and to protect fair competition in all markets in which it is actively involved whereby relevant laws regarding cartel prohibition, competition and competition limits are observed. Unfair advantages towards clients, suppliers or competitors shall be avoided.

Conflicts of Interests

d-log expects loyalty to the company from its employees.

All employees must avoid situations in which their personal or financial interests come into conflict with those of d-log GmbH. Therefore, it is expressly prohibited to be involved with competitors, suppliers or clients or to privately enter business relations with them in as far as this can lead to a conflict of interest. It is not permissible to compromise the interests of d-log GmbH through conflict situations.

Such conflicts of interest can arise in various situations: For example, an employee is not permitted to accept gains – in any form whatsoever – whereby it is reasonably assumed that these could influence the business decisions or transactions of d-log GmbH. Invitations must remain within the boundaries of normal business hospitality. Employees shall not personally obtain indirect and/or direct gains through access to confidential information based on their position at d-log GmbH. All employees are obligated to promote the legitimate interests of d-log GmbH as much as possible. Every competitive situation with the company shall be avoided.

Prohibition of Corruption

d-log GmbH is against corruption and bribery. Conduct involving business affairs conducted by unfair means will not be tolerated. Employees of d-log GmbH are not permitted to offer any kind of concessions to business partners or receive or accept any offers which could lead to an impairment of an objective and fair business decision or merely create the appearance of such.

Environment and Resources

d-log is guided by the principles of sustainability and environmental compatibility. d-log GmbH is aware of the scarcity of resources and the responsibility towards future generations. The observance of all pertinent environmental laws, including the regulations of the country where d-log is active for the given situation, is the natural obligation of the executive management, the managers and each and every individual employee of d-log GmbH.

The observance of environmental legislation also guides the development, the manufacturing process and the life of our products and services. We set high standards in consideration of ecological and environmentally compatible aspects particularly with regard to our development, selection of materials and suppliers.

Fair Employment Conditions

All employees of d-log GmbH are responsible for a safe and healthy environment. Therefore, the safety regulations and practice must be strictly observed.

As a socially responsible employer, d-log GmbH values their employees highly. They demand strong commitment from their employees and, in return, shares the company success with them. The personnel policy of d-log contributes by offering every employee the possibility of professional and personal development. Open exchange of opinions, critique and ideas are encouraged.

d-log GmbH condemns unlawful discrimination or harassment of any kind.

Social Interaction

d-log GmbH works together with employees and business partners of diverse nationalities, cultures, religions and ideologies. The interaction with each other is characterized by respect, tolerance, esteem, fairness and openness.

Without exception, d-log GmbH opposes discrimination, harassment, disadvantage, disparagement or any other form of slander as well as the preferential treatment of their employees or business partners based on their ethnic background, gender, religion, ideology, political opinions, a disability, age, sexual identity or other ethical, social and legally protected characteristics. Any kind of harassment at the place of work, in particular sexual harassment, regardless of its form, is generally prohibited. Should this come to pass, it is irrelevant whether the affected person was able to remove themselves from the situation or whether the offender considers his/her behavior as acceptable.

Managers should be aware of their functions as role models and take care to create a discrimination- and harassment-free working environment.

Handling Internal Knowledge

All employees at d-log GmbH are obligated to ensure a quick and smooth exchange of information within the company. Information is to be properly and completely passed on to the departments concerned unless, in exceptional cases, specifically due to confidentiality obligations, there are priority interests. It is not permissible to wrongfully withhold, falsify or selectively pass on relevant knowledge.

Dishonest reporting within the company or to outside organizations or individuals is strictly forbidden. All annual accounts and year-end reports, business papers and account books of d-log GmbH must accurately represent business and other transactions and comply with the legal demands as well as the accounting policies and the internal accounting procedures of d-log GmbH.

Handling Financial Assets

All employees of d-log GmbH are responsible for the proper and sparing handling of the property of the company. Every employee is obligated to protect the property of d-log GmbH against loss, damage, abuse, theft, embezzlement or destruction. Every employee has the obligation to immediately inform his/her superiors of a use of financial assets that is contradictory to the preceding.

Privacy and Data Protection

The majority of the business information of d-log GmbH is confidential or legally protected so that an obligation of confidentiality exists. This does not apply if a publication of the information has been authorized by d-log GmbH or is mandatory on the grounds of laws or regulations.

The confidentiality obligation particularly relates to intellectual property. This includes business secrets, patents, brands and copyrights as well as business and marketing plans, drafts, business papers, payroll data and all other unpublicized financial data and reports.

All personal information about employees, clients, business partners and suppliers as well as other third parties are used with care at d-log GmbH and treated confidentially under complete adherence to data protection laws. The protection of this information must be performed with the greatest care.

Implementation and Monitoring

The laws that are included in this Code of Conduct form a core of the business culture of d-log GmbH. The uniform observance of these principles is essential. Every employee is responsible for this.

In the event an employee has concerns or objections to the points listed in this Code of Conduct or has knowledge of a possible breach of the conduct guidelines contained here, he/she should immediately clarify this to his/her supervisors. This can also be done anonymously or in confidentiality. d-log GmbH does not allow reprisals based on complaints that are brought forward in good conscience in the context of this Code of Conduct.

Responsibility

All employees as well as members of the management board and the board of supervisors of d-log are bound to the regulations of this Code of Conduct. Violations of this Code of Conduct lead to consequences. In serious cases, this can lead to the termination of the employment relations.