Code of conduct

The SHG Group is aware of its responsibility to people and the environment and takes this very seriously. We believe that economic success and the commitment to responsible action are inextricably linked. This commitment applies not only to our employees but also to society as a whole and the environment. The business success and reputation of the company are based on the principles of fair  interaction and ethically sound conduct of our employees. The SHG Group strives to conduct its business activities according to the highest ethical standards and expects all employees to handle ethical issues with sensitivity, considering the potential consequences of their actions for the company, its reputation, its business relationships, and its relations with the public. It is the responsibility of each individual employee to follow the guidelines set out in this document. Anyone who violates our business ethics must expect employment consequences up to and including termination. Primarily, it is up to each employee to judge for themselves, based on high ethical and moral principles, which behavior is considered acceptable. The following principles serve as guidance: 

• Conflicts of interest are to be avoided.
• Resources, assets or confidential information are not to be used for personal purposes.
• Anyone who suspects violations of ethical principles or legal regulations should report these to their direct supervisor or another manager within the company. Discuss situations which arise and seem difficult for you to take appropriate or suitable measure openly with your direct supervisor. We consider the cover-up and any failure to report such a situation as unacceptable behavior.
• All employees are required to cooperate when compliance with ethical principles and legal regulations is being reviewed
• Uncovered unethical business practices need to be corrected and reported to the company management. 

Our company places great importance on adhering to internationally recognized standards for labor and human rights, as outlined in the conventions of the International Labour Organization (ILO) and/or the UN Guiding Principles on Business and Human Rights. The following principles thus apply: 

• We are a company that promotes equal opportunity and equal treatment, and respects the dignity, diversity, and individual rights of its employees and third parties with whom we maintain business relationships. Our goal is to create a working environment that is free of discrimination, bullying, and harassment of any kind.
• We condemn forced labor, child labor, and any form of exploitation or discrimination, and strictly adhere to applicable laws.
• We do not tolerate the exploitation of children and labor forces. We expect our employees, consultants, contract partners, suppliers, and business partners with whom we maintain business relationships to also adhere to these standards. 

The SHG Group's commitment to respecting and protecting human rights specifically includes the rights of children. The SHG Group acknowledges that every child has the right to healthy and safe living conditions, education, play and recreation, an adequate standard of living, and protection from abuse and suffering. Although the risk of child labor occurring in our market segment, with our customers, and along our supply chains is generally considered to be low, we explicitly state that the SHG Group does not tolerate child labor. The following principles thus apply:

• Our employees in the relevant task areas are trained on the topic of youth labor protection law.
• Our HR department is instructed not to hire minors below the legal minimum age.
• Our suppliers and business partners must assure us that they are not involved in child labor. If we become aware of locations where children are employed, we terminate the relevant contract with immediate effect.

Climate protection is a high priority in the internal strategic goals of SHG Group's environmental management. Our goal is to reduce carbon emissions along the entire value chain and make our business activities even more climate-friendly. We are committed to the Paris Climate Agreement and the climate protection goals of the United Nations, thereby supporting the objectives of international climate policy. Specific measures include reducing electricity and heat demand, using renewable energy, saving fuel for company vehicles, promoting electric mobility, and avoiding business trips by using digital alternatives. We also actively strive to protect our environment. We also expect our employees to conduct themselves in an environmentally conscious and friendly manner, such as using water, heating energy, and electricity sparingly and ensuring proper disposal and separation of waste in our company.

The SHG Group promotes performance, teamwork, and business success through open communication. We encourage our employees to exchange ideas. The SHG Group advocates a “open door” leadership style, in which employees are encouraged to discuss work-related concerns with their supervisors or corporate management.

Ensuring fair working conditions, is an essential part of our corporate culture. The SHG Group is committed to equal opportunity, fair treatment, and diversity. It strives to protect the health and safety of its employees and to provide a work environment that is free from any form of discrimination, harassment, intimidation, or violence. The SHG Group promotes the diversity of its employees in terms of age, cultural background, disability, gender, level of education, nationality, ethnic origin, organizational level, and other characteristics that distinguish people as unique individuals. We make personnel decisions based on performance, meaning that when recruiting, hiring, training, development, and promoting employees in all areas of activity, we make decisions independently of ethnicity, skin color, religion, gender, nationality, age, disability, veteran status, sexual orientation, or any other characteristics protected by applicable anti-discrimination laws. We strive for a diverse working environment that is free from discrimination. 

