Jenoptik Integrity Code - More Integrity, More Compliance, More Ethics
Corporate Center · Compliance & Risk Management

AgendaRespect for human rights – a high priority and abasic prerequisite for our business activities

Compliance & Ethics – the benchmark for our
conduct in the Jenoptik market environment

Working at Jenoptik

Compliance with the Jenoptik Integrity CodeCompliance & Ethics – the benchmark for our
conduct in the workplace

Scope, version & contact person

Compliance & Ethics – the benchmark for our
conduct in the market
Jenoptik Integrity Code2

Explanations
SymbolExplanation
Further information

Our contribution as Jenoptik employees

Responsible departments for further questions

Reporting channels

Jenoptik Integrity Code3

Our Jenoptik Integrity Code

Making the right choice at
the right moment, actingwith integrity – that is what
we are all about in all partsof Jenoptik. Shared values
are essential to this.

Jenoptik Integrity Code4

Our Jenoptik Integrity Code
Our Integrity Code applies globally to all Jenoptik

We, as Jenoptik employees, are informed about theemployees. In the following, "Jenoptik" refers to allapplicable legal basis for our work as well as internal

companies in which JENOPTIK AG directly or indirectly holds

guidelines, including this Integrity Code, and we adhere toat least 50% of the shares. Consequently, the term "Jenoptik

them. Our managers at all levels provide guidance andemployee" includes all employees of one of the companies

support.

belonging to the Jenoptik Group.
Our Integrity Code brings together our rules of conduct so
The Integrity Code sets the standard for our daily actions inas to ensure a high level of integrity and high ethical andJenoptik‘s business environment. It defines relevant topics

legal standards in our company and to protect theand provides guidance on standards of integrity, compliancereputation of all Jenoptik companies. It is based on binding

and ethical behaviour.

standards and values such as respect, tolerance, honesty
and openness, which apply to all Jenoptik employees

At Jenoptik, compliance stands for adherence to legal

worldwide - from the Executive Board to trainees.

provisions, internal company guidelines and the Jenoptik

values to protect our companies and brands. At Jenoptik,
acting in accordance with applicable law is a matter ofcourse, the basis of all business activities and the top priority
for all employees. The legal regulations and our own internal
guidelines form the framework within which we conduct ourbusiness.

Dr. Stefan Traeger
Chairman of the
Executive Board

Dr. Prisca HavranekKosicek

Dr. Ralf Kuschnereit

Member of the
Chief Financial Officer Executive Board

Jenoptik Integrity Code5

1

Respect for human rights – a highpriority and a basic prerequisite forour business activities

1. From the outset: The protection of human rights – a high priority and abasic prerequisite for our business activities

For us, economic success and responsibility for our actions
are inextricably linked goals. Jenoptik is committed torespecting human rights and protecting the environment –in our own company and throughout our supply chain.

The published policy statement on the protection of human rights and theenvironment explains this in detail and is available on our website under
Sustainability / Responsible corporate management / Respect for human

Human Rights Officer(CC Compliance & Risk Management)rights.
Jenoptik Integrity Code7

2

Working at Jenoptik

2. Working at Jenoptik
2.1 We as a team
Together, we are a globally active technology groupfocussing on the photonics market with its range of
products and services. Optical technologies are thefoundation of our business. Our key markets primarily

Colleagues we would like to work with arecolleagues who...

Our contribution:•

We listen carefully.

•

We share our thoughts and develop ideas in an open−

listen,industry, life science and medical technology as well astransport and security. We are active in various sectors and−have a natural curiosity for their profession,−

are open to new developments,•

We are open to change and better solutions.

markets and operate with different, strong brands (e.g.

−have the will and motivation to win,•

We actively promote our topics, projects and ideas.

−

have the desire to make things happen,•

We want to be better than the competition.

−

are dynamic,•

We want to move forward, we want to be fast, we−

identify with the great products that Jenoptik
manufactures,−are convinced of their skills and experience and−see opportunities and possibilities instead of obstacles.

include semiconductor equipment and the electronics

Jenoptik, TRIOPTICS, SwissOptic).

Jenoptik Integrity Codedialogue and across borders.

want to win – but always in compliance with therelevant rules!
•

We offer our employees the opportunity to give theirbest as part of a very good team.

•

We are determined to break new ground.

92. Working at Jenoptik

curiousopen for new ideas

less bureaucratictransparent
honestopen mindedclarity

Jenoptik Integrity Code10

2. Working at Jenoptik
2.2 Our Jenoptik values
Open

Driving

Confident

Employer Brand

We believe that committed and curious

Jenoptik is an innovative company. This

We have the courage, the conviction andValuespeople always excel. That‘s why we listenmeans that we do things that have not been

the expertise to seize opportunities as they

well in order to understand. We value newdone before. To do this, we are actively

arise and to be leaders in the field ofideas and develop them further in an open

driving things forward. To achieve our goals,

photonics. We look to the future with

dialogue.

we support people who want to succeed,

optimism and confidence.

who lead the way and who are absolutely
motivated to win.

