Code of Conduct

1. General Principles

1.1 Basic Understanding

Fingerhuth recognizes its social and societal responsibility and is committed to meeting this responsibility in all its business activities.

1.2 Compliance with Laws

Fingerhuth commits to adhering to all applicable laws and relevant regulations in the countries where it operates in all business actions and decisions. Business partners are treated fairly. Contracts are honored, taking into account any changes in conditions.

1.3 Adherence to Generally Accepted Values and Principles

Fingerhuth bases its actions on generally accepted ethical values and principles, particularly integrity, honesty, respect for human dignity, and non-discrimination.

2. Principles of Social and Societal Responsibility

2.1 Human Rights

Fingerhuth respects and supports the observance of internationally recognized human rights. In particular, it adheres to the human rights as stated in the UN Universal Declaration of Human Rights (General Assembly Resolution 217 A (III) of December 10, 1948).

2.2 Prohibition of Discrimination

Within the framework of applicable laws and regulations, Fingerhuth rejects any form of discrimination. This particularly refers to disadvantages based on race, ethnic origin, gender, religion or belief, disability, age, or sexual identity.

2.3 Occupational Safety and Health Protection

Fingerhuth ensures occupational safety and health protection at the workplace in accordance with national regulations. Fingerhuth supports continuous development to improve the working environment.

2.4 Working Conditions, Prohibition of Forced and Child Labor

Fingerhuth respects the right to coalition and freedom of assembly of its employees within the framework of applicable laws and regulations. Fingerhuth complies with labor standards regarding maximum permissible working hours and remuneration, particularly with respect to wage levels in accordance with applicable laws and regulations. Employees are protected from physical punishment and from physical, sexual, psychological, and verbal harassment. The privacy of employees is respected. The prohibition of forced labor of any kind is observed. In particular, the Convention on Forced or Compulsory Labor of 1930 (ILO Convention 29) and the Abolition of Forced Labor Convention of 1957 (ILO Convention 105) are adhered to. Fingerhuth complies with regulations prohibiting child labor, particularly the Convention on Minimum Age for Admission to Employment of 1973 (ILO Convention 138) and the Convention on the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor of 1999 (ILO Convention 182). If national regulations regarding child labor set stricter standards, these are given priority.

2.5 Environmental Protection

Fingerhuth is sustainably committed to the goal of protecting the natural foundations of life for present and future generations. Laws and regulations enacted to protect the environment are adhered to.

2.6 Communication

Fingerhuth communicates openly and in a dialogue-oriented manner about the requirements of this Code of Conduct and its implementation with employees, customers, suppliers, and other stakeholders and interest groups.

3. Principles of Fair Competition

3.1 Prohibition of Corruption

Fingerhuth rejects corruption and bribery. In dealings with business partners and public institutions, the interests of Fingerhuth and the private interests of employees are strictly separated on both sides. Decisions are made free of irrelevant considerations and personal interests. The applicable anti-corruption criminal law is observed. Offering personal benefits by Fingerhuth and its employees to domestic or foreign officials (such as civil servants or public sector employees) with the aim of obtaining advantages for Fingerhuth or for oneself or third parties is not allowed. Personal financial advantages as compensation for unfair preferential treatment in business transactions between companies may not be offered, promised, granted, or approved. Similarly, personal benefits of value for unfair preferential treatment in business dealings may neither be demanded nor accepted from business partners. Fingerhuth management and employees may not offer, promise, demand, grant, or accept gifts, payments, invitations, or services in business dealings that are intended to improperly influence a business relationship or where there is a risk of compromising the professional independence of the business partner. This is generally not the case with gifts and invitations that fall within the scope of customary hospitality, manners, and courtesy in business.

3.2 Conduct towards Competitors

Fingerhuth respects fair competition. Therefore, it complies with applicable laws that protect and promote competition, particularly the applicable antitrust laws and other laws regulating competition. In dealings with competitors, these regulations specifically prohibit agreements and other activities that unfairly influence prices or conditions, unlawfully allocate sales territories or customers, or otherwise hinder free and open competition. These regulations also prohibit unfair agreements between customers and suppliers intended to restrict customers' freedom to autonomously determine their resale prices and other conditions (price and condition setting).

3.3 Trade Secrets

Fingerhuth respects and protects the trade and business secrets of others. Confidential information and documents may not be unlawfully disclosed to third parties or otherwise made accessible unless authorization has been granted, the information is publicly available, or a binding decision by an authority or court compels it.

4. Scope, Implementation, Suppliers

4.1 Scope

This Code of Conduct applies to all branches and business units of Fingerhuth.

4.2 Implementation and Compliance

Fingerhuth informs its employees about the contents of this Code of Conduct and the obligations arising from it. It takes appropriate measures to ensure that this Code of Conduct is followed.

4.3 Suppliers

Fingerhuth will communicate the principles of this Code of Conduct to its immediate suppliers, promote compliance with its contents by their suppliers to the best of its ability, and encourage them to also adhere to the principles set forth in this Code of Conduct. Furthermore, Fingerhuth will recommend that its immediate suppliers encourage their suppliers to follow this Code of Conduct as well.