Code of conduct

Preamble

At VEACT, we attach the utmost importance to integrity, responsibility and sustainable practices in all our business relationships. Our aim is to uphold the highest standards – in terms of quality, ethics, safety and environmental protection – together with our suppliers, service providers, subcontractors and business partners. This Code of Conduct forms the foundation for a trusting and collaborative partnership. It sets out the principles we collectively adhere to in order to ensure fair, transparent and legally sound business practices. We ask our partners not only to embed these values in their own processes, but also to implement them throughout their entire supply chains. Furthermore, we expect all relevant national and international laws and regulations to be complied with – particularly in the areas of labour, human rights, the environment, data protection and competition. Where several regulations apply simultaneously, we adhere to the stricter provision in order to ensure the highest standards. Should challenges or potential breaches arise, it is our shared aim to identify them at an early stage, communicate them openly and resolve them constructively. In this way, we lay the foundations for sustainable, trusting and successful partnerships – today and in the future.

1. General Provisions, Scope and Obligations

This Code of Conduct applies to all suppliers, service providers, subcontractors and business partners of VEACT. We expect our partners to comply with the requirements set out herein and to ensure that their supply chains also meet these standards. Appropriate organisational measures should be demonstrably implemented and, where necessary, supporting evidence provided. Actual or suspected breaches must be reported to VEACT without delay.

2. Integrity, Prevention of Corruption and Conflicts of Interest

Integrity is the foundation of our business conduct. We expect our business partners to behave lawfully, responsibly and in an ethically impeccable manner at all times. Bribery, corruption and any form of improper granting of advantages or exerting undue influence will not be tolerated. Gifts, invitations or other benefits may only be offered within reasonable and legally permissible limits. Business decisions must be made objectively and free from irrelevant considerations. Potential or actual conflicts of interest must be disclosed transparently.Integrität ist die Grundlage unseres unternehmerischen Handelns. Wir erwarten von unseren Geschäftspartnern ein jederzeit rechtmäßiges, verantwortungsbewusstes und ethisch einwandfreies Verhalten. Bestechung, Korruption sowie jede Form unzulässiger Vorteilsgewährung oder Einflussnahme werden nicht toleriert. Geschenke, Einladungen oder sonstige Zuwendungen dürfen ausschließlich im angemessenen und gesetzlich zulässigen Rahmen erfolgen. Geschäftliche Entscheidungen sind objektiv und frei von sachfremden Erwägungen zu treffen. Potenzielle oder tatsächliche Interessenkonflikte sind transparent offenzulegen.

3. Prevention of Money Laundering

We expect our partners to consistently comply with all relevant laws and regulations aimed at preventing money laundering and the financing of terrorism. They must ensure that financial transactions are lawful, transparent and traceable.

Business relationships and payment flows must be structured in such a way that they cannot under any circumstances be misused to conceal illegal income or transactions. Any involvement in money laundering or similar unlawful practices is strictly prohibited.

Fair Competition and Competition Law

VEACT is committed to fair competition. We expect our partners to respect the principle of an open and fair market and to conduct all business in accordance with antitrust and competition law. Collusion regarding prices, market sharing or confidential business information is strictly prohibited. Transparency and honest reporting of business activities are a matter of course for VEACT.

Export Controls and Sanctions

Our partners comply with all applicable national and international regulations on export controls, sanctions and embargoes. They ensure that no business is conducted with sanctioned individuals, organisations or countries and that all necessary export licences are obtained. The lawful transfer of goods, technologies or services is carried out strictly in accordance with the applicable export control regulations. Where products or services are subject to export restrictions, our partners take appropriate measures to ensure compliance with these requirements throughout their supply chain. Breaches of export control or sanctions regulations will not be tolerated.

6. Human Rights and Fair Working Conditions

Our partners respect internationally recognised human rights and treat all employees with dignity and respect. Forced labour, child labour and modern slavery are strictly prohibited; employment must be entered into voluntarily. Working conditions, working hours and remuneration comply with applicable legal standards. Discrimination, harassment or unfair treatment will not be tolerated. Furthermore, our partners ensure a safe and healthy working environment. Risks must be systematically identified and appropriate measures implemented to prevent accidents at work and adverse effects on health.

7. Information Security and Data Protection

Customers, employees and shareholders rely on their data being protected. Our partners process personal data only for the agreed purposes and take technical and organisational measures to protect it. Breaches or security incidents must be reported to VEACT immediately. Further provisions can be found in the Data Processing Agreement at veact.com/avv.

8. Environmental and Sustainability Responsibility

Sustainable business practices are an integral part of our corporate philosophy. We expect our partners to comply with applicable environmental regulations and to conduct their business operations in a resource-efficient and environmentally conscious manner. Emissions, waste and harmful substances must be reduced as far as possible. We strive for continuous improvement in our environmental performance.

9. Quality, Product Conformity and Continuous Improvement

Our partners shall ensure that products and services meet the agreed requirements and quality standards. Any deviations or defects must be disclosed immediately so that suitable solutions can be developed jointly. We expect a systematic quality and improvement management system, including clearly defined performance targets and appropriate corrective actions. To ensure stable business processes, appropriate business continuity measures shall be implemented to maintain critical operations and minimise potential disruptions. VEACT reserves the right to verify compliance with these requirements to an appropriate extent. Our partners shall support such audits in a cooperative and transparent manner.

10. Intellectual Property and Confidentiality

Our partners handle VEACT’s tangible and intellectual property responsibly. Company property may only be used for business purposes, unless an explicit provision permits private use. Protective measures are implemented, and any misuse or misappropriation is reported immediately. When using third-party rights, a valid agreement with the rights holder must always be ensured.

11. Whistleblower Protection

VEACT expects partners to provide easily accessible and confidential reporting channels through which employees or third parties can report possible misconduct or breaches of this Code of Conduct. Furthermore, VEACT expects the identity of whistleblowers to be treated confidentially and whistleblowers to be protected from any form of retaliation. Serious breaches or substantiated cases of suspected misconduct along the supply chain must be reported to VEACT without delay. Any form of retaliation against persons who report concerns in good faith will not be tolerated.

12. Final Provisions

This Code forms an integral part of the working relationship with VEACT. Upon commencement of the business relationship, the partner accepts the obligations set out in this Code as binding.