Code of Conduct of the TIMETOACT GROUP

The companies of the TIMETOACT GROUP have a great interest in compliance with the applicable antitrust and competition regulations, because non-compliance can have serious consequences for the companies. In particular, fines or other forms of fines may be imposed on the company concerned, agreements may be invalid, third parties may be able to claim damages, and there is a risk of reputational damage and negative press if violations of the law become public.

In order to avoid damage to the companies of the TIMETOACT GROUP as a result of antitrust and competition violations, the following must therefore be observed in particular:

The conclusion of agreements of any kind or concerted practices (e.g. informal cooperation) with competitors or with customers that are intended to restrict competition or that have an anti-competitive effect are considered to be violations of antitrust law. Business talks with competitors can also be regarded or interpreted as violations of antitrust law in individual cases. This may be the case in particular in the case of

• agreements to set or control prices (e.g. minimum prices, minimum fees or discounts);
• exchange of information on prices, conditions of sale, discounts and promotion measures;
• agreements on territorial sharing of markets;
• specific invitation to tender;
• agreements on the allocation of customers;
• agreements on the restriction of production or the sale of products;
• agreements to boycott certain business partners or customers;
• Agreements on vertical restraints (e.g. prohibition of passing on discounts).

If a business-related discussion is held with a competitor on one or more of the aforementioned topics, employees should not participate in the discussion or leave the meeting, as meetings of this kind may constitute or at least indicate anti-competitive cooperation.

In the course of their work, employees and management may become aware of information that is not publicly known and is relevant to the trading of securities. The use of this information may constitute insider trading. Insider trading is the unlawful use or disclosure of insider information.

Inside information is specific information about circumstances that are not publicly known that relate to a issuer of insider securities (financial instruments of any kind such as shares, bonds, warrants and derivatives) or the insider securities themselves and are of such importance that they can significantly influence investors' decisions when buying, selling and holding securities.

In particular, the following information may be inside information:

• Takeover bids
• The company's research success
• New Product Launch
• unexpected increases in profits or large orders
• unexpected slump in profits
• Insolvency filing due to insolvency or over-indebtedness
• Corporate mergers
• Personnel changes
• planned IPOs
• Change in management

The current regulations on insider trading are complex. Even if there is a suspicion of a violation of the laws and regulations on insider trading, there is a risk of damage to reputation. In addition, insider trading can be punishable by law.

Employees are therefore not allowed to:

• acquire or sell inside securities for their own account or for the account of other persons using inside information,
• disclose or otherwise make available to other persons inside information of which you have knowledge without authorization, or
• Recommend that any other person purchase or dispose of inside securities, or induce any other person to trade in inside securities based on your inside information.

Employees must ensure that insider information is only ever passed on internally to those persons who are authorised to take note and who need insider information for their work.

Data protection serves the right to informational self-determination of the individual, i.e. the right of every person to determine for himself the disclosure and use of his or her personal data, such as name, postal address, e-mail address, telephone number, financial circumstances, etc. Data protection is necessary to prevent a violation of fundamental personal rights.

The companies of the TIMETOACT GROUP give high priority to the protection of personal data. Therefore, the companies of the TIMETOACT GROUP do not process (i.e. collect, store, change, transmit, block, delete, etc.) personal data or use it as a matter of principle, unless full compliance with applicable law has been ensured in advance, in particular in the course of the use of artificial intelligence. Where necessary, personal data will be anonymised or pseudonymised. The handling of personal data must be transparent for the data subject. The right of the data subject to be informed about the handling of the personal data and to be able to request a necessary correction of the data must also be guaranteed. The same applies to the right of the data subject to object to the processing of personal data if the legal requirements are met, or to request the deletion or blocking of personal data.

Employees may only use personal data that has been disclosed to them or to which they have access in the course of their work for a company of the TIMETOACT GROUP if there is a legal basis (which also includes the necessity of storage or use for the purpose of a contractual relationship, in the case of employee data, the necessity for the establishment, implementation or termination of the employment relationship,  ) or with the consent of the data subject. This also applies when personal data is exchanged between companies of the TIMETOACT GROUP.

Employees can find out which specific standards and requirements the applicable law sets for the use of personal data in their area of responsibility from the respective data protection officer of the respective company.

The unauthorized use of the intellectual property rights of third parties is prohibited and will not be tolerated by the companies of the TIMETOACT GROUP. In particular, copyright laws prohibit the reproduction, performance, distribution, licensing, or display of copyrighted works without the prior permission of the copyright owner. The copyright holder's permission is also required for the creation of derivative works. Trademark laws protect names, logos, and other company identifiers.

Employees must ensure that there is an agreement with the rights holder when using their intellectual property. In the event of uncertainty, and in particular before the use of a name, logo, text, images or other identifier in business transactions or when using AI systems, they should therefore consult with the respective rights holder.

