Code of Conduct

The MEC Code is intended to help MEC employees understand and adhere to these standards in their daily activities and is not intended to serve as a replacement for the laws, regulations, and internal policies that govern our operations. The relevant Group Guidelines and Group Policies are being updated and distributed continuously. Any changes to this Code may only be made by MEC, Corporate Office, and will be disclosed.

Each of us must be committed to living our values and using our MEC Code as a guide for interactions with our stakeholders, including fellow employees, customers, business partners, shareholders, suppliers, government agencies, and communities, whose trust in the responsible and lawful conduct of all MEC employees is vital to us. Accordingly, we have the responsibility to report concerns about possible violations of the MEC Code, company policies, or laws and regulations. MEC employees should first contact their supervisor to raise their concerns. However, if you are uncomfortable talking to your supervisor, contact MEC Human Resources or MEC compliance via e-mail

                                               compliance@MEC-Holding.de 

lt is important to note that violations of the MEC Code, company policies, or laws and regulations will be taken seriously and may result in disciplinary action up to and including termination, or / and legal proceedings and penalties. 
To simplify reading, the MEC Code makes no distinction between the male and female language form. The wording refers to all genders equally (m/f/d). 
 

2.    Supervisor and Manager Responsibilities

Leaders, supervisors and managers have the following responsibilities:

• Lead by example and model the highest standards of ethical business conduct and our company values.
• Take the time to ensure your employees know how to use the MEC Code and how to seek additional help.
• Help create a work environment that focuses on building relationships, recognizes effort, and values mutual respect and open communication.
• Be proactive. Look for opportunities to discuss and address ethics and challenging situations with others.
• Create an environment where everyone feels comfortable asking questions and reporting known or potential violations of the MEC Code, policies, or the law.
• Strictly avoid acts of retaliation or behavior that may be perceived by others as retaliation against those who report concerns.
• Respond in a timely and effective manner to concerns which are brought to your attention. Respond after reflecting and seeking advice, if needed.
• Never ask or pressure anyone to do something that you would be prohibited from doing yourself.

3.    Human rights -  child labor/forced labor - prohibition of discrimination

MEC adheres to internationally recognized human rights and general ethical principles for the rejection of child labor and forced labor.

Make sure you:

• lmmediately report any suspected potential human rights related violations.
• Strictly prohibit use of child or forced labor, including prison or bonded labor.
• Commit to obeying the associated laws and regulations and where these laws vary or conflict, follow the highest standards.

The diversity of the people working for MEC is a strength of our company. The differences in terms of origin, culture, language and way of thinking of our staff give us a competitive edge. They contribute to new ideas and innovations because of their willingness and openness. 
We expect that each employee treat colleagues or third parties in a respectful, fair, friendly and professional manner. Discrimination based on race, color, sex, sexual orientation, religion, national origin, age, physical handicap/disability, or other traits protected by local law, will not be tolerated at MEC. Firm steps are taken against inappropriate discrimination, preferential treatment, bullying, exclusion and other attacks that injure or curtail the dignity and honor of employees at their workplaces. 

We do not tolerate harassment of any kind. Verbal or physical conduct that harasses another, disrupts another's work performance, or creates an intimidating, offensive, abusive, or hostile work environment will not be tolerated. Harassing conduct can include inappropriate gestures, remarks, or touching or displaying sexually explicit or offensive pictures. Promises of promotion or special treatment in return for sexual favors also constitute harassment. 

Make sure you: 

• Treat others respectfully, professionally, and promote diversity in the workplace.
• Avoid making comments or jokes, and sending or posting materials which others might consider offensive.
• Avoid discrimination against others on the basis of any characteristic protected by law.
• Review your own decisions to ensure that you are using objective and quantifiable standards and business considerations to drive your actions.
   

4.    Antitrust and competition law

The provisions of the antitrust and competition law serve for a fair and genuine competition in the interest of all market participants.
These prohibit obligations and actions, which can lead to a restriction of trade or competition. Legal violations especially cover price-fixing, agreements to boycott of certain nations, suppliers or customers, division of customers or markets, or restrictions in sales and distribution or in the production area. Every employee has to avoid the appearance of such conspiracy.
MEC employees must not engage in any anti-competitive practice and shall comply with the antitrust and competition laws.

