Code of Conduct

Preamble

Respectful and cooperative collaboration as well as the conscious perception of social responsibility form the basis for long-term business success.

Winweb Informationstechnologie GmbH (hereinafter referred to as “Winweb”) is committed, within the scope of its business activities, to its social responsibility, its responsibility towards its own company and its own employees, towards customers and suppliers, as well as towards the environment.

Winweb defines in the Code of Conduct the essential principles and basic rules for its own actions as well as for conduct towards employees, business partners, customers, suppliers and the public.

1.0 General principles

1.1 Compliance with laws

Winweb is committed to observing national and international laws as well as other relevant regulations of the countries in which it operates in all business actions and decisions. Winweb always observes the applicable legal prohibitions and obligations, even if this entails short-term economic disadvantages or difficulties for the company or individual persons.

1.2 Data protection and information security

The protection of personal data in general, but especially of the data of employees, partners, customers and suppliers, is of very high value for Winweb. In principle, Winweb collects and processes personal data only when this is absolutely necessary to fulfill the respective task or has been required by law, and even then Winweb pays attention to data security, transparency and data minimization. Otherwise, Winweb processes personal data only after obtaining the consent of the data subject, which always complies with the provisions and principles set out in the European General Data Protection Regulation.

2.0 Principles of social and societal responsibility

2.1 Human rights

Winweb respects the internationally recognized human rights in accordance with the UN Charter of Human Rights, dignity and personal rights and supports their observance.

2.2 Equal treatment and prohibition of discrimination

At Winweb, a culture of mutual trust and mutual respect is practiced throughout the company. We promote equal opportunities, tolerance and respectful and honest interaction with one another and prevent any discrimination, especially in the hiring of employees as well as in promotion or the granting of education and further training measures. We treat all employees equally, regardless of gender, age, skin color, culture, ethnic origin, sexual identity, a disability, religious affiliation or worldview.

2.3 Employee rights and working conditions

Winweb strictly rejects any form of forced and child labor.

Winweb is committed to fair working conditions in accordance with the applicable laws and regulations, including with regard to remuneration, the regulation of working hours and the protection of privacy. Winweb ensures a healthy and hazard-free working environment for its employees and protects its employees from physical, sexual, psychological and verbal harassment. The privacy of employees is respected.

2.4 Environmental protection

Sustainable environmental and climate protection are among the most important goals of Winweb. Laws and regulations for the protection of the environment are complied with.

3.0 Principles of fair competition

3.1 Prohibition of corruption

Winweb stands for expertise, innovative strength, customer orientation and motivated employees who act responsibly. Winweb rejects corruption and bribery in any form. The applicable anti-corruption criminal law is strictly complied with, personal advantages as consideration for unfair preferential treatment in business transactions may neither be granted nor accepted. Exceptions are gifts and invitations that are within the scope of customary business hospitality and courtesy.

3.2 Conduct towards competitors

Winweb respects fair competition. The applicable laws governing competition are complied with. This prohibits any unfair agreements between competitors or between customers and suppliers.

3.3 Trade secrets

Winweb takes the necessary steps to protect confidential information and business records in an appropriate manner from access and inspection by employees not directly involved in the specific business transaction and by other third parties. Employees who possess information that is not generally known or not readily accessible may not disclose this information or otherwise make it public.

4.0 Principles of responsibility of every employee in the company

4.1 Appearance and communication in public and within the company

Winweb respects the right to freedom of expression as well as the protection of personal rights and privacy. At the same time, every employee is aware that even private statements can be associated with the company's activities. For this reason, every Winweb employee pays attention to the image and reputation of Winweb when appearing in public, especially towards the media.

Every employee ensures that both their internal and external reports, information and communications are complete and correct and comply with applicable law and internal requirements.

Respect, tolerance, honesty and integrity among employees are the cornerstones of cooperation at Winweb.

4.2 Protection of company property

Every employee undertakes to use Winweb's property and resources properly and carefully and to protect them against loss, theft and misuse. Winweb's intellectual property constitutes a competitive advantage and therefore a valuable asset worthy of protection, which must be defended against any unauthorized access by third parties.

The tangible and intangible property is generally used for business purposes unless private use has been permitted. Also in the case of business trips and other company-related expenses every employee is committed to the principle of cost-effectiveness and thus to an appropriate relationship of the costs to the type and scope of the event.