The SHG Group is an employer that promotes equal opportunity and equality, and makes personnel decisions based solely on performance. We want to fill every position with the most suitable person. The SHG Group is committed to complying with all applicable standards, laws, and regulations that ensure equal opportunity in employment. This obligation applies to all employees of the company and states that employees of the company, whether superiors or subordinate staff, may not discriminate against others. 

The SHG Group makes reasonable efforts to enable the employment of a qualified person with physical or mental disabilities, unless it would cause undue hardship for the company. Applicants or employees, whose workplaces need to be adapted due to a disability, should contact the HR department to clarify the need. The company reviews and identifies any obstacles that stand in the way of 20 an applicant's or employee's equality and the performance of their duties. The company assesses which adjustments are possible to compensate for the limitations. If the adjustment measures are appropriate and do not represent an unreasonable hardship, the company will take the measures. 

"If you believe you have been discriminated against in any way, or if you know a colleague who has been discriminated against, please contact the HR department immediately. Our company will promptly and carefully investigate the matter and take the necessary measures. If we determine that discrimination has occurred, we will initiate effective remedial measures, up to and including termination. In addition, we will take appropriate measures to prevent similar cases from recurring in the future. Employees who file a complaint should not fear any disadvantages as a result.

The working conditions, remuneration, and other benefits at the SHG Group comply with current legal regulations. The SHG Group is committed to providing fair and competitive working conditions in terms of remuneration, working hours, weekly rest periods, vacation, health protection, occupational safety, and maternity protection.

All employees have the right to be treated with respect. It is the stated goal of the SHG Group to provide all employees with a working environment that is free from sexual or other harassment, discrimination, and reprisals. For this reason, our company does not tolerate any form of harassment or discriminatory behavior towards employees and job applicants based on their skin color, gender or gender identity, ethnicity, religion, sexual orientation, nationality, descent, marital status, pregnancy, age, health status, disability, or any other characteristic protected by applicable anti-discrimination laws. Employees who harass others in any form must expect disciplinary measures up to and including extraordinary termination. Our customers, suppliers, and other business partners are of course also prohibited from harassing our employees. The following behaviors are considered to be reprehensible harassment:

use of racist slurs, ethnic insults, jokes or gestures, or other expressions that negatively describe, refer to, or insult an individual or group; expressions of hostility towards an individual or group; behaviors that threaten or intimidate others; the publication or distribution of written or graphic materials, audio, or video recordings, or other materials in the workplace that attack, slander, demean, disparage, or express animosity towards an individual or group of employees.

The prohibition of harassment in the manner described above, of course, also applies to superiors towards their employees, employees towards their colleagues, external individuals towards employees, and employees towards applicants.

The SHG Group also strictly prohibits sexual harassment in the workplace, regardless of whether it originates from men or women, 26 from supervisors or from subordinate employees. The following behaviors are considered to be sexual harassment:

unwanted sexual advances, requests for sexual favors or other verbal or physical behavior of a sexual nature, sexually suggestive looks or gestures; lewd or obscene gestures; sexually offensive jokes, innuendos or obscene comments of a sexual nature; deliberate touching of another person; physical harassment; sexually offensive or unwanted flirting, verbal sexual insults; display of sexually explicit images, greeting cards, articles, books, magazines, videos, pictures, or cartoons.

If you feel that you have been or are being harassed, discriminated against, or bullied in violation of this policy set by us, by another employee, a supervisor, a guest, an external contractor, or any other business partner, we expect you to report this immediately to your supervisor or the HR department. The same applies if you observe another person being harassed by an employee, a supervisor, or an external person. You must also report this immediately to your supervisor or the HR department.

The company takes all complaints regarding harassment very seriously. Employees who report an incident in good faith shall not face any disadvantages as a result. In confirmed cases of harassment or other violations of this policy, remedial actions will be initiated, including appropriate disciplinary actions up to termination.

The SHG Group is committed to preventing violence in the workplace and providing a safe working environment for all employees. For this reason, the company has established the following guidelines for dealing with any form of intimidation or threats of violence of that can occur during working hours. It is essential for us that all employees are treated with courtesy and respect at all times. All employees are encouraged to inform their superiors or the HR department about disputes or differences with other employees before the situation threatens to escalate. The SHG Group does not tolerate physical confrontations or other behaviors that endanger others. Carrying weapons including knives, dangerous objects or dangerous substances on the premises of the SHG Group is strictly prohibited. Threats of violence, aggressive behavior, or coercion against another employee, a customer, or any other person, will not be tolerated either during or outside of working hours. 

