CODE OF CONDUCTof the WITTENSTEIN GroupCODE OF CONDUCTof the WITTENSTEIN Group3

Contents
Preface ........................................................................................................................

4

1. Basics ......................................................................................................................

7

2. Scope and purpose ..............................................................................................

9

3. We comply with the law ........................................................................................

11

4. We play fair .............................................................................................................

13

5. We do not tolerate corruption .............................................................................

15

6. We avoid conflicts of interest ...............................................................................

19

7. We do not tolerate discrimination .......................................................................

23

8. We do not tolerate child labour or forced labour .............................................

25

9. We guarantee the freedom of association ........................................................

27

10. We observe health and safety standards .......................................................

29

11. We pay our employees fairly .............................................................................

31

12. We conserve our environment ..........................................................................

33

13. We care about product safety ..........................................................................

35

14. We protect our development results ................................................................

37

15. We are careful with business documents and data protection .......................

41

16. We carefully consider risks and opportunities ...............................................

45

17. We comply with export, customs and tax laws .............................................

47

18. We behave in an exemplary manner ................................................................

51

19. We do not discriminate against whistle-blowers ............................................

53

20. Implementing the Code of Conduct .................................................................

55

Contacts ......................................................................................................................

56

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5

Anyone who is active in the business world isfrequently faced with the question of what actions
are permitted and what are not. This Code of
Conduct shows you how to deal with this situation.
WITTENSTEIN not only wants to comply withstatutory provisions but also sets itself high ethicalstandards.
Sustainable and socially responsible conduct inbusiness is the basis for all our transactions andprovides a universal foundation for good, long-termbusiness relations.
Igersheim-Harthausen – April 2018

Management Board
Dr. Anna-Katharina Wittenstein

Dr. Dirk Haft

Erik Roßmeißl

Dr. Bernd Schimpf

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1. Basics
Our Vision
WITTENSTEIN is committed to being a world class global partner for the customers of
its intelligent mechatronic drive technology, servo systems and components.

Our Values
Our relationship with our customers, suppliers and colleagues represents our corevalues. We therefore act in keeping with the following:
Responsibility – Trust – Openness – Innovation – Change

Responsibility for compliance with all statutory and in-house regulations
Compliance means that the conduct of all employees* of the WITTENSTEIN Group –whether in administration, production or at managerial and board level – correspondswith the applicable laws and with in-house regulations.
This is in line with the corporate principle of compliance:“The companies of the WITTENSTEIN Group of companies
and their employees comply with all the laws and other regulationsof the countries in which we do business.”
The integrity of all employees and the total commitment of managerial staff toresponsible management are crucial.

*For the sake of simplicity, only the masculine form is used.

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2. Scope and purpose
Worldwide application to all employees and business relationships
This Code of Conduct applies worldwide to every employee of the WITTENSTEIN Group –whether in production, administration or at managerial or board level. Employees
include both permanent and temporary staff.
Every individual is equally responsible for compliance with the principles of good
conduct.
We all stand for honest dealing and are committed to the following principles of conduct;
they are the only way to ensure that economic success is sustainable.

Consequences of Violation
WITTENSTEIN has a zero-tolerance policy on compliance. Any action that is detrimental
to the company will be traced, investigated and punished according to the severity of thebreach. Where a business partner consistently violates the rules laid down in this Codeof Conduct, the business relationship with the said business partner must be severed
following an appropriate warning.

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3. We comply with the law
Compliance with applicable valid laws
Sustainable business success at home and abroad is only possible where there is strict
compliance with the respective legal system. Sooner or later, violations of the law resultin higher costs and involve incalculable risks such as fines, penalties, claims in damages
and damage to reputation. Ultimately, violating the law threatens jobs.
We act in accordance with the provisions of the internationally recognised UN Global
Compact and it goes without saying that our actions are subject to the fundamental
principles of the International Labour Organisation (ILO).

Compliance by all employees and business partners
We require absolute compliance with the applicable valid laws by all managerial staff,
every employee – including temporary staff – and all our business partners.
In this regard, the managers and executives of our companies must lead by example.

What does this mean for me?

As an employee of WITTENSTEIN, I am obliged to comply with the applicable laws at all times.
This applies to every legal system under which I operate.
I am familiar with the Code of Conduct, apply its principles and rules of conduct on a daily
basis and take responsibility for complying with them.

13

4. We play fair
Free and fair competition in compliance with antitrust law
WITTENSTEIN is unreservedly committed to the principle of free and fair competition.

