CODE OF CONDUCTVerhaltenskodex
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01 Aim of the Code of Conduct
With this Code of Conduct, the management and employees
pursue the aim of ethically impeccable business activity at E-T-A
Elektrotechnische Apparate GmbH. All employees of thecompany group worldwide are committed to this code, which
determines the standards, applicable directives and expectationsof our behaviour. The management board assumes a special rolemodel function in this respect.

02 General principles
Honourablebusinessman

We always act fairly and decently in relationship with ourcustomers, partners, employees and shareholders. We arecommitted to conducting our business ethically and legally
impeccable, by complying with applicable laws, directives andstandards. We avoid conflicts of interest and respect the customs,
traditions and social values of the countries and cultures in which
we operate.

Protection of lives andassets

E-T-A’s mission is to protect lives and assets. We see this as thepurpose of our products and services. This is also the reason why
we do not want to supply products or solutions for militarycustomer applications, that are intended for combat operations.

No military businessAcceptance of furtherprinciples

We bindingly accept the directives of the BME Code of Conduct
and thus the ten principles of the United Nations Global Compact.
We expect and encourage our business partners to implement
ethical principles themselves on this basis, and to follow theprinciples of the E-T-A Code of Conduct in co-operation with us.

03 Social responsibility
With our mission we pursue a healthy balance between theinterests of customers, employees and shareholders, toguarantee a sustainable corporate development - botheconomically and ecologically. Achieving this balance has been
an essential part of our value-oriented family business fordecades.

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Human rights
Child labour / Forcedlabour

We respect human rights and positively contribute to theirprotection and promotion with our behaviour.
We actively ostracise child and forced labour in any form.

Equal opportunity

People of different origins and different nationalities work at E-TA. They are of different genders and have different sexual
identities, different religions and different world views. They areyoung, elderly, disabled or not disabled. We benefit from thisdiversity in our daily work, because together we find better
solutions. Regardless of all individual differences, each of us isentitled to fair and equal treatment and protection fromdiscrimination and harassment.

Fair cooperation

The basis for successful cooperation is a corporate culture
characterised by fairness, mutual respect and trust in our social
interactions - today and in the future. Every employee should
contribute to this and create an atmosphere of partnership in
which discrimination has no chance. This requires a high degreeof open-mindedness and tolerance in social interaction.

Work safety andhealth protection

The safety of our employees and customers is our utmost priority
and one of E-T-A’s central values. Together we create a safe
working environment and ensure the safety of our products. We
avoid hazards with consistent, preventive industrial safety. We
realise this by predictive, thoughtful and safety-consciousbehaviour. Maintaining the work capacity and health of ouremployees is very important for us, as we guarantee ourcompany success by maintaining the know-how and capacity of
our employees.

Know-How

Environmental
protection

E-T-A is fully committed to the protection and preservation of anenvironment worth living in. Therefore, we will continuously strive
to shape the entire life cycle of our products as ecologicallycompatible as possible. This also applies to our efforts to reduceenergy and resource consumption with all its effects and thus
minimise the inevitable environmental pollution.

Climate protection

We take climate protection very seriously as a generational
project and make our contribution as a company and community.
For this reason, we set ourselves ambitious goals every year,
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becoming a climate-neutral company. We also sensitise andmotivate our employees and business partners for climateprotection.

04 Behaviour of our personnel
Appearance

Our employees have influence on E-T-A’s public appearance. We
take care to always interact with our customers and business
partners in a friendly, accommodating way at eye level.

Confidentiality

All information on E-T-A’s business activities, which is not public
or general knowledge, is treated confidential. This also includes
information from business partners and other parties, that E-T-A
receives based on our joint business activities.

Avoiding
conflicts of interest

We avoid situations in which personal or financial interests collidewith the interests of E-T-A or those of our business partners. We
take care not to interfere with E-T-A’s interests and at the sametime aim to guarantee the reconciliation of family and career.
Secondary activities and shareholding of competitors or business
partners must not put anyone at risk of a conflict of interest.