Jenoptik Integrity Code11

2. Working at Jenoptik
2.2 Our Jenoptik values

Open

Driving

Confident

CuriousAmbitious

InspiringLess bureaucratic

Speed

Quality

Will to win

Determined

Keep it simple

Transparent

Proactive

Reliable

Innovative

Responsible

Transparent

Empowered

Optimistic

Open minded

Motivated

Courageous

HonestClarityOpen to new ideas

Jenoptik Integrity Code12

2. Working at Jenoptik
2.3 The principles of our conduct
Jenoptik is committed to ensuring equal opportunities, equal

Jenoptik also expects all employees to keep their promises,

treatment and fair working conditions.

carry out their work conscientiously and in a goal-oriented
manner, take responsibility and actively support their

All employees respect the personal dignity of eachcolleagues.

Open− Transparency always− Helping behaviour

individual and refrain from actions or comments that
discriminate against, disadvantage or treat other persons

When in doubt, our leaders provide guidance and support at

unequally on the basis of ethnic or national origin, skin

all levels to help us behave with integrity and in accordancecolour, gender, religion or ideology, political affiliation,with the standards and principles set out here and to makedisability, age, marital status, sexual identity or otherthe right decisions.

personal traits or characteristics.
Our managers are measured against the Jenoptik Leadership

Interacting with others in a broad-minded, open andPrinciples.

Driving−−−−

Customer obsession
Drive for Solution
Focusing
Individual initiative

respectful manner is just as important as regularly
communicating with colleagues. Cooperation based on trust
starts with friendliness, helpfulness and reliability.

Confident−−−−

Jenoptik Integrity CodeOrganizational ownership
Hiring & Development
Invent and simplify
Self development

13

2. Working at Jenoptik
2.4 Jenoptik feedback and error culture

Mistakes are human –there is no doubt.
Where people work,
mistakes happen.

Jenoptik Integrity Code14

2. Working at Jenoptik
2.4 Jenoptik feedback and error culture
Constructive and appreciative feedback is highly valued at

For us, mistakes are not a stigma, but an opportunity for

Jenoptik and is always welcome. In addition, there is a regularimprovement. In this way, we are able to respond quickly andexchange of feedback between employees and managers as

effectively to problems and adapt to changes. To staypart of the standardised annual employee appraisal, based on

innovative and achieve business progress, we need a healthy

our Jenoptik values.

willingness to take risks. On the other hand, we want to avoid

and actively deal with errors free of blame inorder to analyse them and, if necessary, further

The aim is to obtain regular feedback between employees

unnecessary risks. In order to prevent possible damage to us
and Jenoptik, we point out errors directly, honestly andand managers over the course of the year. The topics arewithout reservation.

instructions and procedures.

selected according to current developments and needs (e.g.
job description, project list, feedback to employee or

We promote a positive and open error culture and actively

manager, company values, etc.) between employee anddeal with errors without apportioning blame in order tomanager and can be divided into separate feedback

analyse them and, if necessary, further develop skills,

meetings.

processes, work instructions and procedures.

Errors can and may also be communicated openly as part ofJenoptik firmly believes that in an atmosphere in whichconstructive feedback. This applies in both directions. It is

employees are not afraid to point out their own mistakes,

important to us that a recognised error is expressed as a

fewer errors will automatically occur.

Our contribution:▪

We promote a positive and open error culture

develop competencies, processes, work▪

We firmly believe that in an atmosphere inwhich employees are not afraid to point out
their own mistakes, fewer mistakes willautomatically occur.

criticism of behaviour ("Colleague X didn't check that") andthat no criticism is made of the person themselves("Colleague X is sloppy and unfocused").

Jenoptik Integrity Code15

3

Compliance & Ethics –the benchmark for our conduct
in the workplace3.1 Integrity towards colleagues
and Jenoptik as an employer

3. Compliance & Ethics – the benchmark for our conduct in the workplace

We conduct ourselves ethically in our workplace and comply with all laws
and internal regulations that apply to us.
Jenoptik Integrity Code18

3. Compliance & Ethics – the benchmark for our conduct in the workplace
3.1.1 Diversity in the workplace – diversity, equal treatment and equal opportunities
What Jenoptik means by diversity andOur contribution:

inclusion:
By diversity and inclusion, we mean ensuring a work
environment that is free from prejudice and creates an▪

We treat everyone fairly and with respect.

▪

We demonstrate an open and inclusive mindset

atmosphere of openness and respect for each and every

by actively allowing for different ideas,

one of our employees. As an international company, we areperspectives and approaches.

a reflection of the diversity of our customers and business▪

partners. We reject any form of discrimination based on age,

We comply with national anti-discrimination
legislation (e.g. AGG, Civil Rights Act, Americans

gender and sexual identity and orientation, ethnic origin

with Disabilities Act, etc.) in our daily activities.

and nationality, religion and ideology or physical abilities.

