Compliance Guidelines IPM Elektromatic GmbH

Code of Ethical Business Conduct of IPM Elektromatic GmbH

All employees of IPM Elektromatic GmbH are bound to the regulations of these

Compliance Guidelines. They set out the values, principles and courses of action which determine the

entrepreneurial actions of IPM Elektromatic GmbH.

The goal of the company management is the adherence to ethical standards and the creation of a

working environment that promotes integrity, respect and fair conduct. A business policy that is strictly

business policy serves the long-term interests of the company.

These compliance guidelines have been adopted by the management of IPM Elektromatic GmbH

and approved by the shareholders' meeting.

Compliance with laws and other regulations at home and abroad

In all its business decisions and actions, IPM Elektromatic GmbH endeavors to comply with the

applicable laws and other relevant regulations at home and abroad.

Integrity and honesty promote fair competition, also in the relationship with our customers and

suppliers. Commitment of the company management

IPM Elektromatic GmbH considers it its duty to act economically, socially and environmentally conscious.

IPM Elektromatic GmbH therefore strives to conduct its business in a competent and ethical manner and to be a reliable partner in

to protect fair competition in all markets in which it is active by complying with applicable laws on

Anti-Trust, Competition and Restraints of Competition are complied with. Unfair advantages

to customers, suppliers or competitors shall be avoided.

Conflicts of interest

IPM Elektromatic GmbH expects its employees to be loyal to the company.

All employees must avoid situations in which their personal or financial interests conflict with those of IPM Elektromatic GmbH.

interests come into conflict with those of IPM Elektromatic GmbH. Therefore it is in particular

competitors, suppliers or customers or to enter into business relationships with them in a private capacity, insofar as

business relations with them in a private capacity, insofar as this may lead to a conflict of interest. Through

conflict situations, the interests of IPM Elektromatic GmbH must not be impaired.

Such conflicts of interest can arise in many situations: For example, no employee may accept advantages - in

in any form whatsoever - which, when viewed reasonably, can be assumed to be of a business

that they could influence business decisions or transactions of IPM Elektromatic GmbH.

could influence. Invitations must remain within the limits of customary hospitality.

hospitality. Due to their position in IPM Elektromatic GmbH, employees should not

personally gain advantages directly and/or indirectly through access to confidential information.

indirectly through access to confidential information. All employees have a duty to promote the legitimate interests of IPM Elektromatic GmbH as far

as possible. Any competitive situation with the company is to be avoided.

Any actual or potential conflict of interest must be reported and discussed with the relevant superiors.

discussed with the superiors concerned.Prohibition of Corruption

IPM Elektromatic GmbH is against corruption and bribery. Conduct in which

business is conducted by unfair means will not be tolerated. Employees of IPM Elektromatic GmbH

may not offer any benefits to business partners or receive or accept any such benefits from them that could

business partners which could lead to an impairment of an objective and fair business decision or even

even the appearance of such.

Fair working conditions

All employees of IPM Elektromatic GmbH must provide a safe and healthy working environment.

environment. Therefore, safety regulations and practices must be strictly adhered to.

As a socially responsible employer, IPM Elektromatic GmbH considers its employees to be of great

value. It demands great commitment from its employees and, in return, shares its

business success with them. The human resources policy of IPM Elektromatic GmbH contributes to giving every

employees the possibility of professional and personal development. Open

exchange of opinions, criticism and ideas is encouraged.

IPM Elektromatic GmbH condemns illegal discrimination or harassment of any kind.

kind.

Dealing with internal knowledge

All employees of IPM Elektromatic GmbH are obliged to ensure a fast and smooth exchange of information within the company.

exchange of information within the company. Information is to be passed on correctly and

and complete to the departments concerned, unless in exceptional cases, in particular due to secrecy obligations

due to confidentiality obligations, overriding interests exist. Relevant knowledge may not be

unlawfully withheld, distorted or selectively passed on.

Dishonest reporting within the company or to organizations or persons outside the company is strictly prohibited.

persons is strictly prohibited. All financial statements and annual reports, business papers and

IPM Elektromatic GmbH must accurately present business transactions and events and comply with legal

and comply with legal requirements, accounting principles and internal accounting procedures of IPM Elektromatic GmbH.

accounting procedures of IPM Elektromatic GmbH.

Handling of assets

All employees of IPM Elektromatic GmbH are responsible for the proper and careful handling of the company's

the property of the company. Each employee is obligated to protect the property of IPM

Elektromatic GmbH against loss, damage, misuse, theft, embezzlement or destruction.

destruction. Each employee has the duty to immediately inform his or her superior of any use of assets that is contrary to the

of any use of assets contrary to the foregoing.

Confidentiality and Data Protection

A large part of the business information of IPM Elektromatic GmbH is confidential or legally protected.

protected by law, so that there is an obligation to maintain secrecy. This does not apply if publication of the

information has been approved by IPM Elektromatic GmbH or is mandatory by law or regulation.

The obligation to maintain secrecy relates in particular to intellectual property. This includes

Trade secrets, patents, trademarks and copyrights, as well as business and marketing plans,

designs, business papers, salary data and all other unpublished financial data and

reports.

All personal information about employees, customers, business partners and suppliers as well as

third parties will be used carefully and treated confidentially within IPM Elektromatic GmbH, in full

full compliance with data protection laws. The protection of this information must be fulfilled with the greatest

care.

Implementation and monitoring

The rules contained in this Code of Conduct form a core component of the

corporate culture of IPM Elektromatic GmbH. The uniform observance of these principles is

indispensable. Every employee is responsible for this.

If an employee has concerns or complaints about the points listed in this Code of Conduct

this Code of Conduct or has knowledge of a possible breach of the behavioral guidelines contained herein, he or she should

immediately bring this to the attention of his or her supervisor for clarification. This may also be done anonymously or

confidential manner. IPM Elektromatic GmbH does not permit any reprisals based on

complaints made in good faith under this Code of Conduct.

Responsibility

All employees as well as the members of the management and the shareholders of the IPM Elektromatic

GmbH are bound by the rules of this Code of Conduct.