Code of Conduct of the TIMETOACT GROUP

Contents of the Code of Conduct:

Purpose
Scope of application
Guidelines
Implementation of the Code of Conduct
Training and awareness raising
Monitoring and continuous improvement
Responsiblities
Implementation and compliance
Change management

1. Purpose

The companies of the TIMETOACT GROUP aspire to be modern and sustainable companies that provide excellent services and are committed to the fundamental values of society. The TIMETOACT GROUP has a responsibility to create and maintain a corporate culture in which the relevant legal provisions and regulations as well as ethical principles are best maintained.

Due to the large number of laws and official requirements, it is hardly possible to offer a ready-made solution for every conceivable situation. However, in order to ensure that they act in accordance with the law and ethical values as far as possible, the companies of the TIMETOACT GROUP have formulated this Code of Conduct. It defines the general standards for conduct in business, legal and ethical terms and is decisive for dealing with colleagues, customers and business partners. We are also committed to using artificial intelligence (AI) ethically, transparently and comprehensibly.

The companies of the TIMETOACT GROUP would like to thank their employees for their cooperation in complying with this Code of Conduct. This is the only way we can meet our own high standards in our dealings with each other and with customers and business partners. In this way, each individual employee contributes to ensuring the basis for a successful future for the Group companies.

2. Scope of application

The Code of Conduct is aimed at all employees of the companies of the TIMETOACT GROUP, including the management. Each individual is expected to consistently adhere to this Code of Conduct.

This Code of Conduct must be complied with even if the applicable laws or regulations are less far-reaching. At the same time, it cannot be ruled out that stricter laws and regulations may apply than those laid down in this Code of Conduct. In this case, these stricter laws and regulations take precedence.

3. Guidelines

TIMETOACT GROUP is committed to the principles of the United Nations Universal Declaration of Human Rights and expects suppliers and business partners to share these values and commit to upholding them.

The rights to freedom of association and collective bargaining in accordance with applicable laws and regulations are granted without exceptions. Inhumane practices such as forced labour, child labour, all forms of modern slavery and human trafficking as well as any form of exploitation are prohibited at the TIMETOACT GROUP and strict compliance with the relevant laws is ensured.

3.1 Human rights

3.2. Subject-specific regulations

3.2.1. Fair competition

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.

3.2.2. Insider trading

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.

3.2.3. Privacy

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.

3.2.4. Protection of third-party intellectual property (e.g. copyright, trademark, design and patent rights)

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.

3.2.5. Compliance with anti-money laundering laws

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.

3.2.6. Accounting and documentation

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.

3.2.7. Dealing with the media

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.

3.3 Conduct in the workplace and business environment

3.3.1. Discrimination- and harassment-free workplace

All employees, customers and business partners have the right to fair, respectful, dignified, courteous and indiscriminate treatment. We are committed to this principle and want to guarantee this right in our companies.

The companies of the TIMETOACT GROUP observe the principles of equal opportunities in the workplace. Personnel decisions (e.g., recruitment, selection, training, promotion, and compensation) are based on qualifications, experience, and other work-related criteria. The companies of the TIMETOACT GROUP do not discriminate on the basis of gender, ethnic origin, religion or belief, disability, age or sexual orientation.

It is the responsibility of the companies of the TIMETOACT GROUP to uphold the right of employees to a working environment free of sexual harassment or other undue discrimination. Any form of sexual harassment or other inadmissible discrimination on the basis of gender or ethnic origin, religion or belief, disability, age or sexual orientation will not be tolerated and must be avoided.

Sexual harassment is unwanted, sexually determined behaviour, which also includes unwanted sexual acts and requests for them, sexually determined physical touching, remarks of a sexual content as well as unwanted showing and visible display of pornographic images that have the purpose or effect of violating the dignity of the person concerned, in particular if a person is intimidated, hostile, humiliated, degraded or insults. Sexual harassment is illegal. Examples of illicit sexual harassment include:

Solicitation of sexual acts or an offer of sexual acts in exchange for benefits in the workplace;
cornering, patting, pinching or touching or other unwanted physical contact with sexual content;
public conjectures about or repeated inquiries about a person's sex life;
jokes, remarks, or innuendos of a sexual nature about a person or men and women in general; or
visible display of pornographic images in the workplace.