The Company is obliged to comply with the applicable anti-money laundering laws. Among other things, there is an obligation to identify the contractual partner, to choose permissible forms of payment and to determine how possible money laundering transactions can be detected.

Employees should immediately report any suspicion of money laundering to their responsible supervisor or a member of the Executive Board. They should pay particular attention to events that they notice because of an unusually high sum of cash. The same applies if they notice transaction structures to avoid reporting obligations or to circumvent proper accounting.

The companies of the TIMETOACT GROUP are committed to ensuring that all books, records, accounts and other documents (hereinafter referred to as "Documentation") that are relevant for accounting purposes meet the highest standards of accuracy and reliability. The companies maintain documentation that accurately identifies all transactions, thus enabling financial statements to be prepared in accordance with applicable law and the relevant general principles of proper accounting.

If the activity of the respective employee includes the documentation of the company's financial transactions, then he or she must ensure that these principles of conduct are observed. In this context, the deliberate misrepresentation or omission of material facts constitute infringements of the law. The same applies to the intentional inducement of others to misrepresent or omit material facts.

Insofar as accounting obligations are part of an employee's area of responsibility, he or she is expected to be aware of all financial and accounting principles in their current version and to be attentive with regard to violations of them. In this case, the employee is responsible for ensuring that all cash, bank accounts and other assets are recorded in the official books accurately and in a timely manner; it is strictly prohibited to obtain or create false invoices or other misleading documents and to make payments to unknown bank or numbered accounts. The constant possibility of inspecting all documents must be guaranteed. In the case of a cash payment, a signed receipt or comparable receipt must be presented. The employees concerned must always cooperate with the auditors of the respective companies.

The reputation of the companies of the TIMETOACT GROUP depends to a large extent on their external presentation and impact, and in particular on how they deal with the media. For the public image of the companies, it is therefore indispensable to present a uniform appearance to the outside world and to provide truthful information.

All inquiries from the media must therefore first be passed on to the respective management. Employees are not permitted to make written or oral statements to media representatives on behalf of or about a group company without the prior consent of the respective company.

Publications, lectures and interviews that are related to the TIMETOACT GROUP as a whole or to a single or several companies should also be discussed with the respective management of the employee in order to maintain a uniform image in the public.

Internet, intranet and e-mail communication are essential tools in the context of daily work.

Inappropriate use of the Internet, intranet, e-mail or computer systems is not permitted. Inappropriate uses include, but are not limited to, unauthorized access to another user's email account, unauthorized transmission of secret or confidential information, sending offensive materials or messages, transmission of materials that infringe the copyrights of third parties, and other unlawful or unethical activities. Every employee ensures that he or she complies with all internal regulations on the use of information and communication technology.

The activities of the companies of the TIMETOACT GROUP depend to a considerable extent on the functionality of the IT systems. This is because the handling of business processes is no longer conceivable without these technical facilities. Employees are required to follow all relevant safety guidelines.

The companies of the TIMETOACT GROUP provide all the equipment and resources required for the efficient performance of tasks and rely on their employees to use the resources provided responsibly and, in particular, not wastefully.

The companies of the TIMETOACT GROUP provide all the equipment and equipment needed for the efficient performance of the tasks and rely on the employees to handle the resources provided responsibly and, in particular, not wastefully.

In order for the companies of the TIMETOACT GROUP to be able to comply with their legal and regulatory obligations to retain data, employees are obliged to properly and carefully store documents and records in their area of responsibility. They are also responsible for the completeness of the documentation and must have knowledge of data storage and retrieval in relation to the documents and records for which they are responsible.

Employees are also requested to find out for their area of responsibility which documents and documents must be retained in what form (e.g. as originals or in electronic form) and for how long. The destruction or modification of documents and records that are subject to retention before the expiry of the retention period can significantly complicate or hinder investigations, (tax) audits and the successful conduct of legal proceedings and thus cause considerable damage to the companies of the TIMETOACT GROUP.

The companies of the TIMETOACT GROUP entrust their employees with a large amount of information on a daily basis in the performance of their activities and tasks. The same confidentiality obligation applies to information that has been communicated to the respective company of the TIMETOACT GROUP by business partners under a confidentiality obligation.

In order to protect the Confidential Information, employees are obliged to observe the following:

• Confidential information may not be disclosed to any other person inside or outside the Company (including colleagues or family members) during or after the termination of the employment relationship with the relevant Company, except as necessary to perform the work for the Company.
• Confidential information must not be discussed (in person or by telephone) in public places (entrances, corridors, public transport, public places, toilets, etc.) where a conversation can be overheard.
• Documents containing confidential information must be stored in such a way that they cannot be inspected by unauthorized persons.
• In particular, it is important to ensure that visitors do not have access to documents of the companies of the TIMETOACT GROUP. Visitors are therefore generally not allowed to stay unaccompanied in the business and office premises of the companies of the TIMETOACT GROUP.
• Confidential information must be sent by appropriate means of communication that guarantee the confidentiality of this information.

