I. General

Scope and objectives

This Code of Ethics applies to all of Kittner’s business activities and establishes clear standards for proper business conduct. We are firmly committed to managing our business in accordance with the highest standards of business ethics and behaviour, and to encouraging our employees to discuss ethical issues with company leaders so that we can sustain this high standard.

By this Code of Ethics, we clearly declare:

To be an ethical company that complies with all domestic and international laws and regulations through fair and transparent management methods.

To continuously satisfy customer expectations by improving the quality of our products and services and reducing their production costs based on appropriate improvement measures.

To strive for maximum corporate growth through fair and efficient management.

To work towards creating a transparent corporate culture through fair trading practices and competition.

To collect and analyse information from our customers about the quality of our products and services and measure how closely they meet their needs and expectations.

To continuously improve the qualification and motivation of employees for high-quality work performance.

To strive to be a company with the highest qualified human resources, offering our employees equal opportunities in a safe and comfortable working environment according to national and international standards.

To become a preferred partner in the market.

Kittner Anlagen- und Maschinenbau expects and requires each of its employees to act in accordance with applicable regulations and in accordance with the company’s core values and business principles. Each of us has a responsibility to act with honesty and integrity and to conduct ourselves ethically at all times. No employee shall exploit his or her position for personal gain or patronize or tolerate any behavior inconsistent with this Code of Ethics. We also expect our suppliers, consultants, independent contractors, intermediaries and other third party representatives to meet these standards.

Executives at Kittner are expected to establish the highest ethical standard for themselves, in turn serving as examples to their teams. This leadership through personal contribution is critical in establishing and maintaining the firm’s standards described in this Code. Managers are also expected to be diligent and vigilant to potential violations of the Code and to report concerns in a timely manner.

II. More integrity in business processes

  1. 1. Open and fair competition

Kittner is committed to open, fair and legal competition in global markets. Anti-competitive price agreements with competitors or market sharing, as well as market dominance abuse, are prohibited.

Employees must avoid situations in which their personal interests conflict with their duties at Kittner. If such a conflict of interest occurs, the employee must inform his or her supervisor.

Employees are especially prohibited from participating in associations with competitors, suppliers or customers or from working for them and their interests.

  1. 2. Obligations to our customers

Customer satisfaction:

We recognize that customer satisfaction is achieved primarily by providing the best quality products on time and will make every effort to achieve this goal.We have our customers as the foundation of our company inspiration and development. Their satisfaction should be our top priority and the basis for our actions and decisions. We must protect the interests and integrity of our customers.

Fair Business Practices:

We will not use our position in the market to justify unreasonable actions or exert improper influence.

Mutual Trust:

We must strive for fair and open business actions based on mutual trust and cooperation. We must support and encourage business ethics in our partners.

III.        Responsibility to employees

  1. 1. Human Resources Development

The variety of our employees is a source of strength for our company. We value and respect people with different qualifications, abilities and viewpoints.

We must be guided by the sovereignty and creativity of our employees, supporting their self-improvement. We need to create a system for the performance of duties and the personal development of all employees, and also an environment in which this can be realised.

We comply with all applicable labour and employment laws, including those that prohibit discrimination and harassment and ensure reasonable accommodation of differences. Employees must be selected and promoted on the basis of their qualifications, regardless of race, age, gender, citizenship, religion, sexual orientation, disability.

  1. 2. Health and safety at work

It is essential that Kittner employees work in a safe and clean environment. We are committed to complying with all health, safety and environmental laws and regulations that apply to us and strive to monitor and review every activity for continuous improvement.

We must make every effort to prevent accidents at work and to provide clean and safe working environments. We must conduct regular safety inspections of our buildings and facilities and regular safety training for all employees to ensure their safety in the workplace.

IV. Ethics of employees

  1. 1. Work with integrity, fairness and respect for one another

Our philosophy at work is that each of us, employee and supervisor, shares responsibility for ensuring the Kittner company’s success.

Our relationships with each other are based on trust, tolerance, ethics and cooperation. It is essential that we respect others who may have different ideas and opinions. We treat the different cultures and customs of colleagues of other nationalities and religions with consideration and care. We must recognise the importance of all employees and workers and respect their individuality, rights and dignity.

Personal insults, disagreements, sexual harassment or physical violence and harm are not tolerated. They shall be punished with the full weight of the law. Disputes, criticisms and disagreements shall be resolved by civilized methods in open communication. The privacy of each employee shall be respected and kept inviolable.

  1. 2. Fulfillment of duties

All employees must faithfully perform their duties based on all applicable rules and regulations as well as company business policy. They must know their rights and responsibilities and make decisions and act in accordance with Company objectives and the Code.

All employees must understand that deliberate or reckless handling of documents or calculations can lead to errors in company decision-making and therefore must write down and report all information accurately.

In the case that Company employees have made an error in documents or calculations due to carelessness, they should immediately inform their supervisor about it in order to correct it.

All employees must actively collaborate both within their department and with colleagues in other departments to maximize work efficiency.