No anti-competitive agreements
We reject pricing agreements, agreements on market share, sharing of local markets,
sharing of customers, price fixing and such like.
Other violations of antitrust law such as concerted practices, informal discussions andinformal agreements are prohibited. Details of in-house calculations, capacity, development results or plans shall not be made accessible to competitors. Exceptions may
arise only in the case of business divestitures, acquisitions or projected joint ventures
where a non-disclosure agreement is mandatory prior to exchanging data.

What does this mean for me?

As an employee of WITTENSTEIN, I can certainly take part in an event where competitors are also present and discuss the current economic climate in an informal discussion. Where, during such a meeting, however, a competitor says that he is considering
increasing the prices by five percent next year and another competitor replies that this is
not feasible and he will not be raising prices next year, then I must communicate loud andclear that I will not take part in any discussion of market-sensitive information and leave
the group immediately. Even if I only listen passively to what is being said, I may be foundto have taken part in a cartel and be liable for heavy fines. I can also express my objection
again in writing if necessary.

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5. We do not tolerate corruption
We reject bribery and corruption
We do not offer our business partners inappropriate gifts or grant them any otheradvantage. WITTENSTEIN staff do not abuse their position in order to procure any
undue advantage of a personal or commercial nature for their business partners.
If at all, WITTENSTEIN staff only accept gifts and invitations that are low in value.
Low-value gifts and invitations must not be accepted if they could be used tomanipulate the employee. In case of doubt the employee must consult his line
manager or the Compliance Officer.
The appearance of being subject to extraneous considerations must be avoided
at all times.
The misconduct of others is no justification for one’s own misconduct.

16

Inappropriate gifts, invitations and undue advantage
can be recognised by way of an overall assessment of all the circumstances of theindividual case. The following criteria are used as guidance:
Timing
The closer we are in time to concluding projects or entering into contractual
negotiations, the more restrained we must be regarding any type of gratuity toand from business partners.
Quantity
Particular caution is required where invitations and gifts mount up.
Quality
When considering whether gratuities are appropriate, we consider not only the value
but also the context: Is this gratuity socially accepted and customary given the local
conditions and hierarchical position of donor and recipient?
Gratuities exchanged at management level are usually higher in value than thosebetween purchasers and sales staff. Thus an invitation to a high-class restaurant
may be reasonable for managing directors, whereas purchasing and sales staff
would be invited to go to a more basic restaurant or staff canteen.

5. We do not tolerate corruption

What does this mean for me?

If a business partner “expects” a donation to a charitable organisation in return for
concluding a deal, this amounts to corruption even if the advantage is granted to athird party – I will report this “expectation” to my superior or Compliance Officer
without delay.
If a business partner invites me to eat in a “simple” guest house or in his company
canteen, this is generally unproblematic.
If a business partner invites me to a major sporting, cultural or other event, e.g.
a Formula-1 race or a concert, I must either refuse and make reference to our Codeof Conduct or consult my superior or Compliance Officer.
If I receive small low-value promotional gifts (pens, calendars etc.) acceptance isunproblematic.
If, during an international project, a business partner surprises me with an expensive gift
and I cannot refuse it, e.g. for fear of causing loss of face on the part of an Asian businessassociate, I must inform my superior and the Compliance Officer. Depending on thesituation and context, the gift will be returned, given as a donation, raffled off, consumed
together with the department etc. Under no circumstances will I keep the gift for myself.
If I am invited by a business partner to an event or a meal together with my husband*,life-partner or other family member, I will refuse this invitation with reference to our Codeof Conduct.

No invitations and/or gifts for officials
Officials and other government servants at home and abroad must not be given any
gifts at all even if this is regarded as “normal” in some countries. The same applies toinvitations by officials and other government servants.

Careful selection of advisers, service providers and other third parties
WITTENSTEIN does not work with advisers, service providers or other third parties
who procure orders for WITTENSTEIN by way of bribery and corruption or similar.

*For the sake of simplicity, only the masculine form is used.

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6. We avoid conflicts of interest
Interests of the WITTENSTEIN Group take precedence
Individual and departmental interests are always secondary to the overall interests of
the WITTENSTEIN Group.

