1. General principles

Integrity, credibility, transparency

trenzyme GmbH aligns its corporate actions and decisions with generally accepted ethical values, including integrity, credibility and respect for human dignity.

trenzyme GmbH promotes transparency, responsible management and control in the company in an appropriate manner.

 

Scope

The Code of Conduct represents binding rules which must be observed by every employee of the company. Members of the management and in particular all executives bear a special responsibility in actively implementing this Code of Conduct. They must act as role models in every respect. The Code serves as a basis and guide for dealing with ethical and legal challenges in day-to-day work. Any employee may contact his or her supervisor or the management with any questions or comments in this context.

 

Supply chain

The company expects its suppliers to comply with the guiding values of the Code of Conduct. The company supports them in this to the best of its ability and encourages them to do the same in their supply chains.

 

Compliance with laws

The company respects the laws and other legal regulations of the countries in which it does business. This also expressly applies to the provisions of national, European and international chemicals law, valid laws on the handling of biological substances and genetically modified organisms, as well as all valid embargo, customs and export control regulations.

2. Conduct towards competitors, business partners and third parties

Competition and antitrust law

The company respects the rules of fair and open competition and does not enter into any agreements that influence competition in an unlawful manner.

All employees of the company are obliged to comply with the rules of fair competition at all times. In particular, any agreement, but also any concerted practice with competitors on the following topics is prohibited:

- prices and price components

- terms and conditions

- customers

- delivery areas

- quotas and capacities

- agreed market exits

- coordination of planned innovations

- boycotts

 

Invitations to tender

If the contract is awarded on the basis of a formal invitation to tender, the company will neither discuss nor coordinate bids with other bidders. This applies to both public invitations to tender and restricted invitations to tender, and is independent of whether the procurement procedure is conducted by the public sector or a private entity.

 

Corruption

The company expressly opposes any form of corruption in Germany or abroad and avoids any appearance of influencing business decisions through unfair business practices.

No employee may exploit the company's business relationships for his or her own benefit or the benefit of third parties or to the detriment of the company. In particular, this means that no employee shall grant or accept inadmissible private benefits (e.g. money, material assets, services) in business dealings that are likely to influence an appropriate and proper decision.

Every employee of the company is obliged to seek advice or assistance in the event of suspicion or legal doubts about the existence of corruption or white-collar crime. Advice or assistance is provided by the company management.

 

Granting and accepting benefits, invitations and gifts

Invitations to business meals or events that are in line with recognized business practices and are appropriate may be both extended and accepted, provided that this does not serve the purpose of inadmissible preferential treatment. The same applies to the acceptance or giving of gifts. If there is any doubt as to the existence of an objective reason or the customary nature of a gift or gratuity, the employee must first contact the company management. This point is regulated internally in a comprehensive and unambiguous manner.

 

Public officials

Benefits of any kind granted to civil servants and other public officials as well as agents of state institutions, including indirectly through third parties, are prohibited, regardless of their value.

 

Political parties and elected officials

Benefits to political parties and organizations, as well as to elected officials and candidates for political office, are only made in accordance with applicable laws.

 

Consultants and agents

The use of consultants, agents and other intermediaries is not intended to circumvent the ban on bribery.

 

Donations and sponsorship

Donations shall be made only on a voluntary basis and without expectation of any consideration in return. Donations and sponsoring activities must not be aimed at covertly promoting decisions in the interests of the company. Every donation must be transparent and traceable. The recipient of the donation and the specific use to which it will be put must be known. It must be possible to account for the reason for the donation and the intended use of the donation at any time. Remuneration similar to donations is not permitted. Donation-like payments are payments that only appear to be compensation for a service, but whose value significantly exceeds that of the service.

 

Money laundering

The company does not tolerate money laundering. All employees are required to strictly comply with anti-money laundering laws. In addition, employees must immediately report to management any suspicious forms of payment or other transactions that may indicate money laundering.

 

Tax law / customs law / foreign trade law

The company shall prepare tax returns and declarations truthfully. All goods subject to customs duties must be properly cleared. The company consistently complies with the legal requirements of export control and customs in the subject areas of foreign trade and customs law and ensures their proper implementation.

The company also expects its suppliers to provide export control and foreign trade data in a qualified and timely manner and to continue to implement sufficient standards for supply chain security within the framework of global customs security programs.

