The fol­lo­wing Code of Con­duct regu­la­tes the beha­viour of the employees of Noven­tiz GmbH, Noven­tiz Dual GmbH, Noven­tiz Digi­tal GmbH and Noven­tiz GEE GmbH, her­ein­af­ter coll­ec­tively refer­red to as Noven­tiz, towards each other, all busi­ness part­ners and the public.

All actions are based on the Basic Law, as well as the laws and regu­la­ti­ons of the Fede­ral Repu­blic of Ger­ma­ny, EU direc­ti­ves that are direct­ly appli­ca­ble, inter­na­tio­nal regu­la­ti­ons such as sanc­tions that the Fede­ral Repu­blic of Ger­ma­ny has under­ta­ken to imple­ment, and any agree­ments that Noven­tiz has con­cluded with its con­trac­tu­al part­ners. This appli­es to all employees and bodies of Noven­tiz.

The basic ethi­cal prin­ci­ples of Noven­tiz include inte­gri­ty, cre­di­bi­li­ty, trans­pa­ren­cy and the pur­su­it of excel­lence in all are­as.

Noven­tiz pro­vi­des ser­vices only and is the­r­e­fo­re not affec­ted by the Ger­man Sup­p­ly Chain Act. Howe­ver, Noven­tiz expects its busi­ness part­ners to be com­mit­ted to the same or simi­lar prin­ci­ples and to pro­mo­te their imple­men­ta­ti­on through their dai­ly actions, as Noven­tiz does.

Noven­tiz respects the rules of fair com­pe­ti­ti­on and does not enter into any unlawful agree­ments. The same appli­es to par­ti­ci­pa­ti­on in public and pri­va­te ten­ders.

Noven­tiz takes a firm stance against giving bri­bes and avo­ids any impres­si­on that its busi­ness decis­i­ons could be influen­ced by cor­rup­ti­on. Employees are not per­mit­ted to take advan­ta­ge of their employer’s busi­ness rela­ti­onships for their own bene­fit or for the bene­fit of their fami­ly or fri­ends.

If an employee beco­mes awa­re of a mat­ter that rai­ses a sus­pi­ci­on of cor­rup­ti­on or eco­no­mic crime, he or she must seek advice or assis­tance in asses­sing the situa­ti­on. The first point of cont­act is the line mana­ger or, alter­na­tively, the com­pli­ance offi­cer. Employees can also make anony­mous reports if they wish to remain anony­mous.

Invi­ta­ti­ons to busi­ness meals or events that are con­sis­tent with nor­mal busi­ness prac­ti­ces as estab­lished by case law may be accept­ed as long as they do not con­sti­tu­te impro­per pre­fe­ren­ti­al tre­at­ment – the same appli­es to gifts.

It is pro­hi­bi­ted to pay any kind of bri­be, even indi­rect­ly, to public offi­ci­als or repre­sen­ta­ti­ves of govern­ment insti­tu­ti­ons, regard­less of the amount. It is not per­mit­ted to use con­sul­tants, agents or other inter­me­dia­ries to cir­cum­vent this pro­hi­bi­ti­on.

Con­tri­bu­ti­ons to poli­ti­cal orga­ni­sa­ti­ons, repre­sen­ta­ti­ves or can­di­da­tes may only be made in con­sul­ta­ti­on with the manage­ment and in accordance with the appli­ca­ble laws.

Dona­ti­ons must be trans­pa­rent, vol­un­t­a­ry, and must not be tied to the expec­ta­ti­on of a quid pro quo.

In case of doubt, employees must first seek the advice of the manage­ment.

Noven­tiz does not tole­ra­te any money laun­de­ring and ins­tructs employees to com­ply ful­ly with anti-money laun­de­ring laws. They are requi­red to report sus­pi­cious pay­ment methods and other tran­sac­tions to the manage­ment or the com­pli­ance offi­cer.

Honest, accu­ra­te and clear report­ing and com­mu­ni­ca­ti­on within Noven­tiz and to the public is of key importance. Noven­tiz docu­ments its busi­ness acti­vi­ties and reports them to the com­pe­tent aut­ho­ri­ties as requi­red by law. All tax and cus­toms decla­ra­ti­ons are made truthful­ly. Taxes and other fis­cal char­ges are pro­per­ly declared and paid. The legal requi­re­ments for export con­trols, as far as they app­ly to Noven­tiz, are com­pli­ed with. Noven­tiz expects its busi­ness part­ners to sup­port the achie­ve­ment of the­se objec­ti­ves through appro­pria­te con­duct.