Make sure you:

• Never share the company's sensitive information with any third party without authorized permission.
• Never share sensitive information of business partners or other third parties with others without their permission.
• Never take advantage of anyone through manipulation, abuse of privileged information, misrepresentation of facts, or any other intentionally unethical or illegal action.
   

5. International trade - prohibition of terrorism

MEC is committed to respect and to take into account national, multinational, and supranational foreign trade regulations. In particular, this concerns:

• Customs regulations as weil as the provisions supported by the international community for preventing the production and sales of chemical, biological and nuclear weapons and their support systems as weil as
• The prohibition of export and re-export of certain products, technologies and services to certain nations, organizations or individuals for the prevention of international terrorism.

We do not allow our affiliates to participate in trade or transactions with persons, who have been expelled in connection with terrorist activities, belang to terrorist organizations or groups or are close to them. 
While exporting goods, it is to be ensured to the extent necessary that the prescribed end user identifications/certificates are available. 
MEC employees shall strictly follow local law in relation to terrorism and terrorism financing. In addition, with regard to the foreign trade regulations, the German legal system is basically binding to the extent it is not inconsistent or contrary to the relevant local regulations. In addition, the management of MEC may also decide to comply with the laws and regulations on foreign trade control of other countries. lf doubts or uncertainties remain, then MEC will not perform the corresponding export operation. 

Make sure you: 

• Understand the trade controls related to MEC products, technology, and information and the restrictions on transferring those items to entities outside the company.
• Comply with all export and import laws, regulations, and requirements and with Company trade control policies.
   

6.    Safety at the workplace - health and environment

The circumvention, control and prevention of risks for people and the environment represents an essential part of our responsibility-conscious and sustainable actions. This includes protection of the environment and conservation of its natural resources. Therefore, MEC follows the laws enacted to protect the environment, as weil as the technical and health safety in production or development of our products.

Make sure you:

• Comply with all applicable environmental laws, regulations, and company policies.
• Do your part to reduce water and energy use.
• ldentify opportunities for improving our conservation and recycling efforts.

Each employee is responsible for the security at his or her workspace. The safety regulations must be implemented and adhered to strictly. All employees are requested to show initiative and to develop an awareness of the hazards, which is not only in their own interests, but also in the interest of all colleagues, as weil as the MEC Group as a whole. Every employee is required to immediately report to his superiors about any existing or potential sources of hazards. 

lt is not permitted to bring weapons to work. MEC employees are prohibited from entering the company premises and/or carrying out official duties under the influence of alcohol or non­medically prescribed drugs. MEC operates a no smoking policy within all buildings at each of its locations. 

Make sure you: 

• Review and follow the safety, security, and health rules and practices that apply to your job and your facility.
• Do not bring prohibited items, such as explosives (fireworks, firearms, or ammunition), knives or other weapons into company facilities or to company sponsored events.
   

7.    IT - Data Security and Data Protection

In order to maintain the confidentiality, integrity and availability of the company's IT systems, applications, digital services, data and documents, employees must use the IT assets and systems assigned to them in the manor for which they were specifically intended and according to any relevant policies on acceptable use.
All employees are prohibited from using the company's IT assets, digital services, applications, documents, support documents or data carriers outside their business activity for private purposes without prior consent/permission from their superior.
The documents and information used at the workplace must not come into the possession of unauthorized persons. Employees must protect devices used to access company data, applications and digital services by the security mechanisms specified by the issuing IT organization and its policies on acceptable use. Passwords, PINs and authentication devices/services must be protected to prevent unauthorized access. Unauthorized access to data by third parties must be actively prevented at all times, even in the event of a lang absence of the employee from his workplace.

Make sure you:

• lmmediately report any suspicions of fraud, theft, or misuse of company assets.
• Do not share passwords or allow other people to use company resources.
• Do not attempt to access any data that you are not authorized to view.
• Do not download, install, or run unauthorized or unlicensed software on company information technology.
• Never copy, install, or use company software or the company's digital services for personal purposes.