Separation of private and company interests
Independence, integrity and transparency determine our conduct and ensure ourcredibility with business partners.
Every employee must keep their private interests separate from those of the company.
We avoid any conflicts of interest. Conflicts of interest may arise where WITTENSTEIN
staff or their family members are involved with suppliers, customers, competitors,
advisers or other third parties that have business relations with the WITTENSTEIN
Group. Any conflicts of interest must be disclosed without delay.
Personal decisions must not be influenced by private interests or relationships.

20

No use of internal company information
for personal advantage
Internal company information about developments, orders, strategy
and other projects or plans may not be used for self-enrichment, to gain personaladvantage or to procure an advantage for a third party.

No private use of company property for private purposes
Company property (vehicles, office material, devices, data, documentation etc.) andcompany staff cannot be used for private purposes unless existing company rules
expressly permit this.

6. We avoid conflicts of interest

What does this mean for me?

A good friend is self-employed and sells software that I want to use in my own
department. That would make my work much easier – especially as my friend hasoften demonstrated the software to me. As with any other assignment,
I will involve the purchasing and information management departments
and will not engage my friend independently. Where the offer from my friend stands
up to a third-party comparison, he may be engaged by the purchasing department.
My son has finished his studies but cannot find a job. I am convinced that there is asuitable job at WITTENSTEIN and press HRM to employ my son. Preferential treatment
for relatives or friends is not permitted. HRM must decide exclusively according to thequalifications of the applicant. Where applicants are equally well qualified and suitable,
there is no reason not to employ a relative.
There is a choice of several suppliers or service providers for a project. The difference
between their offers is minimal. One supplier/service provider invites me to an expensive cultural or sporting event. I will refuse such private invitations with reference to our
Code of Conduct.
What do I do if I have been personal friends with a business partner for many years?
If I am personal friends with a business partner and this has no influence on the business relationship it is certainly acceptable for us to go out together with our families toan event provided there are no invitations and each pays privately for their own tickets/bills.

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7. We do not tolerate discrimination
Fair and respectful dealings
All staff in every country have the right to equal treatment and equal opportunities.
No person will be unfairly disadvantaged, favoured, harassed or denounced becauseof race, skin colour, nationality, heritage, ethnic origin, belief, world view, membershipof labour organisations (including unions), gender, age, social background or social
origin, sexual orientation, physical make-up, appearance or other personal characteristics.

Respectful and responsible interaction
Our corporate culture is characterised by mutual respect, appreciation and responsible
interaction. This applies both when working with business partners and within the
WITTENSTEIN Group.

What does this mean for me?

My line manager* is harassing me by making sexually suggestive remarks.
I will ask my line manager to refrain from this. If he does not comply with my request, I will
inform HRM or the Compliance Officer.

*For the sake of simplicity, only the masculine form is used.

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8. We do not tolerate child labour orforced labour
Ban on child labour and forced labour
WITTENSTEIN does not accept child labour or forced labour in its own company or inits supply chain. National rules protecting young employees must be complied with.
All employment must take place voluntarily and must be consistent with national laws
and procedures.

Disciplinary measures only in line with laws and human rights
Disciplinary measures against employees must comply with national laws and not
violate internationally recognised human rights.

What does this mean for me?

If I receive evidence that a sub-supplier in Asia is allowing children to work for him ininhumane conditions, I will, in consultation with my line manager, call upon him to remedy
the situation and to document this. If the supplier fails to do so, the business relationshipwith him must be terminated.
If I receive evidence that our supplier is employing minors as “free trainees” but that they
have to work just like “normal employees” then I will, in consultation with my line manager, call upon the supplier to cease this conduct without delay and to confirm it in writing.
If the supplier fails to do so, the business relationship with him must be terminated.
If I receive evidence that a supplier has set up production in a developing country andtakes the passports away from his employees in order to prevent them from handing intheir notice, I will, in consultation with my line manager, call upon the supplier to cease
this conduct without delay and to confirm it in writing. If the supplier fails to do so, thebusiness relationship with him must be terminated.
I will already be in breach of this Code of Conduct if I “close my eyes” and “deliberately
overlook” the evidence in order e.g. to avoid problems with suppliers and their sub-suppliers or e.g. to obtain cheaper prices.

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9. W
 e guarantee the freedom of
association
All employees have the right to set up and join organisations and to enter intocollective bargaining. WITTENSTEIN maintains a fair and frank dialogue with its
employee representatives.
Any discrimination against employee representatives will not be tolerated.
All employees are guaranteed free access to the workplace in order to exercise
their rights.

What does this mean for me?

I will not participate in any activities to restrict these rights.