In order to avo­id con­flicts of loyal­ty, all employees are requi­red to report to their super­vi­sor in case of any con­flicts of per­so­nal or finan­cial inte­rest with Noven­tiz or its busi­ness part­ners. Employees may not mana­ge, work for or have signi­fi­cant influence over a com­pa­ny that is a direct com­pe­ti­tor of the Noven­tiz Group.

Buy­ing, sel­ling or recom­men­ding the buy­ing or sel­ling of assets on the basis of insi­de infor­ma­ti­on is pro­hi­bi­ted. Noven­tiz tre­ats insi­de infor­ma­ti­on as strict­ly con­fi­den­ti­al and does not pass it on to third par­ties. Insi­de infor­ma­ti­on may only be dis­c­lo­sed to employees or con­sul­tants on a need-to-know basis, and is always sub­ject to strict con­fi­den­tia­li­ty. This obli­ga­ti­on con­ti­nues for three years after ter­mi­na­ti­on of employ­ment.

In addi­ti­on, data pro­tec­tion regu­la­ti­ons, in par­ti­cu­lar data con­fi­den­tia­li­ty and the GDPR must be com­pli­ed with. Hand­ling per­so­nal data, inclu­ding – but not limi­t­ed to – pro­ces­sing, sto­rage, dis­clo­sure or publi­ca­ti­on, is pro­hi­bi­ted unless it rela­tes to a spe­ci­fic busi­ness task. This obli­ga­ti­on shall sur­vi­ve the ter­mi­na­ti­on of employ­ment with Noven­tiz.

  1. Prin­ci­ples of respon­si­bi­li­ty

Noven­tiz is awa­re of its social and eco­lo­gi­cal respon­si­bi­li­ties. Noven­tiz respects human rights, oppo­ses any form of forced or child labour, does not tole­ra­te any dis­cri­mi­na­ti­on and pro­mo­tes equal oppor­tu­ni­ties for all employees. Workers’ rights are respec­ted, as are occu­pa­tio­nal health and safe­ty.

Trea­ting the envi­ron­ment and resour­ces respon­si­bly is a key aspect of Noventiz’s cor­po­ra­te iden­ti­ty. All employees and the manage­ment should base their actions on this pre­mi­se. The manage­ment lives by the­se values and sets an exam­p­le for all employees.

Noven­tiz intro­du­ces this Code to its employees and makes it available to its busi­ness part­ners. Noven­tiz will take all neces­sa­ry mea­su­res to imple­ment the prin­ci­ples defi­ned in this Code of Con­duct. Noven­tiz under­ta­kes to regu­lar­ly review the effec­ti­ve­ness of this Code of Con­duct and to make chan­ges if neces­sa­ry.

Employees who belie­ve that chan­ges to the Code are con­du­ci­ve to impro­ving coope­ra­ti­on within Noven­tiz and bet­ween Noven­tiz and its busi­ness part­ners are encou­ra­ged to make sug­ges­ti­ons – anony­mously if desi­red – in accordance with the pro­cess descri­bed in Sec­tion II abo­ve.

If employees beco­me awa­re of a vio­la­ti­on of this Code of Con­duct, they should report their obser­va­tions to a com­pli­ance offi­cer or to the manage­ment. Such a report may be made anony­mously, if pre­fer­red. Reports will be trea­ted con­fi­den­ti­al­ly, and, if the obser­va­tions are based on mis­in­ter­pre­ta­ti­ons, will not have a nega­ti­ve impact on the report­ing employee – unless it is a fal­se accu­sa­ti­on based on intent or gross negli­gence.

Vio­la­ti­ons of this Code of Con­duct and, in par­ti­cu­lar, of the legal prin­ci­ples con­tai­ned the­r­ein, may result in sanc­tions under labour, lia­bi­li­ty or even cri­mi­nal law.

The con­tent of the Code will be review­ed regu­lar­ly to ensu­re that it always remains up to date.

Colo­gne, 16 June 2023