The companies of the TIMETOACT GROUP claim to ensure transparency in their dealings with customers, business partners and authorities. International standards for combating corruption as well as national and local regulations for combating corruption and bribery are to be complied with.

Personal or one's own financial interests must not influence business decisions. Therefore, all situations in which personal or one's own financial interests come into conflict with the interests of the companies of the TIMETOACT GROUP or third parties must be avoided. If such conflicts of interest exist, the further procedure must be coordinated with the direct supervisor.

Employees may not suggest, solicit or demand benefits of any kind (such as gifts, other benefits or invitations, personal services or favors) for themselves or for other persons or organizations in return for the performance of official acts.

Advantages of any kind are to be rejected if the employee is aware that he or she is violating laws and/or guidelines or instructions of the company where the donor is employed by accepting the benefit and/or that the donor is violating by granting the benefit. In addition, benefits of any kind should be rejected if they can influence the employee's decision due to their intrinsic value or even if they can only give the impression of influence. In case of doubt, the benefit granted must be returned. If this seems rude, the further procedure must be coordinated with the direct superior. If it is not possible to return the benefit granted, the company of the TIMETOACT GROUP will initiate the realisation for the benefit of a non-profit organisation.

Exceptionally, invitations to events or business dinners may be accepted by employees, provided that they are issued voluntarily, are made for the purpose of a business exchange on professional topics, do not take place unreasonably often and the value of the invitation does not exceed the scope of what is customary and appropriate in relation to the occasion. The assessment of the question of appropriateness is determined according to normal business practice, whereby a value of approx. EUR 100.00 is used as a guide.

The assumption of travel and accommodation costs by third parties is not permitted, unless it is an event in which the company of the TIMETOACT GROUP actively participates (e.g. as a speaker) or this is expressly approved by the respective supervisor before the start of the trip.

A voluntarily granted promotional and occasional gift may be accepted as long as its value is within the scope of what is reasonable. The assessment of the question of appropriateness is determined according to normal business practice, whereby a value of approx. EUR 100.00 is used as a guide.

The receipt of invitations to events or business dinners as well as promotional and occasional gifts must be disclosed and documented if the specified orientation value limits are exceeded.

If employees purchase goods or services from business partners for private purposes, the market price must be paid. If customary market discounts are granted, they may be used.

Gifts and benefits to business partners may also only be granted in an appropriate amount and within the scope of normal business activities. It is prohibited to promise or grant payments, benefits or monetary benefits to third parties in order to obtain orders or benefits for the companies of the TIMETOACT GROUP or other persons. Any appearance of such influence must be avoided.

The companies of the TIMETOACT GROUP want to cooperate with the state authorities in a spirit of trust on the basis of the applicable law. Therefore, all lawful orders of state authorities must be followed, while at the same time exercising the legal rights of the company.

In the ordinary course of business or as part of a formal official investigation, representatives of public authorities or public officials may make specific inquiries to the companies of the TIMETOACT GROUP. If an employee is confronted with official inquiries or investigative actions, he or she is obliged, unless there are compelling reasons to the contrary, to always and immediately involve the management of the company of which he or she is an employee and to behave cooperatively.

Our corporate values are based on safety, performance and professionalism. Therefore, the consumption and possession of illegal drugs, as well as the consumption of alcohol and other intoxicating substances during working hours, is prohibited. This also includes situations in which there is an impairment due to previous consumption.

An exception applies to the medically prescribed use of intoxicating substances, provided that this takes place within the framework of the applicable local legislation. If a medically prescribed medication results in work-related restrictions or the need for adjustment, affected employees can voluntarily and confidentially contact the HR department or the responsible manager to find a solution that takes into account both the legal requirements and the operational requirements.

Moderate consumption of alcohol in a spatial or temporal context with the work performance of employees is prohibited in exceptional cases, such as e.g. an evening business lunch.

Engagement and support for political parties on behalf of one of the companies of the TIMETOACT GROUP, as well as donations or other contributions in the form of cash or in-kind assets on behalf of the TIMETOACT GROUP, require their approval. The same applies to any organization of political events on the premises or in the business premises of a company of the TIMETOACT GROUP.

Employees are of course free to engage in political activities in their private lives, provided that they do not act as employees or representatives of a company of the TIMETOACT GROUP. If the interests of a company of the TIMETOACT GROUP are affected by a political commitment, their prior consent must be obtained.