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10. W
 e observe health and safety
standards
Protection of our employees
Health and safety at work forms part of all operational processes and must be
incorporated into the consideration of technical, economic and social issues.
Protecting our employees and the general public against health risks is the responsibility of all managers and all employees. The health and safety regulations issued by
WITTENSTEIN must be observed in the same way as applicable national laws.

Fair conditions of employment
Suppliers must provide a safe and non-hazardous working environment in order toavoid accidents and damage to health.
A hygienic workplace, access to drinking water, adequate sanitation facilities, regularsafety training and emergency preparedness must be standard for all employees.
Suppliers must ensure that working hours do not exceed the statutory maximum limits
applicable in each case. Employees must also be permitted to have adequate breaks
and rest periods, and to take holiday, in accordance with the statutory requirements.

What does this mean for me?

I notice that a fire extinguisher has been removed and put into a cupboard in order to makebetter use of space. I will inform my line manager, the Safety Officer or Compliance Officer
in order to ensure that, in the event of fire, fire-fighting operations can be performed without
delay in order to protect people and buildings.

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11. We pay our employees fairly
Remuneration below the statutory minimum wage is not accepted either at
WITTENSTEIN or in the supply chain. We are committed to fair remuneration inaccordance with national laws and practices.

What does this mean for me?

I receive evidence that a supplier can only offer the cheapest price because he is paying
his foreign workers, who he regularly replaces after just a few months, less than the statutory minimum wage. I will, in consultation with my line manager, call upon the supplierto cease this conduct without delay and to confirm it in writing. If he fails to do so, thebusiness relationship with him must be terminated.
I will already be in breach of this Code of Conduct if I “close my eyes” and “deliberately
overlook” the evidence.

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12. We conserve our environment
The statutory minimum requirements on environmental protection must be observed.
Any unlawful release of substances requiring authorisation must be avoided.

What does this mean for me?

I notice that substances requiring authorisation are being released unlawfully. I will
inform the plant manager or the office responsible for environmental protection within
the company, without delay.
It is my responsibility to avert damage to the company and the environment.

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13. We care about product safety
Reporting risks to the responsible department within the company
We monitor our products carefully. Dangers which arise, or simply those which may
arise, from our products, are analysed just as carefully as the use of our products,
where such use involves risks to people or property.

Warnings on products
Operating and assembly instructions are revised regularly. Our products display theappropriate warnings.

What does this mean for me?

I hear from a customer that critical situations have occurred repeatedly when using our
products which have had no serious consequences but which were capable of posing
a danger to people. I will inform the competent department within the company, e.g. theproduct manager or Compliance Officer, without delay.

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14. We protect our development results
The results of our technical development work form the basis of our future
success
All development results must be gathered, documented, identified, communicatedand archived in accordance with the latest internal rules. The security of development
results must be assured at all times.

No sharing of trade secrets with third parties
Business and trade secrets must not be passed on to work colleagues, or to friends,
relatives or business partners, without the effective protection of a non-disclosureagreement. Sharing confidential information is only permitted for the good of theCompany on a “need to know” basis, subject to compliance with the latest secrecy
regulations. We adhere to our statutory obligations to maintain confidentiality as we doto our contractual obligations which, in some cases, include an obligation to maintainsecrecy about the contractual partner and the project.

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Assessment required before granting licenses
Prior to being concluded, all agreements granting licenses to third parties to use ourdevelopment results must be assessed by the legal department and approved by therelevant managing director or Board member.

Careful examination of existing intellectual property rights during productdevelopment
During product development, there should be consultation with the in-house patents
department in order to avoid any infringement of existing third-party intellectual
property rights.

No unauthorised use of third-party trade secrets
We respect the trade secrets of third parties in the same way that we expect third
parties to respect our own.

14. We protect our development results

What does this mean for me?

I receive a call from the employee of a customer who wants me to send him confidential information straight away, about a development involving our know-how. He says
he needs it immediately for a board meeting on an important project and he cannot
currently reach the colleague responsible. I will only reveal this information followinginternal consultation with the colleague responsible and will not allow myself to be
put under pressure. I explain to the external colleague that I cannot reveal confidential
documents just like that, even if it would be in the interests of his company.
I am working on a highly innovative project with a promising future and I am proud of
the results of our development team. Even though it is difficult, I will not talk about thedetails of the project over lunch with colleagues from another department or during
my free time or when giving a tour of the Company. Ideally, I will not talk about thisproject at all unless it is necessary to do so for the project work itself.
The technical discussions on a development project are already far advanced. The
only thing left is the contractual agreement on ownership of the development results
and their use. The contractual discussions are just as tedious for the customer as
they are for me. Even if it is currently very inconvenient, I will arrange for the technical,
commercial and legal work to run in parallel and ensure that the responsible departments are involved at the right time in order to avoid any harm to WITTENSTEIN’s
bargaining position.

