Code of Conduct

Customer oriented. Family based. Innovative. Success oriented. These are the values upon which the Lapp Group is built. Our clear values have made us strong as a company, and as a family business, we know that it is only through our joint efforts – through teamwork within our company and with our business partners – that we will be successful. And the basis for this is our values. If we align our behaviour with these values every day, if we treat each other and our business partners fairly and with respect, we will perpetuate the Lapp Group's success story as a leading manufacturer of system solutions for cabling and connection technology. In this Code of Conduct, we try to describe more precisely what our values mean for our day-to-day work. We hope that this will be of help to you.

Board of Lapp Holding AG

Preamble
Absolute compliance with all legal requirements takes top priority for our company, and is also an integral part of our core values. Implementation and compliance is regulated in numerous internal guidelines and directives. The key elements are summarised in this Code of Conduct, in order to make it easier for employees to comply with the requirements. The rules contained within this Code of Conduct apply to the relationship between the respective Lapp Group company and its employees and serve as a mission statement for cooperation with our suppliers and business partners. No rights in favour of third parties are created by this Code.

1. Principles

Lawful conduct
We advocate the principle of legality in all acts, measures, contracts, and other transactions of the Lapp Group. We endorse the principle of acting solely within the confines of the law, regardless of whether or not the Lapp Group derives any benefit from this. All of our employees are personally responsible for adhering to the law within their own field of work. It is forbidden to induce third parties to act unlawfully or knowingly to contribute to any such unlawful acts.

Managers are responsible for ensuring that no breaches of the law and of this Code of Conduct occur in their areas of responsibility, which could have been prevented or hampered through appropriate supervision. They must make it clear that breaches of the law are frowned upon and will result in disciplinary action, regardless of the employee's position within the company's hierarchy. Managers throughout the world have an obligation to take appropriate action to ensure that employees have the up-to-date knowledge of legal regulations required in order to be able to act responsibly.

Responsibility for the reputation of the Lapp Group
All employees must pay due regard to the reputation of the Lapp Group when performing their duties.

2. Human Rights
The Lapp Group acknowledges its social responsibility as a globally operating business. On the basis of a value-oriented corporate management and in consideration of internationally recognised human rights, the basic principles of the International Labour Organisation (ILO) and the applicable laws in the various countries and locations, as well as in recognition of the various cultures, the following principles apply:

a. Conduct towards employees
We respect and protect the personal dignity of each individual. Discrimination and harassment will not be tolerated at any Lapp Group location. In particular, discrimination on grounds of ethnic or cultural characteristics, disability, gender, religious beliefs, age, or sexual orientation will not be tolerated. All of our employees have the right to be treated fairly, politely and with respect.

b. Child labour and forced labour
Child labour and forced labour will not be tolerated and will be opposed without exception, even in the case of our business partners.

c. Safety at work, fire precautions, health and environmental protection
It is the duty of all employees to avoid hazards to people and to the environment, to minimise the impact on the environment and to use resources sparingly. Processes, sites and operating materials must comply with the applicable legal and internal requirements regarding safety at work, fire precautions, and health and environmental protection. Health, safety at work, and decent working conditions are an important element of company policy. Substances that are harmful to health and the use of raw materials from conflict areas (conflict minerals) should be avoided.

d. Training and qualifications
In the Lapp Group, employees are always selected, hired and promoted on the basis of their function-specific qualifications, their skills and their personality. The company supports the purposeful, continuous and needs-oriented training of its employees, in order to facilitate high performance levels and high-quality work. Employees are regularly informed of current topics in connection with this Code of Conduct.

3. Avoiding Conflicts of Interest
Secondary employment is only permissible with the prior written consent of the company. Consent will be granted if there is no risk of any negative impact on work performance. Employees will only be permitted to invest in or carry out side-line activities for competing firms, suppliers or customers if they have prior written approval from the respective local subsidiary or regional holding company. Decisions will be taken on a case-by-case basis.

Transactions with companies, in which an employee, his/her spouse or partner, or close family member holds an interest or serves in a senior position, and where the employee is in a position to influence the business relationship and a conflict of interest could occur, may only be entered into with the prior written consent of the respective local subsidiary or regional holding company.

Engaging business partners for private purposes
Employees may only engage a business partner of the Lapp Group for private purposes with the prior written consent of the respective local subsidiary or regional holding company if their work entails direct involvement in the awarding or settlement of orders, and there is consequently a potential for a conflict of interest. This provision does not apply to goods and services that are generally available.

4. Dealing with Information

Reporting
All of our records, reports and statements must be accurate and truthful. The generally accepted accounting principles should be adhered to; in accordance with these, data and other records must be complete, correct, timely, and organised. The creation of records, files and the like, for which confidential information belonging to the company is used, is permitted only if this directly serves the interests of the Lapp Group and all data protection standards are complied with.

Confidentiality
Confidential information belonging to the company must be kept secret. This obligation will continue to apply even after the termination of the employment relationship.

Data protection and information security
When developing and processing all (IT-supported) business processes, the right to privacy and to a private life must be protected and information security guaranteed, on the basis of and in compliance with the applicable statutory requirements regarding data protection and IT and data security.

