Code of Conduct of the TIMETOACT GROUP

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The companies of the TIMETOACT GROUP claim to be modern and sustainable companies that provide excellent services and are committed to the basic values of society. The TIMETOACT GROUP is responsible for creating and maintaining a corporate culture in which the relevant legal provisions and regulations as well as ethical principles are observed to the best of its ability.

Due to the multitude of laws and regulatory requirements, it is hardly possible to offer a ready-made solution for every conceivable situation. However, in order to ensure as far as possible that actions are carried out in accordance with laws and ethical values, the companies of the TIMETOACT GROUP have formulated this Code of Conduct. It defines the general standards for behavior in business, legal and ethical respects and is authoritative for dealing with colleagues, customers and business partners.

The Code of Conduct is addressed to all employees of the companies of the TIMETOACT GROUP, including the management. Consistent compliance with this Code of Conduct is expected from each individual.

This Code of Conduct must be complied with even if the applicable laws or regulations are less far-reaching. At the same time, it cannot be ruled out that stricter laws and regulations may apply than those set out in this Code of Conduct. In this case, these stricter laws and regulations take precedence.

The companies of the TIMETOACT GROUP already thank their employees for their cooperation in complying with this Code of Conduct. Only in this way can we meet our own high standards in our dealings with each other and with customers and business partners. In this way, each individual employee contributes to ensuring the basis for a successful future for the Group companies.

1. Human Rights

TIMETOACT GROUP is committed to the principles of the United Nations Universal Declaration of Human Rights and expects that suppliers and business partners also share these values and commit to their observance.

The rights to freedom of association and collective bargaining in accordance with applicable rights and regulations are granted without exceptions. Inhumane practices such as forced labor, child labor, all forms of modern slavery and human trafficking as well as any form of exploitation are prohibited at TIMETOACT GROUP and strict compliance with corresponding laws is ensured.

2. Subject-specific Regulations

2.1 Fair Competition
2.2 Insider Trading
2.3 Data Protection
2.4 Protection of intellectual property (e.g. copyright, trademark, design, patent rights)
2.5 Compliance with anti-money laundering laws
2.6 Accounting and documentation
2.7 Dealing with the media

3. Conduct in the workplace and in the business environment

3.1 Drugs and Alcohol
3.2 Discrimination and Harassment-Free Workplace
3.3 Dealing with property and rights of the company
3.4 IT-Security
3.5 Utilization of operating resources
3.6 Retention of documents and records
3.7 Confidential information
3.8 Gifts and gratuities
3.9 Dealing and cooperation with public authorities Public clients

4. Conflict of Interest

Conflicts of interest may cast doubt on the quality of business decisions made and on the integrity of the persons making such decisions. Conflicts of interest, or even the appearance of them, must be avoided at all times. If such conflict avoidance is not possible, it must be dealt with actively, openly and honestly. In the event of potential conflicts, employees are encouraged to actively approach their supervisor and agree on how to proceed. In particular, the following conflicts of interest must be avoided:

4.1 Secondary Employment
4.2 Political Activities

5. Implementation of the Code of Conduct

5.1 Questions and Comments
5.2 Reporting violations ("whistleblowing")
5.3 Part of the employment relationship