Code of Conduct

Preamble

Respectful and cooperative collaboration, together with a conscious commitment to social responsibility, forms the basis for long-term business success.

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

In its Code of Conduct, Winweb sets out the key principles and fundamental rules governing its own actions and its conduct toward employees, business partners, customers, suppliers, and the public.

1.0 General principles

1.1 Compliance with laws

Winweb is committed to complying with national and international laws and other relevant regulations of the countries in which it operates in all business activities and decisions. Winweb complies with the applicable legal prohibitions and obligations at all times, 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, and in particular the data of employees, partners, customers and suppliers, is of great importance to Winweb. As a matter of principle, Winweb collects and processes personal data only when this is strictly necessary to perform the respective task or is required by law, and even then, Winweb ensures data security, transparency and data minimisation. 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 corporate and social responsibility

2.1 Human rights

Winweb respects internationally recognized human rights in accordance with the UN Charter of Human Rights, as well as human dignity and personal rights, and supports compliance with them.

2.2 Equal treatment and prohibition of discrimination

At Winweb, we foster a corporate culture of mutual trust and respect. We promote equal opportunities, tolerance, and respectful and honest interactions, and prevent all forms of discrimination, especially when hiring employees, making promotions, or providing education and training opportunities. We treat all employees equally, regardless of gender, age, skin color, culture, ethnic origin, sexual identity, disability, religion, or belief.

2.3 Employee rights and working conditions

Winweb strictly rejects all forms of forced labor and child labor.

Winweb is committed to fair working conditions in accordance with applicable laws and regulations, including with regard to remuneration, the regulation of working hours, and the protection of privacy. Winweb provides a healthy and safe working environment for its employees and protects them from physical, sexual, psychological, and verbal harassment. Employees' privacy is respected.

2.4 Environmental protection

Sustainable environmental and climate protection are among Winweb's most important goals. Laws and regulations to protect the environment are complied with.

3.0 Principles of Fair Competition

3.1 Prohibition of corruption

Winweb stands for expertise, innovation, customer focus, and motivated employees who act responsibly. Winweb rejects corruption and bribery in any form. Applicable anti-corruption laws are strictly observed, and personal benefits in return for unfair preferential treatment in business dealings may neither be granted nor accepted. Exceptions are gifts and invitations that fall within the bounds of customary business hospitality and courtesy.

3.2 Conduct toward competitors

Winweb is committed to 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 appropriately protect confidential information and business records against access or inspection by employees who are not directly involved in the specific business transaction and by other third parties. Employees who possess information that is not generally known or readily accessible may not disclose this information or otherwise make it public.

4.0 Principles of responsibility for every employee in the company

4.1 Conduct 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 may be associated with the company’s activities. For this reason, every Winweb employee takes care to uphold Winweb’s public image and reputation when appearing in public, particularly when dealing with the media.

Every employee ensures that their internal and external reports, information and communications are complete and accurate and comply with applicable law and internal guidelines.

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

4.2 Protection of company property

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

Tangible and intangible property is generally used for business purposes unless private use has been authorized. For business trips and other company-related expenses, every employee is also required to observe the principle of cost-effectiveness and thus ensure that costs are reasonable in relation to the nature and scope of the event.