Code of Conduct

1. Observance of the applicable law

Compliance with all applicable laws and regulations is an indispensable basis for all actions of the PONGS Group. This Codex sets forth some of the key principles for the conduct of the PONGS Group, including its employees and officers. However, it can not handle all of the legal regulations that must be observed by the corporate bodies, executives and employees of the PONGS Group worldwide. All employees and corporate bodies of the PONGS Group are required to obtain information about the legal provisions applicable to their area of ​​responsibility within the company and, in case of doubt, to seek legal advice from the competent authorities in the PONGS Group.

2. Fair competition

It is in line with the business policy of the PONGS Group to promote fair competition. The PONGS Group complies with all applicable domestic and foreign antitrust laws and the law against unfair competition. Price or condition agreements with competitors are therefore just as inadmissible as agreements with competitors for the purpose of market distribution. Unlawful agreements may not be replaced by concerted practices with competitors or by coordination within associations. Unfair competition practices are rejected by the PONGS Group. If PONGS Group companies hold a dominant position, they must not be misused in relation to customers and competitors. It must be clear to every employee and all bodies that violations of competition law regulations are under no circumstances in the interest of the PONGS Group and must therefore be avoided without exception.

3. Corruption

All employees undertake to do everything in their power to prevent corruption. Corruption is the offering, giving, or acceptance of a gift, loan, commission, reward, or any other benefit to or from any person as an incentive to do something that is dishonest, illegal, or a breach of trust.

4. Conflicts of interest

It is a duty of all PONGS Group officers and employees to avoid conflicts of interest between their private interests (directly or indirectly, or by related parties or companies) and the interests of the PONGS Group.

5. International trade

For the PONGS Group, the legislation governing international trade in their products and services is binding. All companies of the PONGS Group therefore comply with export or import bans and regulatory approval requirements due to national or international legal regulations.

6. Fair working conditions

The business success of the PONGS Group depends to a large extent on its employees. The company is therefore committed to the principles of social responsibility. Therefore, it is in the company’s interest that the PONGS Group has fair working conditions worldwide. Compliance with all local labor and social laws is a matter of course for the PONGS Group. The requirement of fair working conditions excludes any form of discrimination against employees based on their gender, sexual orientation, origin, color or other personal characteristics. The PONGS Group considers it its duty to be an employer around the world who respectfully and fairly deals with its employees. The PONGS Group therefore expects their employees to treat each other with respect. Discrimination or harassment will not be tolerated.

7. Child labor

The PONGS Group rejects child labor, even among its business partners. The minimum age for admission to employment in the PONGS Group in accordance with the relevant state regulation is observed.

8. Occupational safety, health, fire and environmental protection

It is the task of all employees to avoid hazards to people and the environment, to minimize the impact on the environment and to use resources sparingly. Processes, facilities and equipment must comply with the applicable statutory and internal requirements for occupational safety as well as health, fire and environmental protection.

9. Confidentiality

The knowledge and information acquired in the PONGS Group is an essential element for their business success. The PONGS Group invests substantial human and financial resources in the development of innovative products and services. The protection of innovations thus developed ensures the PONGS Group’s success in competition; It is therefore a special asset. All employees and corporate bodies of the PONGS Group are obliged to prevent this knowledge and information, insofar as they constitute trade or business secrets, from becoming known outside the PONGS Group, eg. by unauthorized dissemination of sensitive data in conversation with third parties, in professional journals or on the internet. In addition, any employee with such knowledge and information is required to know the extent to which obtaining intellectual property rights for such knowledge and information may be considered. Business or business secrets of business partners of the PONGS Group must also be protected against unauthorized disclosure.

10. Privacy

Respecting the personality of our employees includes the protection of their personal information. The PONGS Group therefore ensures compliance with the applicable data protection regulations and requires this from its employees.

11. Internal organization to comply with this behavioral code

Each organizational unit is responsible for complying with the regulations contained in this Code of Conduct as well as other internal rules within its area of ​​responsibility.