Invitations andgifts

In our business actions we do not offer, promise, request or grant
gifts, payments, invitations or services with the intention ofinfluencing a business relationship in an unacceptable way orjeopardising the professional independence of the business
partners. In general, this does not apply to gifts and invitations
which are customary in the context of hospitality, custom andcourtesy. This includes reasonable, low-value and symbolic gifts,
business lunches and events of our own company or of business
partners or holiday and other gifts.

towards business partners,
05 Behaviour
competitors and officials
E-T-A responds to the needs of customers, suppliers andbusiness partners and treats them responsibly, honestly and fair.

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ENG INEERING TECHNOLOG YCorruption

E-T-A does not tolerate corruption or other unfair commercial
practices of employees or third parties appointed by us. We
completely reject incentives, privileges, benefits or otheradvantages that influence business decisions in an unacceptableway. We select consultants, agents and mediators carefully
according to their suitability, professional qualification andintegrity and remunerate them in an appropriate way for theservices performed.

Behaviour towardsofficials

As a matter of principal, material and immaterial donations of any
kind to public officials, employees or agents of state institutions or
their relatives are prohibited. Donations of any kind to politicalparties, their representatives, politicians, elected officials andcandidates for political office are prohibited as well.

Politics and parties

Competition andantitrust law

We comply with the relevant competitive and antitrust law
regulations and do not enter into any agreements that affectprices and conditions or otherwise unduly restrict fair competition.

Donations/Sponsoring

Donations and sponsoring activities must always be transparent
and documented. They are done exclusively on a voluntary basis
and without any expectation of consideration or covert promotionof interests. Donations are decided by a circle of employees fromthroughout the company. E-T-A uses sponsoring within the areas
determined by the sponsoring circle.

06 Responsibility towards the management board
E-T-A’s actions are characterised by responsibility andtransparency towards our shareholders. In that sense, theprotection of company assets and the sustainable increase of thecompany’s value are goals of our entrepreneurial work. This is aprerequisite for the existence of our company group and for longterm job security.
Protection ofthe company’sassets

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Company property and all work equipment provided for
operational purposes by the company must be treated with careand may generally only be used for business purposes - unlessotherwise contractually agreed. Company property may not be

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sold or loaned or used for non-business purposes without explicit
permission, regardless of its condition or value.
In the scope of their work, all employees are obliged to protect ET-A’s property assets and handle it in an honest, correct andinteger way. We do not tolerate fraud, corruption or other criminalactions. Suspected cases of misconduct are investigated to thelegally possible extent and in compliance with data protection
regulations. In case of confirmed misconduct we take appropriateactions.
ReportingCompany reports and records must be created correctly andhonestly in every respect, correspond to applicable standards andinclude all relevant information.

Insider trading

Employees are prohibited from using non-public information fromother companies, that was disclosed to them in the course of theirwork for E-T-A, to obtain financial or business advantages forthemselves or third parties.

Money laundering

E-T-A takes all necessary measures to prevent money launderingin all areas within its control.

Privacy

We only survey, process and use personal data within the limitsof the relevant laws and company policies. We expect ouremployees to handle personal data of our business partners andemployees responsibly.

07 Adherence to the Code of Conduct
Obligation toadhere to the Code ofConduct

All members of the management board, supervisors andemployees at E-T-A are obliged to adhere to the Code of Conduct
and all regulations prevailing at E-T-A. The management board
assumes special responsibility in the communication andimplementation of these guidelines.

Whistleblowing

All E-T-A employees are obliged to report serious violations of thelaw and other acts that are likely to cause significant harm to E-TA, through the existing whistleblower system or to their

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ENG INEERING TECHNOLOG Ysupervisor. We protect employees, who report such violations,against negative consequences.
Consequences

Employees, who violate the law or internal regulations, must
expect adequate consequences, up to severe labour law anddisciplinary measures. Such violations can also result in criminal
and liability consequences.

08 Source of information
More detailed
information

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For further information please visit www.e-t-a.com. If you haveany uncertainties or questions, please contact your responsible
manager. In addition, you always have the option of directly
contacting the personnel department, the workers’ council ormanagement board.

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