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1. Horn & Co. Group Code of Conduct.

The Code of Conduct, alongside our corporate policies and corporate goals and our motto of “Strength through diversity,” stands as an outline of principles for our actions and behavior. It applies directly to every employee. In order to address nuanced questions, the document uses a “traffic light system” to give practical advice on implementation.

2. Each employee is required to observe this Code of Conduct and to be involved in its implementation, enforcement, and continued development.

2.1 Law and society

We observe and act in accordance with the Universal Declaration of Human Rights. We do not violate the statutory rights of our employees or any other personnel with whom we work in the course of our business activities. When hiring and dealing with workers, and in all of our business and commercial activities, we do not discriminate based on race, skin color, sex, religion, political worldview, country of origin, social background, disability, sexual orientation, etc.

We do not tolerate child or forced labor in any area of our business activities. In addition, we do not engage in transactions with any professionals who are involved with child or forced labor.

Following statutory provisions
To fulfill our societal expectations, and as a foundational basis for trust, all managers and employees of the Horn & Co. Group understand this aspect as more than just compliance. Instead, we understand this as our social responsibility which must be observed. In our everyday business activities, we act in a manner conforming to statutory provision and social ethics.

2.2 Customers and business partners

Our mission: customer orientation

Safety of products and services
We observe statutory provisions on product safety in the course of our business activities.

We actively deliver information related to our products and services, prevent product-related accidents in advance and maintain/strengthen a relationship of trust with our customers.

Honest and fair business practices
We engage in honest and fair competition to gain the trust of our customers, business partners and society as a whole. We do not take any actions that violate competitive laws and anti-trust laws in different countries and regions.
In particular, we do not engage in anti-competitive price fixing or agreements on conditions, do not attempt to divide markets, do not engage in bidding collusion or calls for boycotts As part of carrying out our business activities, we confirm competitive law provisions and regulations that affect our business activities.
If we become aware of contractual conditions or forms of business that restrict fair competition, or if we become aware that such a condition could exist, we always contact a supervisor for advising/confirmation, and act accordingly.

Hospitality and exchanging gifts
We do not give monetary gifts to business partners or their executive employees, in order to receive preferential treatment in the course of a business relationship.
If we provide hospitality to guests or exchange gifts, we do so within a reasonable framework and in compliance with customary business practices, observing internal provisions for hospitality established by the individual companies on exchanging gifts, granting favors, and other economic advantages.
If accepting a gift would be in line with the customs and practices typical for a country, and the gift cannot be rejected for cultural reasons, then it may be accepted. The gift-giver must observe this regulation, and must inform their supervisor of the gift. In general, all employees are prohibited from accepting money or other in-kind benefits from third parties, such as loans, securities, or commissions.
We do not accept hospitality or gifts if they will or could influence the business decisions of the Horn & Co. Group.

Any form of corruption, such as fraud or granting or accepting other advantages, is prohibited, regardless of whether such advantages are granted directly, through an intermediary, to private individuals or governmental officials. Organizing (active fraud, granting advantages) and accepting (passive fraud, accepting advantages) contributions, in particular, is prohibited if the purpose of these is to gain any illegal advantage.

2.3 Employees

Our mission: Employee orientation

Manager responsibility
We expect our managers to show strong leadership, ambition, responsibility, the courage to make changes, and the ability to act as a role model.
Our managers should familiarize their employees with this Code of Conduct. Our managers should create opportunities to talk about this Code of Conduct with their employees and inform them of its importance.
Our managers do not give employees instructions to and do not suggest that they engage in any actions that would violate social ethics, statutory or internal company provisions, even if these would help achieve success targets.
Our managers should create an open working environment where employees can communicate problems related to the Code of Conduct without worry.
Our managers do not ignore problems related to compliance with the Code of Conduct, but instead act promptly and appropriately to take corrective measures to handle problems.

Respectful treatment
We expect that employees treat one another respectfully both on different levels and between levels of the company. We also actively promote this value in our customer and supplier relationships.
The Horn & Co. Group is committed to equal opportunity, appreciation, trust and performance. We offer our employees a challenging work environment, and support our employees in working to their full potential by setting high goals. We promote a culture of mutual trust, respect and open dialog.
Every employee has the right to an individual performance assessment.
We foster a culture where people can develop their talents and ideas and can be motivated to provide great performance.
We support the development of our employees, set challenging goals, and reward good performance.
We promote responsible action by every employee, as well as teamwork. Each employee is required to act to the best of their knowledge and ability, and in accordance with generally recognized ethical principles, and to inform supervisors of problems.

Loyalty and conflicts of interest
We do not engage in any actions where private interests (including familial interests) and any company conflict. If such conflicts are possible, we always contact a supervisor for advising/confirmation, and act in an appropriate manner.