  1. 3. Good and credible communication

Communication and information exchange in the company are based on the procedures for each process, the responsibilities and authorities corresponding to the functional and hierarchical levels, and the working procedures regulated by internal acts and certificates.

We must be sure that what we write and say while we are at work and outside of work is representative of the integrity and standards expected of us.

To protect Kittner’s reputation and your own, it is important that all written communication be prepared with care and with the understanding that it may one day become public. While surfing the Internet outside of work through your personal computer systems and devices, you should be careful not to post material on social sites that disparages the company, defames suppliers or customers, reveals trade secrets, or infringes Kittner’s copyrights and patent rights.

If a news media reporter or journalist, industry professional or anyone else asks you to discuss or comment on matters related to Kittner, you should contact Kittner management according to the type of event.

  1. 4. Protection of Personal and Company Secrets and Confidential Information

Confidential information, which includes trade secrets and proprietary information relating to us, our customers and suppliers, is a valuable part of our business and we are committed to protecting it. Confidential information and records should be treated with great care and electronic devices should not be left unattended, especially during travel and business events. Such information should not be shared with anyone outside Kittner unless required by law or authorized business persons.

Employees who have information about Kittner’s strategy, policies, plans or assets shall not use it in an unauthorized manner – without proper authorization outside of their official duties for their personal benefit or the benefit of third parties.

We respect the privacy of our employees and are committed to protecting their personal information. We will collect, use and disclose personal information only for legitimate business or employment purposes and as required by law. We will also take adequate steps to protect the confidentiality of personal information we have collected.

The Company guarantees the confidentiality of the use and storage of the personal information provided in accordance with the Personal Data Protection in Electronic Information Exchange Act.

  1. 5. Corporate capabilities and property values

As employees of Kittner, we must avoid situations in which our personal interests conflict with the interests of the company or situations that leave this impression.

Kittner provides its employees with the material assets necessary for the performance of their duties, e.g. buildings, equipment, appliances and other property assets, e.g. inventories, liquidity, rights, know-how. Employees must treat these tangible and other property assets in good faith and protect them from loss, theft or damage.

Kittner’s tangible and other property valuables must be used only for business purposes. Company resources should not be used for your personal benefit. Nor should you engage in any activity that places you in a competitive position against Kittner.

To help Kittner Company succeed, you must devote your full time and attention to your work during the workday. You must not be allowed to accept outside engagements that would reduce the time and attention you can devote to your work.

  1. 6. Giving and receiving undue advantages

Our relationship with all business partners must be based on integrity and solid business information. No employee shall, in the course of his/her official dealings or dealings with institutions, directly or indirectly, create any improper advantage or bribe for his/her business partners, their employees or employees of institutions. Similarly, an employee shall not demand or accept unauthorised advantages or bribes from business partners. We must also always ensure that records of all payments we make are accurate and complete.

An advantage is improper when its type and amount serve to influence the recipient’s actions and decisions.

In our business relationships with customers or suppliers, it is acceptable to give or receive business gifts if they are reasonable or of modest value. These may be company promotional materials – calendars, company notebooks, pens, souvenirs, etc.

  1. 7. Sexual harassment at work

All employees should recognize the illegality of sexual harassment in the workplace and the resulting demotivation and reduced productivity. Any acts of a sexual nature are prohibited in the workplace. In order to prevent sexual harassment in the workplace, appropriate educational training must be provided to all employees.

V. Internal Standards

Integrated management system

In order to demonstrate the company’s ability to provide its customers with products and services that meet their requirements, an Integrated Management System has been developed and implemented in the company in accordance with the requirements of the international standards: the ISO 9001:2012 Quality Management System.

VI. Implementation of the Code of Ethics

  1. 1. Implementation and information

The Code of Ethics has been approved by the Management of Kittner Anlagen- und Maschinenbau Ltd. Every employee, including new ones, must be informed of it.

It is published and appropriately presented on the company’s website:

www.kittnerbg.com

  1. 2. Consequences for breach of the Code of Ethics

We are strongly committed to the values of the Code of Ethics and will take seriously any failure to comply with these obligations. Violation of the Code of Ethics may result in disciplinary sanctions for employees. The type of sanction will depend on the seriousness of the violation and, in more serious cases, may include disciplinary dismissal.

Consequences may also be the same for our suppliers, consultants and other third party representatives who fail to meet our ethical standards. If the violation is very serious, it may also result in termination of the relationship with them.

You should also note that some sections of the Code of Ethics simply reflect applicable legal requirements. This means that in some cases an action that violates the Code of Ethics may also be a violation of the law. In these cases, the penalty may include a fine or imprisonment.

Information about actual and alleged violations must be submitted to Management in writing and in a non-anonymous form to be analyzed in accordance with applicable law.

Complaints, reports of corruption or non-compliance with the Code of Ethics should be sent to:

 

hr@kittnerbg.com or in writing to the HR Department with guaranteed confidentiality.