 

3. Avoidance of conflicts of interest

Loyalty of employees

The company expects all of its employees to be fully loyal. It will ensure that employees do not find themselves in situations where their personal or financial interests could conflict with those of the company or its business partners. Company employees must immediately report any personal interest that may exist in connection with their work to their supervisors or to the company's management.

 

Secondary activities and shareholdings

Employees of the company are prohibited from working for another company or managing a company themselves that is in competition with trenzyme GmbH. This also applies to the participation of a close relative or life partner.

 

4. Handling of information

Company and business secrets

The employees of the company are bound to absolute secrecy regarding all company and business secrets and other internal matters. This also applies to the non-publicly accessible information of contractual partners and customers or the confidential information of these.

The access of employees to confidential information of customers and contractual partners is limited to what is absolutely necessary.

The obligation to maintain confidentiality shall continue to apply even after termination of the employment relationship.

 

Data protection

In addition to the general confidentiality regulations (e.g. § 17 UWG), data secrecy in accordance with DSGVO must be observed at all times. In particular, it is prohibited to process, disclose, make accessible or otherwise use protected personal data without authorization for a purpose other than that which is part of the respective lawful performance of the task. This obligation shall continue to apply even after termination of the employment relationship.

 

Duty of truth

All reports and other written documentation must be correct and truthful. This applies irrespective of whether the reports are internal or are given externally or to customers.Data collection and other records must be based on the principles of proper accounting and must always be complete and correct.

 

5. Principles of social and environmental responsibility

Social responsibility

Social responsibility is an indispensable component of value-based corporate governance and a key factor in sustainable corporate success.

 

Human rights

The company respects and supports internationally recognized human rights.

In this context, we are also in constant dialogue with our suppliers in order to avoid our products containing raw materials from conflict regions.

 

Child labor

The prohibition of child labor and forced labor in any form is respected and complied with.

 

Prohibition of discrimination

Discrimination against employees and third parties is not tolerated under any circumstances.

The company rejects any unacceptable treatment of employees; this applies in particular to sexual or verbal harassment.

 

Equal opportunities

The company attaches particular importance to equal opportunities for its employees.

 

Employee rights

The freedom of assembly and association of employees is recognized to the extent that this is legally permissible under national regulations.

The company complies with applicable national laws and labor standards with regard to appropriate remuneration, maximum working hours and adherence to break and lockout times.

This naturally also includes compliance with all provisions and rules of the minimum wage act in Germany.

Overall, the company pays attention to fair working conditions.

 

Occupational safety and health protection

Occupational safety and health protection in the workplace are ensured within the framework of national legal and official regulations.

A safe and healthy working environment is ensured by the company. It takes all necessary measures to prevent occupational accidents and damage to health that may arise in connection with its activities.

 

Environmental and climate protection

Sustainable environmental and climate protection are important corporate goals, as is maximum resource efficiency.

Both in the development of new products and services and in the operation of laboratory and production facilities, we ensure that any impact they may have on the environment and climate is kept as low as possible. Our services and products should make a positive contribution to environmental and climate protection for our customers.

Through their individual behavior, each employee assumes a responsibility to treat natural resources with care and thus contribute to the protection of the environment and climate.

 

Consumer interests

Insofar as consumer interests are affected, the company complies with consumer protection regulations.

 

Social commitment

The company contributes to the social and economic development of the country and region in which it operates.

 

6. Compliance with the code of conduct

Communication

The contents regulated in this Code of Conduct shall be made familiar to the company's employees and it shall explain to them the obligations arising from it.

The company also communicates the principles of this Code of Conduct to its business partners.

 

Guidelines and processes

The requirements for employee conduct set out in this Code of Conduct are to be regarded as a binding part of the employment contract and must therefore be complied with by employees.

The company takes all necessary steps to implement the basic values and requirements contained in this Code of Conduct through necessary and appropriate organizational measures, guidelines and processes in all business areas.

 

Regular Checks

The company undertakes to regularly monitor compliance with the Code of Conduct.

 

Notification of violations

Every employee of the company is obligated to report identified violations or even potential violations of laws, internal regulations and this Code of Conduct to the management without delay. Reports of a violation of this code shall be treated in strict confidence and shall not have any negative consequences for the reporting employee, unless an untrue fact has been deliberately alleged.

 

Consequences of violations

Violations of the Code of Conduct and legal provisions may result in consequences under employment and liability law, depending on their severity. Furthermore, criminal prosecution is also within the realm of possibility.

 

The management of trenzyme GmbH

Constance, November 2022