In line with this policy and the consistent implementation of the objectives outlined above, the following principles apply

• The SHG Group commits to ensuring a safe and healthy work environment.
• The SHG group will promptly initiate remedial actions, up to and including immediate termination, if employees threaten, intimidate, physically harm, or insult others through gestures or language.
• The SHG Group will promptly take immediate actions when customers, former employees, or visitors of the company behave as described above. Depending on the situation and/or legal situation, suitable actions are considered to be notifying the police or other authorities and pursuing criminal prosecution of the acts described in this policy to the fullest extent of the law. SHG Group Employee Handbook 29
• The consumption of alcohol or drugs by employees, customers, and visitors is strictly forbidden on the entire company premises during working hours. Employees are also strictly prohibited from performing their work under the influence of alcohol and/or drugs. A violation of these prohibitions can lead to extraordinary termination.
• Employees, former employees, customers, and visitors are prohibited from carrying any type of weapons on the premises of the SHG Group.
• The company takes effective security measures to protect its facilities as much as possible and to prevent unauthorized access by individuals not associated with the operation, employees outside of their working hours, and former employees.

All direct or indirect threats of violence and acts of violence should be reported to the direct supervisor or the HR department as soon as possible. This also applies to threats from employees, customers, sellers, advertisers, or any other external individuals. If you report a threat of violence, you should describe it as specifically and as detailed as possible. Report all suspicious persons or activities to your supervisor as soon as possible. All reported threats of violence, violent acts, as well as suspicious persons and activities, are promptly and carefully investigated by the company. The identity of the person reporting an incident is protected as much as possible. In order to maintain safety at the workplace and to prevent disruption of the investigation, the concerned employees can be given leave with or without pay until the completion of the investigation.

The safety and health of employees, customers, and visitors is of the highest priority for the SHG Group. We strive to continuously improve the protection of health and occupational safety of our employees by adhering to all applicable health and safety regulations and standards, and by taking all necessary precautions in a continuous and planned manner to protect the physical and mental health of our employees. In particular, our managers have the task of ensuring that appropriate safety precautions are taken in accordance with current legal regulations. 

All employees receive occupational medical care appropriate to their activities. For this, there is a contractual arrangement with the Private Institut für Arbeitsmedizin (Private Institute for Occupational Medicine), owner Dr. med. Sigrud Scholl, Wilhelmstr. 55-63, 53721 Siegburg, Germany. This institute performs the duties of a company doctor in accordance with the Occupational Safety Act and DGUV Regulation 2. In addition to the mandatory examinations, we also offer our employees the opportunity for voluntary examinations in accordance with the Occupational Health Care Regulation (Arb- MedVV). 

The SHG Group expects its employees to comply with all safety regulations and to exercise caution in their activities to avoid dangerous situations. 

Imminent danger situations, near accidents, and unsafe working conditions must be reported immediately to the supervisor. Employees who violate the safety regulations of the SHG Group, cause a dangerous situation, or fail to report a security-relevant incident, must expect disciplinary measures up to and including termination. In the event of an accident involving personal injury, irrespective of how minor the injury may seem, you must immediately inform your supervisor. Prompt reporting of accidents is also essential to ensure 32 compliance with all legal regulations and to quickly notify the workers' compensation board and other insurance providers of the incident. 

Expert advice on occupational safety and the duties of the occupational safety specialist are provided externally under a contractual agreement by Büro für Arbeitssicherheit D. Stracke & T. Stracke GbR, Strunder Feld 26, 51069 Cologne, Germany. When evaluating accidents involving personal injuries, the safety specialist must be consulted. 

Employees often have good ideas when it comes to improving safety in the workplace. 

If you have an idea, a suggestion for improvement or any general security concerns, please contact your superior. In order to protect your colleagues from infections, it is important to us that you do not come to work with contagious infectious diseases. If you are experiencing flu-like symptoms, such as high fever combined with dry cough, muscle, limb, and headaches, you should immediately see a doctor to rule out the presence of a contagious infectious disease. It is your responsibility to protect your colleagues from avoidable infections.

Our employees are required to comply with applicable guidelines in performing their duties and to disclose any potential or actual conflicts of interest. A potential or actual conflict of interest arises when an employee is in a position within the SHG Group's business activities where they can influence a decision in their favor or in favor of a family member. Employees who have influence over transactions related to procurement or contracts must immediately inform the management of the SHG Group about the existence of a possible or actual conflict of interest, so that appropriate precautions can be taken to protect the parties involved. As an employee, do not refer business to a business operation or company in which you, close friends, or family members are involved, and do not provide them with more favorable business conditions. Do not give close friends and family members jobs, unless they are each the most suitable person for this position, and you have previously disclosed your personal relationship. Employees who are at risk of a potential or actual conflict of interest are obligated to promptly inform their superiors or the management in order to expedite resolution.

