Code of conduct

Introduction
Our success is based to a large extent on two important factors which cannot be found in financial statements:

• The reputation of a modern company: a reliable, competitive supplier of systems and services
• The experience and competence of our associates

This reputation is very important, yet also highly vulnerable. Illegal or unethical conduct even of a single associate could have far-reaching negative consequences. Compliance with legal requirements has always been imperative for et TRANSVER and is part of our values. Only acting within the law guards against being open to blackmail.
Our conduct is shaped by our education and our culture; many things we do appear "normal" to us. However, it is important to formulate these rules of conduct so that they can become part of our culture in areas where they are not already in place.

For clarity, the following text uses the male form for functions and titles; obviously all statements apply equally to female persons.

PRINCIPLES

Compliance with the law
We advocate strict legality for all actions, measures, contracts and other actions. We do not just follow this principle because we would be subject to prosecution, fines or claims for damages and suffer commercial losses if we do not comply; we fully support the principle of acting within the law, regardless of whether et TRANSVER benefits from such behavior or not. Each associate is personally responsible for compliance with the law in his area of work. It is not permitted to encourage any third parties to act unlawfully or to knowingly participate in illegal activities; any such conduct will result in disciplinary action.
Managers are responsible for the publication, enforcement and information about possible consequences of acting against this regulation within their area of responsibility.

Company reputation
In fulfilling their tasks, all associates must consider et TRANSVER's reputation as a company.

Conduct toward associates
We respect and protect the personal dignity of each individual. Respect is one of et TRANSVER's guiding principles. We will not tolerate any religious, sexual, linguistic or other discrimination, neither will we tolerate any harassment, bullying or threats against our associates.

AVOIDING CONFLICTS OF INTEREST

Secondary employment
Any secondary employment is only permitted with prior approval by the management, and only if the employers concerned are not in competition with et TRANSVER and the associate's performance is not negatively affected.

Private commissioning of business partners
Associates require prior written approval by their line manager when using any of et TRANSVER's business partners privately if they are directly dealing with the handling and execution of orders so that there may be a conflict of interest.

HANDLING OF INFORMATION

Confidentiality
Any proprietary and confidential company information must be kept secret. This obligation remains in force after the termination of employment.
Data protection and information security
Privacy must be protected when processing personal data, equally the safety of all commercial information, subject to current legal requirements, in all business processes.

CONDUCT TOWARD BUSINESS PARTNERS AND THIRD PARTIES

Competition and anti-trust law
All associates are obliged to conform with the rules of fair competition within the framework of legal regulations. Special allocations of territories or customers, agreements or exchange of information on prices, conditions of supply etc are not permitted among competitors.

Relationship with suppliers and customers
Agreements with customers and suppliers must be complete and unambiguous and must be documented, including any subsequent changes or additions. Internal regulations concerning dual control ("four eyes" principle) and the separation of operational and control functions must be strictly adhered to. Suppliers must be selected on commercial grounds alone.

Corruption, gifts and other benefits
Any agreements involving favors to certain persons in connection with the procurement, commissioning, delivery, processing and payment of orders are not permitted. Commissions and payments to dealers, agents or consultants must be within a tolerable ratio to services rendered. No services must be agreed upon whose purpose may be regarded wholly or in part as a payment of bribes.
Commissions or gifts of any kind which an associate has received in the course of his professional activities or business relationships are principally company property.
When giving or receiving gifts and other benefits (e.g. attending events not directly related to business) including invitations, there should be a highly restrictive approach. The financial aspects of these benefits must be such that their acceptance must not be kept secret and does not result in any binding dependency. In case of any doubt or if the financial gain exceeds CHF 200, written permission must be obtained from the relevant line manager.

PRODUCT QUALITY AND SAFETY

We aim to fulfill our customers' quality requirements. If, despite our efforts, any defects are reported, we will strive to rectify them in accordance with legal and contractual obligations.

HEALTH AND SAFETY, FIRE AND ENVIRONMENTAL PROTECTION

All associates are obliged to avoid any threat to human health and the environment, reduce any environmental impact and conserve resources. Legal requirements regarding health and safety as well as fire and environmental protection must be adhered to.

REPORTING OF IRREGULARITIES

All associates are obliged to report to their superiors any instances which may be regarded in breach of this code of conduct; this may be done anonymously.