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15. We are careful with businessdocuments and data protection
Careful handling of business documents and data media

All business documents and data media must be carefully stored to ensure that they
do not fall into the hands of third parties. Confidential documents must not be left open
when leaving the workplace.
Your own PC must be secured against unauthorised use whenever it is left.

Careful storage of documents with traceable file management(electronic and in paper form)

All records and documents must be kept and stored in such a way as to ensure that
representation is possible at all times. Traceable, clear and complete record-keeping inpaper and/or electronic form is essential in this regard. Storage periods must at least
comply with the statutory requirements. The internal archiving regulation, as amended,must be observed in order to ensure that documents can be located at any time in full.

42Compliance with the rules on data protection

Compliance with the statutory rules as well as the latest company rules on information
technology and data processing is obligatory.

Involvement of the Data Protection Officer

We exchange information on a daily basis by way of the internet, intranet, emails etc.
The subject matter may also be personal data (name, address, birthday, hobbies,etc.) – data which makes it easier to network with business partners. The handling of
personal data is subject to data protection laws.
Where data is transmitted across borders, both the relevant national rules and theinternational agreements must be observed.
In case of queries or concerns, please always contact the Data Protection Officer prior
to any exchange of personal data.

15. We are careful with business documents and data protection

What does this mean for me?

I am going on holiday tomorrow and have just realised that I have only stored documents,from an important project that I am working on, locally on my own computer. For the sakeof simplicity, my colleague offers to retrieve the documents from my computer drive while I
am away if I let him have my computer password. Even though I appreciate his willingness
to help, I never reveal my computer password but ensure, during project work, that therelevant documents are already saved in a shared folder, common SharePoint etc.
I notice that a colleague has his computer password written on a post-it note hidden under
his keyboard. I tell my colleague that the password must always be stored safely.
I want to bundle together personal customer data for an international project, and forward it
to an internal colleague based abroad to enable cross-border cooperation. Before starting
work I will check with the Data Protection Officer whether this is permitted.

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16. We carefully consider risks
and opportunities
According to the principle of mindfulness, we can only make the best possible
entrepreneurial decisions by using opportunities and recognising risks.
Taking risks that jeopardise the Company is not permitted.
Risks must be indicated in the risk management system in order to protect theCompany from “unexpected” obligations or claims.

What does this mean for me?

I receive an enquiry regarding a very promising project involving high turnover from aforeign partner in whose country backhanders are customary and normally formallyprocessed via a chain of “sub-contracts”. I do not accept backhanders, either directly
or indirectly, and inform my line manager in order to avoid prosecutions and legal proceedings which will do more damage to the Company than any benefit likely to comefrom such a lucrative contract.

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17. We comply with export,
customs and tax laws
Compliance with export and customs laws
As a global Company, WITTENSTEIN is subject to various national and international
foreign trade laws. A variety of regulations apply to the import, export and transfer(also by email) of goods, technologies and services as well as to the movement of
capital and payments across certain international borders. Trading bans (embargoes)
and trade restrictions can also arise from the characteristics or the purpose of thegoods or services, the country of origin or use and the identity of the business partner.
Certain goods are used for both military and civilian purposes (dual use) and may besubject to authorisation. Export controls also affect exchanges between the individual
WITTENSTEIN companies.

Agreements regarding export control
On questions relating to export and customs laws, please consult our Export Control
Officer.

What does this mean for me?

I am asked by a German business partner if, for the sake of simplicity, I will send
project-related documents to his customer in a country subject to an embargo andto advise the customer so that the work can be processed more quickly. I refuse to
do so because export control legislation also applies to ancillary services that are
directly or indirectly linked to an embargo or to listed goods. Thus services can also
be affected particularly where the products themselves are covered by an embargo.
In such a situation, I will always consult the Export Control Officer.

48

Compliance with tax law
As a global company, WITTENSTEIN is subject to a variety of tax regulations whichmust be complied with in relation to all national and international transactions, even
where they are purely inter-company transactions. Tax law is highly complex andsubject to frequent changes. Every employee must be aware that, as a result of regularand careful auditing by the tax authorities, tax offences can quickly give rise to criminal
proceedings.