Personal data in particular must be protected. To protect personal rights, personal data may only be accessed, processed and used in conformance with the applicable legal provisions. 

Since the information technology we use when working for MEC belongs to our company, you should not have an expectation that emails, internet activity, computer files, and the like are private. MEC reserves the right to review all information technology usage and will do so in accordance with the law. 

Make sure you: 

• Learn which types of information are given heightened protection by the law and company policy (such as government issued identification, bank account numbers, and medical records) and protect them through appropriate means (such as encryption or other types of limited access).
• Protect the confidentiality of personal information of current and former colleagues, as well as job applicants, business partners, and customers.
• Do not access, discuss or share confidential information unless there is a legitimate business reason to do so.
• lmmediately report any loss or inadvertent disclosure of confidential employee information.
• Ensure recipients of employee information will safeguard the information.
   

8.    Social Media

Social media use must not interfere with employee's responsibilities at MEC. Every MEC employee has to use social media responsibly, adequately, cautiously and appropriately. At MEC Group it is allowed only for authorized employees to give official statements, in particular to the press and other media. This includes not to appear on behalf of any company of MEC Group as well as not to disclose any company internal information. lt further includes the protection of not only the employee's own privacy, but also of others and requires coherence with local and with international law where applicable.

Make sure you:

• Are familiar with the MEC policy based on the internationally accepted "10-Golden-Rules for use of Social Media".
• Never post company confidential, export restricted, or classified information.
• Never post false information or anything that might defame others or damage our brand or reputation.
• Never post material that is obscene, threatening or abusive toward any person.
   

9. lntellectual property rights and copyrights

Our research and development results and our inventions, patents and other know-how are valuable assets and belong to MEC. Our success, the value of our company, our growth and not the least our competitiveness are based on these assets.

The "Patents, Licenses and Trademarks" responsibles takes care of the legal protection of these inventions and the right to the exclusive use of a patent for a certain period. 
No employee, also after leaving the company, may pass on information about MEC owned knowledge or business secrets to any third party. 
Every employee must respect commercial protection and copyrights of third parties and must avoid their unauthorized use. The installation and use of software applications and digital services is subject to the license conditions of the manufacturer, including the number of licensed workplaces, as weil as local policies relating to software procurement and installation. 
 

10. Relationships with third parties - Anti-corruption legislation

All suppliers (for products or services) are to be selected solely on the basis of objective criteria; these include for example price, quality, service, technical Standards, product suitability, long term business relations, certification according to general standards (ISO standards) and, if appropriate, strategic considerations. Personal interests or personal relations must not affect the conclusion or award of a contract.
No unlawful advantage of any kind may be offered or rendered to government officials. Details are provided in the national legal codes for granting and receiving benefits.
An MEC employee is only permitted to personally accept a gift or grant or benefit of any kind, to the extent this is legal.
This shall prevent bribery, corruption and other suspicious benefits and shall ensure compliance with the MEC Code as weil as with local laws and regulations against corruption and bribery in place.

Make sure you:

• Never directly or indirectly offer, provide, or authorize money or any item of value to improperly obtain or retain business or to improperly influence a third-party's action.
• Never directly or indirectly request, agree to receive or accept kickbacks, payoffs or other personal payments in connection with company business.
• Report suspicious activity such as payments to offshore banking locations, payments to third parties outside the territory in which the third party operates, and false invoices for sales.
   