The SHG Group never participates in any form of corruption. Corruption is the direct or indirect granting, demanding, suggesting, accepting, and promising of benefits to employees or agents of current or prospective business partners, office holders or persons equivalent to them, to obtain unjustified business advantages or to induce a decision-maker at the customer to breach his professional duties. Examples of unjustified advantages are:

• Order placement despite higher price or poorer quality.
• Preference despite the same conditions as competitors.
• Preference in delivery (conditions, dates, quantities).
• Conditional advantages such as discounts/rebates that are officially agreed and documented with a contractual partner are not illicit benefits.

Gifts, whether given to or by an employee of the SHG Group, are only permissible if they are appropriate, non-cash, provided in a transparent manner, and not actively solicited. Gifts related to a business decision are always inadmissible.

Handling Gifts 

The acceptance or granting of low-value gifts (value up to EUR 50.00 gross) does not require the approval of the management, provided they are non-cash and are provided in a transparent manner and are not actively solicited. In the event of a repeat occurrence, the total value between the giver and the recipient must not exceed EUR 110.00 gross in the calendar year. The acceptance or granting of high-priced gifts requires the approval of the management.

Handling Invitations

Invitations, for example, to business meals may be accepted without the approval of the management, provided there is a direct business connection, and the nature and extent of the hospitality corresponds to usual business practices. The acceptance of invitations from business partners to events where the business character is not clearly in the foreground (e.g. sponsoring, marketing, or sales events) or to events with no business nature, requires the approval of the management.

Punctuality

The SHG Group expects its employees to arrive on time at their workplaces. In case of delay, the supervisor must be informed immediately. Repeated delays can lead to termination.

Punctuality 

The SHG Group expects its employees to arrive on time at their workplaces. In case of delay, the supervisor must be informed immediately. Repeated delays can lead to termination.

Vacation 

Vacation requests must be submitted in writing by the employees in a timely manner. The SHG Group strives to accommodate the vacation requests of its employees, however, this cannot be guaranteed if urgent operational concerns or staff shortages oppose the vacation request. 

Illness 

If employees should become unable to work due to illness, they must report this to the HR department or their direct superior by phone or e-mail before the start of their work shift. All employees who fall ill and are unable to work must immediately visit a doctor on the first day of illness and obtain a doctor’s note for work. 

Doctor's Visits 

The physical and mental health of our employees is of utmost priority for the SHG Group. Nevertheless, our employees should consider that doctor's appointments are essentially private matters and should generally be taken outside of working hours. Of course, something different applies when acute symptoms occur or for examinations that must take place at a certain time of day (e.g. a  42 blood draw in the morning). Pregnant women, nursing mothers, and teenagers are of course also exempt from work for doctor’s appointments, with continued payment of their wages, in cases specified by law. 

Smoking 

Smoking is strictly prohibited inside our company buildings.

Employees who believe they have identified a violation of any of the guidelines and specifications of this employee handbook should contact the HR department. We will then discreetly carry out a review or investigation and provide feedback to the person reporting the violation. Please note that the company may not be able to fully investigate vague or general complaints, as applicable. Employees who express concerns or complaints in good faith in connection with this policy, report incidents or ask questions, or who participate in an examination or investigation, have nothing to fear as a result. 

As an additional communication tool for certain types of situations, the SHG Group has established an anonymous whistleblower system, through which employees can confidentially and anonymously report perceived violations of the policies in this employee handbook or against legal/regulatory regulations. This whistleblowing system is not a substitute for communication within our organization between employees and their supervisors. Therefore, regular business matters that do not require anonymity should be discussed with the supervisor or management and not submitted via this system. This whistleblower system is intended as an additional communication tool for special situations. The SHG Group provides it because we believe it is in accordance with the principles of good corporate governance. Even for complaints submitted through the whistleblower system, a personal meeting can be arranged upon request. The anonymous whistleblowing system is externally set up at the office of Mr. Werner Nehnes, a lawyer, Bornheimer Str. 26 a, 53111 Bonn, Germany. Anonymous tips can be submitted by mail or by e-mail to the following e-mail address. All indications will be treated with strict confidentiality:

meldung.shg@rechtsanwalt-nehnes.de