Agreements on tax matters
On questions relating to tax and subsidy law, please consult our Head of Corporate
Finance.

17. We comply with export, customs and tax laws

What does this mean for me?

A sales colleague, who is flying to meet a foreign consultant next day, asks me to let him
have € 15,000 from cash as a prepayment for the commencement of work so that the startof the project is not delayed by the lengthy transfer process. I tell the colleague that all
payments take place by way of bank transfer and subject to the dual control principle andthat I cannot decide on an ad hoc basis whether this may be a breach of the law on money
laundering. In such cases, I always inform our Head of Corporate Finance.

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18. We behave in an exemplary manner
All management staff lead by example
The Board, Managing Directors and entire management of WITTENSTEIN are awareof the effect of leading by example and undertake to manage the company in fullaccordance with the law and ethical principles – they will live and act in accordancewith the principles laid down in the Code of Conduct.

All staff work together to ensure compliance
Every individual employee bears responsibility for observing and complying with theprinciples laid down in the Code of Conduct during their everyday work.
That is the only way to achieve sustainability.

What does this mean for me?

As soon as I notice that a colleague is in breach of this Code of Conduct, I will point this out
to him in a polite manner and, where appropriate, inform my line manager or Compliance
Officer.

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19. We do not discriminate against
whistle-blowers
No discrimination against employees who report violations
Any employee can report circumstances that indicate a breach of this Code of
Conduct. The report may be made by telephone, email or letter to the line manager
or Compliance Officer.
Anonymous reports can only be pursued where they contain detailed information andfacts about concrete violations. You may rest assured that we will treat your report in
the strictest confidence and that you are not at risk of any disadvantage if, acting in all
good conscience, you report a suspected violation.

The rules of the Code of Conduct take precedence over any instructions by aline manager
Even though it may seem appropriate, in the individual case, to suspend the rules of
the Code of Conduct in order to conclude a lucrative transaction and achieve highsales – the rules of the Code of Conduct, in accordance with sustainable and ethicalbusiness management, take priority over contrary instructions from managerial staff.

What does this mean for me?

If I notice that my line manager is accepting inflated invoices from a supplier andhaving the excess amount paid by the supplier to his wife’s consultancy company,
I will inform HRM and the Compliance Officer without delay – even if my line manager
tells me that this has been agreed with the Board. I can be certain that I will not be
put at a disadvantage as a result of my openness.
However, I will never use reports in order to disparage a colleague or line manager,
or accuse him without justification, for my own purposes. In the event of an improper
report, i.e. where reports of occurrences contain allegations that are patently unfounded, WITTENSTEIN reserves the right to take legal action or disciplinary measuresagainst the informant.
If I have a personal problem with a colleague, I will not “run him down” under theguise of compliance in order to “get him back” but will always solve the problem ina business-like and professional manner and together with my line manager whereappropriate. Otherwise I must expect to be reported myself.

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20. Implementing the Code of Conduct
How do we make decisions?
Specific issues arising in everyday professional life cannot always be answered withcertainty. In case of uncertainty, we consult our line manager or the responsible
department within the company.
Answering the following questions with common sense makes our decisions easier:• Is my decision or action in line with the applicable law?
• D oes my decision or action correspond with the requirements of this Code of
Conduct and our Company’s values?
• If my colleagues and friends knew about my decision or action – would I still havea good conscience?
• Can I live with the consequences of this decision or action?
• If my decision or action were reported in tomorrow’s newspaper –could I defend it?

Duties of our managerial staff
All managerial staff of the WITTENSTEIN Group must lead by example and support
their employees.
Compliance with the law, company guidelines and this Code of Conduct always
takes priority.
Under no circumstances will we sacrifice the good reputation and integrity of the
WITTENSTEIN name for short-term gain.

Contacts
Compliance Officer:
Evelyn Rösch
Walter-Wittenstein-Strasse 1
97999 Igersheim
T: +49 7931 493-18520
compliance@wittenstein.de

The latest version of the Code of Conduct, as well as
further information, is available on the intranet, on theleft-hand side under “Compliance”.
Other in-house directives are also available there.

WITTENSTEIN SE · Walter-Wittenstein-Strasse 1 · 97999 Igersheim · Germany
T: +49 7931 493-0 · info@wittenstein.de

WITTENSTEIN – one with the futurewww.wittenstein-group.com