11.    Conflicts between company and private interests - Company property

Every MEC employee must avoid conflicts between diverging interests of the company and private interests. As an MEC employee, every individual is required to avoid any behavior that could conflict with the interests of the company, or be of any material or immaterial or intangible disadvantage for the company, or may cause any damage with regard to the reputation of the company, even when pursuing personal activities:

• The acceptance of an additional work contract or service contract of any kind with a third party during the term of the employment with MEC, requires prior written consent from the Management Body or from the competent supervisory body.
• Any other remunerated or gratuitous affiliation to profit making organizations requires the prior written consent of the Management Body or from the competent supervisory body. This does not apply to the normal purchase of stock or other business shares for private investment purposes.
• Membership of representative bodies or supervisory bodies of any other companies also requires the prior written approval of the Management Body or from the competent supervisory body.
• Any interest as expressed in a direct participation, (co-)ownership, financing arrangement or any other affiliation with a competitor, customer or supplier require prior written consent by the Management Body or the competent supervisory body. The Management Body or the competent supervisory body is to be immediately informed, in so far as legally permissible, about material participations of relatives2 in competitors, customers and suppliers.
• The conclusion of a contract or other business activities with himself or with a legal person controlled by him as well as with relatives or legal persons controlled by them requires prior consent from the Regional CEO, but always at the minimum two levels up.
• Employing relatives2 within MEC requires the express and written prior authorization of the Management Body or the competent supervisory body.

In individual cases, the said activities can be permitted by the Management Body or the supervisory body. lt should be ensured that the concerned person is neither directly nor indirectly involved in the decision on awarding the contract. 
Make sure you always make business decisions in the best interest of MEC. Seek guidance to avoid potential conflicts of interest. 
 

12. Files - Support documents - Corporate information

All work results and all company data must be rendered correctly, in detail, clearly and in a timely manner, pertaining to all relevant facts. Violations against any laws and regulations shall not be tolerated. The same applies for any non-execution of company regulations, reporting and requirements.
Official statements, particularly to the press or other media shall be issued exclusively by the employees authorized for the purpose.

All employees who are responsible for collecting corporate inforrnation and its dissemination to the competent authorities must communicate this information cornpletely, honestly, correctly, on time and comprehensibly. 
All support documents and files must be maintained such that it will be possible for a colleague to represent. Files must therefore be complete, orderly and self-explanatory. 
 

13. Compliance violations

lf you observe or suspect any illegal or unethical behavior, you are expected to raise the issue to your management or one of the other resources listed below. At MEC, there is no tolerance of retaliation for those employees who, in good faith, report possible ethics or compliance violations. lt is therefore expected that all MEC employees cooperate with internal and external inquiries and investigations. 

13.1 Asking Questions and Raising Concerns
The rules of the MEC Code are directed at all MEC employees, including managing directors and executives and require checking one's own behavior in the light of the represented standards and adapting accordingly. lf there are doubts about a violation of these standards, the employee can obtain advice from the respective competent functional or corporate department. 

13.2 Non Retaliation
MEC employees can report suspected ethical violations in confidence and without fear of retaliation. MEC will not tolerate any retaliation against an employee who, in good faith, asks questions, reports possible violations of the Code, policy, or law, or participates in an investigation. 
Reporting "in good faith" means making a genuine attempt to provide honest, complete, and accurate information, even if it later proves to be unsubstantiated or mistaken. Retaliation is a violation of our Code and knowledge or suspicion of retaliation should be immediately reported. 

13.3 Cooperating with Inquiries and Investigations
MEC employees are expected to fully cooperate with internal and external audits, investigations, and inquiries that are conducted by the company. In addition, withholding information or knowingly giving false or misleading information is a serious violation of our duties as employees.

¹ See www.unglobalcompact.org/languages/german/ or in English: unglobalcompact.org/AboutTheGC/index.html.
²The term "Relatives" in the sense of the clause 10 is understood to include the following persons: (1) Fiance, (2) spouse, (3) relatives, where this means relatives of the first order as weil as persons whose relation is formed through a marriage, (4) kin (brother/ sister), (S) brother's /sister's children, (6) spouse of the brother/sister and brother/sister of the spouse, (7) brother/sister of parents, (8) persons who are living on a lang term basis in a common household in a parent-child relationship (foster parents and foster children). The above listed persons are still regarded as relatives, if (a) in the cases No. (2), (3) and (6) the marriage on which the relation is based is no langer valid, (b) in the cases No. (3) to (7) the relationship was terminated by an adoption or (c) in the case No. (8) the common household no langer exists, so lang as the persons are related as parents and child.