Examples of other inadmissible discrimination that is prohibited because of the reference to gender, age, ethnic origin, religion or belief, disability or sexual orientation are:

violation of the dignity of an employee through insulting or degrading remarks or behaviour (e.g. because of foreign origin);
Threats or insinuations that a continued employment relationship depends on the toleration of a certain behavior;
to force an employee to perform degrading or degrading acts, such as harassment because of sexual orientation.

In the event that an employee has been sexually harassed or otherwise inadmissibly disadvantaged, he or she should report this to the company's management or the local HR department. For this purpose, the TIMETOACT GROUP also provides the possibility to submit corresponding reports via online form (see also the chapter "Whistleblowers" of this Code of Conduct).

The TIMETOACT GROUP assures all employees that complaints will be treated as confidentially as possible and that no employee will suffer disadvantages as a result of a report, provided that there is no abuse by the employee.

It is the responsibility of the companies of the TIMETOACT GROUP to take all reasonable precautions to prevent all kinds of sexual harassment and other unacceptable disadvantage and to take immediate action if they are informed of an unacceptable disadvantage.

The companies of the TIMETOACT GROUP reserve the right to take disciplinary action against employees who treat or harass other employees, customers or business partners in an impermissible manner. The disciplinary measures may also consist of the pronouncement of an ordinary or extraordinary dismissal.

3.3.2. Dealing with property and rights of the company

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.

3.3.3. IT-security

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.

3.3.4. Use of operating resources

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.

3.3.5. Use of resources

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.

3.3.5. Storage of documents and records

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.

3.3.7. Confidential information

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.

3.3.8. Gifts and benefits

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.

3.3.9. Dealing and cooperating with public authorities and clients

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.

3.3.10. Drugs, alcohol and cannabis

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.

3.4. Conflicts of interest

Conflicts of interest can raise doubts about the quality of business decisions made and the integrity of the people who make them. Conflicts of interest, or even the appearance of them, must be avoided at all times. If such conflict avoidance is not possible, it must be dealt with actively, openly and honestly. In the event of possible conflicts, employees are encouraged to actively approach their supervisor and coordinate the further course of action. In particular, the following conflicts of interest must be avoided:

3.4.1. Part-time work

The commencement of any secondary employment is subject to the provisions of the employment contract. If the employment contract does not contain any provisions on secondary employment, the employee is required to obtain the written consent of the HR department responsible for him. The Human Resources Department will approve a secondary activity if such activity does not conflict with the legitimate business interests of the companies of the TIMETOACT GROUP and can demonstrably have no influence on the activity for the companies of the TIMETOACT GROUP.

Employees of the companies of the TIMETOACT GROUP are not permitted to take on a managerial position (e.g. as managing director, member of the board of directors, supervisory board or advisory board) at another company without permission if this other company is either in competition with a company of the TIMETOACT GROUP or does business with a company of the TIMETOACT GROUP.

3.4.2. Political activities

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.

3.5. Dealing with artificial intelligence (AI)

We make decision-making processes and algorithms transparent to ensure that they are understandable and comprehensible. We respect the privacy of our users and customers. When using AI, we comply with applicable data protection laws. Control of critical processes remains in human hands, and human decision-makers have the ultimate responsibility. We do not blindly rely on AI, but act responsibly in the application of this tool. Accordingly, we check all content generated by artificial intelligence (AI) for accuracy. We ensure that our employees have the necessary knowledge and skills to use AI systems responsibly and efficiently. We communicate clearly and transparently with our employees, customers and the public about the use of AI. We actively involve external stakeholders in the dialogue to promote a comprehensive understanding and trust in AI. We continuously monitor and evaluate the performance of AI systems.

3.6. Environmental, social and corporate governance

We focus on environmentally friendly practices in order to conserve resources and minimise emissions. Through sustainable innovation and processes, we continuously strive to reduce our environmental impact.

We promote a respectful and inclusive work environment where diversity is valued and all employees are treated fairly. We also support social projects and respect human rights in all areas of our business.

Transparency and integrity characterize our actions, while upholding correct and honest business practices. Bribery, corruption and other unethical behaviour are zero tolerance in our country.

4. Implementation of the Code of Conduct

4.1. Questions and instructions

This Code of Conduct cannot provide detailed instructions for each individual situation. Additional regulations and guidelines of the companies of the TIMETOACT GROUP offer employees further assistance. The application and implementation of the standards set out in this Code of Conduct and in the other internal guidelines of conduct in day-to-day business may require clarification in some cases.