If, in connection with business processes, personal data (pertaining to customers, suppliers, employees or other affected persons) is collected, processed and/or transmitted, the following data protection principles in particular must be observed within the EU (European Union) and the EEA (European Economic Area):

• Prohibition subject to authorisation: Personal data may not be collected, processed or transmitted unless this is permitted by an express, statutory regulation or an explicit, voluntary and informed declaration of consent by the party concerned.
  
  
• Specified purpose and necessity: Personal data may only ever be processed for the purpose, for which it was collected, and any collection, processing or transmission of data must be limited to the data which is necessary for this predetermined purpose.
  
  
• Data reduction and data economy: As little personal data as possible should be collected and processed. Personal data should be deleted, with due regard to any statutory obligations to preserve records, as soon the purpose for processing it no longer exists. Personal data should, to the extent possible and appropriate, be processed in pseudonymised – or ideally anonymised – form.
  
  
• Transparency: Data should always be collected directly from the party concerned, who should be informed when the data is collected of the purpose of this collection, the identity of the collecting/responsible body (data controller) and whether this data will be passed on to any third parties. The concerned party furthermore has a right to information regarding the data collected/stored, and a right to correct or delete said data, in accordance with the statutory provisions (in Germany: the Federal Data Protection Act – Bundesdatenschutzgesetz [BDSG]).
  
  
• Data must only be collected, processed and/or transmitted by a Lapp Group company, particularly outside the EU or the EEA, to the extent that this is permitted under the applicable domestic data protection legislation. Compliance with domestic data protection regulations will be monitored by the data protection officer or the management of the respective Lapp Group company.
  
  
• Data and IT-system security (information security) must be ensured for all business processes by means of suitable and appropriate technical and organisational measures (particularly admission, entry and access controls, encryption, logging, firewalls and back-ups).

5. Conduct Toward Business Partners and Third Parties
All employees have a duty to observe the rules of fair competition as defined by applicable law. In particular, it is not permitted to demarcate sales areas or divide up customers with a competitor, nor may there be any agreements or exchanges of information with competitors concerning prices/price components, supply relations and the conditions governing them, production capacities, or bidding approaches. The same applies to the exchange of information concerning market strategies and investment strategies. This prohibition applies not only to written agreements, but also to oral agreements or tacit collusion (conscious parallel behaviour).

Agreements with customers and suppliers are not permitted if such agreements are intended to restrict the freedom of customers to autonomously determine their prices and other conditions when re-selling.

a. Relationships with suppliers and customers
Agreements with customers and suppliers must be concluded solely in the interests of the company. All employees must comply with the company's internal control regulations (e.g. dual control). Suppliers must be selected solely on competitive merit, based on a comparison of the price, quality, performance and suitability of the products or services offered.

b. Bribery, corruption and other inducements
Agreements or side agreements referring to the acceptance of an advantage or the preferential treatment of individual persons in connection with the brokering, award, delivery, settlement, or payment of orders are prohibited.

Any attempts by suppliers or customers to exert an unfair influence on the decisions of Lapp employees must be reported to the managers responsible.

Any commission or remuneration paid to authorized dealers, representatives, or advisers must be reasonable and proportionate to the work carried out by those persons. The payment of benefits is prohibited if it can be assumed that such benefits are intended, in whole or in part, as payments of bribes.

Extreme caution must be exercised when accepting and offering gifts and other benefits (for example attending events without any direct business relevance), including invitations (from and to suppliers or customers). The financial scope of these gifts or benefits must be assessed on the basis that it should not be necessary for the recipient to conceal their acceptance, and they should not make the recipient feel indebted. In case of doubt, written consent should be obtained from the manager responsible.

c. Donations
Lapp Group companies make monetary donations and donations in kind in the fields of education, science, culture and social concerns. The awarding of such donations is decided upon solely by the managing directors and the Board of Lapp Holding AG. Such donations must be awarded on the basis of selfless and altruistic motivations.

6. Product Quality and Safety
"Success through quality" is one of the guiding principles of our business policy. We aim to satisfy the high quality and safety requirements of our customers, and the improvements we make to ensure this are thorough and designed to last. If defects arise despite our best efforts, we take action to eliminate them in compliance with statutory provisions and contractual obligations, and with the clear priority of preventing injury or loss of life.

7. Reporting Irregularities
This Code of Conduct is a central component of the Lapp values that we work by. It is vital that these values are observed uniformly throughout the Group – each employee is responsible for ensuring this.

Managers have the special responsibility of communicating the content of this Code of Conduct to employees by setting an example. All employees have the right to draw their managers' attention to circumstances appearing to indicate a breach of this Code of Conduct. This can also be done anonymously. Reports will be investigated and corrective measures taken where necessary.

If you are in any doubt as to how you should behave in a given situation or if you would like to report a breach of this Code of Conduct, please feel free to call the following dedicated number: +49 711 7838 8888, or email us at compliance(at)lappgroup.com

8. Monitoring
Each company is responsible for ensuring that the rules contained within this Code of Conduct as well as any other internal regulations within its area of responsibility are complied with. The Internal Audit department has an unrestricted right to obtain information and carry out audits, unless statutory regulations oppose this. When carrying out audits, the Internal Audit department pays attention to compliance with the Code of Conduct and includes its regulations in its test criteria.

Download the Code Of Conduct Flyer here