If employees are unsure about correct behavior, they are encouraged to contact their supervisor or the responsible management.

4.2. Reporting violations (“whistleblowing”)

If an employee becomes aware of conduct that violates the accounting, financial and banking rules contained in this Code of Conduct or other laws and regulations and/or constitutes a criminal offence (e.g. bribery, prohibited insider trading, environmental offences) ("Violation"), he or she should inform his or her supervisor or a member of the Executive Board or another appropriate person of the Company.

In the case of employees who are in the position of a director or board member (executive officer), chief financial officer (CFO), head of accounting (principal accounting officer) or a controller, or who hold a similar function, the term "violation" also refers to conduct that otherwise violates the provisions of this Code of Conduct.

An online form is also available for information, which employees can use to find more detailed information on the intranet. The issuance of information should be made with the disclosure of the identity of the person making the notification. Anonymous tips are generally not welcome, but will also be noted and investigated.

Employees should cooperate in any investigation of an alleged violation. If, as a result of the investigation, it becomes clear that there has been a corresponding violation, the person who committed it (and, if applicable, his or her superior) will be subject to labour law sanctions. The sanctions can consist in particular of a warning or the pronouncement of an ordinary or extraordinary termination.

The companies of the TIMETOACT GROUP shall ensure that the identity of a contributing employee is treated confidentially as far as it is known to the company and as far as this is legally permissible. Reported violations will initially be made available exclusively to our Legal Team and the Integration & Improvement Officer. This will examine the allegations and, if necessary, carry out further investigations. If a suspicion is substantiated, the legal team informs the management. In the further course of the investigation, it may become necessary to disclose the identity of a participating employee to persons involved in the further investigations, in particular to investigating authorities. The same applies to possible subsequent court proceedings. If a collaborator has concerns about such disclosure, they must report this when reporting the violation. A corresponding note is then added to the system.

The companies of the TIMETOACT GROUP ensure that no action is taken against an employee for reporting a violation or participating in an investigation, provided that there is no abuse by the employee.

The companies of the TIMETOACT GROUP will comply with the applicable data protection regulations, in particular the rights of the participating employee and the accused. Notices are only used for the purpose of investigating and possibly punishing violations.

The accused will be informed of any allegations against him as soon as this no longer jeopardizes the investigation. Data that is no longer needed will be deleted within two months of the conclusion of the investigation.

4.3. Part of the employment relationship

This Code of Conduct is an integral part of the employment relationship and is indispensable for the business operations of the companies of the TIMETOACT GROUP. Violations of binding provisions of this Code of Conduct cannot and will not be tolerated. Failure to read or acknowledge this Code of Conduct does not relieve employees of their responsibility for compliance with it.

Depending on the severity, violations of this Code of Conduct can lead to consequences under employment law up to and including extraordinary termination of the employment relationship. If a violation of this Code of Conduct is also a violation of applicable law, then there may also be a risk of claims for damages and/or criminal prosecution.

In light of the above, the companies of the TIMETOACT GROUP call on employees to act responsibly and to follow this Code of Conduct for their own benefit and for the benefit of all companies of the TIMETOACT GROUP.

5. Training and awareness raising

The respective companies ensure that all employees are informed about the policy. Training and awareness-raising activities are carried out to increase awareness of the issue and promote understanding of the importance of the issue.

6. Monitoring and continuous improvement

The policy is regularly reviewed and evaluated to ensure that it is effective and meets the requirements. The responsible business function identifies opportunities for improvement and implements appropriate measures to continuously improve the effectiveness of the policy.

7. Responsibilities

The responsibilities for this policy are as follows:

Employees are responsible for complying with this policy.
The responsible GROUP Function is responsible for verifying, updating and monitoring compliance with this policy and conducting training.
The leaders and managers of the respective companies are responsible for ensuring that all employees are aware of the policy and promote its compliance within their teams
The management is responsible for the content and implementation of the policy.

8. Implementation and compliance

All employees and relevant stakeholders are required to follow this policy. Management is tasked with ensuring that the policy is implemented, understood, and adhered to. Failure to comply may result in disciplinary action.

9. Change management

This policy will be reviewed regularly and updated as necessary. Changes are communicated and documented appropriately.