▪

We pay special attention to appropriate training.

Why diversity is important to Jenoptik:
Diverse teams are successful teams - that’s what Jenoptik
firmly believes. A positive, non-discriminatory working
environment creates added value for the company, but also
for each individual employee. However, this can only beachieved if everyone actively contributes.

Jenoptik Integrity Code19

3. Compliance & Ethics – the benchmark for our conduct in the workplace
3.1.2 Diversity in the workplace – a workplace free of discrimination and harassment
Why a workplace free of discrimination andOur contribution:harassment is important for Jenoptik:▪

Respect and team spirit are basic requirements for our
corporate success. Behavior such as bullying, sexual

We condemn all forms of discrimination andharassment.

harassment or discrimination is incompatible with our▪

We report any case of discrimination or

corporate principles and values and will not be tolerated

harassment either the manager, the HR Businessunder any circumstances. Any indication of such a breach ofPartner* or the Compliance & Risk Management

employment law obligations will be taken seriously and may

Department.

result in action under employment law. We are all▪

responsible for creating a fair, tolerant, respectful andcollegial working environment.

We act as role models when we express that wewill not tolerate discriminatory behaviour.

▪

We promote a work environment free fromdiscrimination and harassment through our way
of working and interacting with each other,including the way we express ourselves.

Human Resource

Jenoptik Integrity Code20

3. Compliance & Ethics – the benchmark for our conduct in the workplace
3.1.3 Legitimate conduct at the workplace
What do approval authority and power of

Why is it important for Jenoptik to define

representation mean?

clear internal approval and external

The external power of representation includes the authority
to conclude legal transactions in the name of and on behalfof one of the Jenoptik companies. These are based, among
other things, on procurations, powers of attorney andspecial powers of attorney.

The authority of all Jenoptik employees to approve mattersrepresentation regulations?
In the daily course of business, it’s important that all staff
members are aware of the authorities they have. This isbecause the conclusion of legal transactions creates rights
and obligations and thus risks and opportunities for
Jenoptik.

internally is regulated the Internal Authorization Matrix("IAM").

Jenoptik Integrity Code21

3. Compliance & Ethics – the benchmark for our conduct in the workplace
3.1.3 Legitimate conduct in the workplace
For this reason, there are defined processes that define− which specialist departments are to be involved before

Our contribution:

concluding legal transactions,− which internal approvals must be obtained,▪

− how these are to be documented and− which employees are entitled to conclude external legal▪

transactions on behalf of Jenoptik.

When defining processes, we make sure that they are

We inform ourselves about our authority with our▪

supervisor and by means of the authority matrices

our own behalf, but on behalf of a Jenoptik

and comply with them.

company when conducting business.

We observe the four-eyes and one-over-one▪

principle that applies globally at Jenoptik.
▪

designed to be efficient and practical. The necessary(internal) approvals must always be obtained prior to theconclusion of corresponding legal transactions in order to

We always make it clear that we are not acting on

We adhere to the principle of joint representationin external legal transactions, i.e. external
documents must be signed by two authorised

We always involve the responsible specialist
department in external legal transactions.

▪

We initiate the relevant processes in good time if
certain legal transactions have to be approved inadvance by committees.

employees throughout the Group.

avert risks for Jenoptik as far as possible and to achieve thebest possible result.

▪

Global / Divisional Internal Authorisation Matrix▪

“External Representation and Signatures” process description▪ Process descriptions for committee approvals

CC Legal & IP

Jenoptik Integrity Code22

3. Compliance & Ethics – the benchmark for our conduct in the workplace
3.1.4 Safety in the workplace
What does occupational health and safetycomprise of?
"Occupational safety" comprises all regulations and measurestaken to protect the life and health of our employees in theperformance of their work. Occupational health and safetyserves to prevent accidents in the workplace and to protect
against work-related hazards and health risks for our

employees.

Why is occupational health and safety a highpriority for Jenoptik?
Jenoptik has a global responsibility for the safety and healthof its employees in the workplace. Safe and decent working

We provide a safe working environment and comply with allapplicable health and safety laws and regulations relevant to
the workplace.
Risk and hazard assessments are carried out throughout thecompany/group. They are used to identify existing hazards

and take suitable preventive and protective measures, butalso to realise potential for improvement and improveergonomics in the workplace. High technical and operationalsafety standards are the basis of our work. Our goal is toprevent work-related accidents and illnesses before theyoccur. Jenoptik relies on the participation of all employees.

When introducing new and changing existing technologies,
materials, workplaces and work processes, the responsible

conditions are therefore a matter of course for us. This is

Environmental, Health and Safety (EHS) management andwhy we integrate occupational health and safety into ourthe fire safety officers must be involved in the risk

structures and processes on a sustainable basis.

assessment.

Jenoptik Integrity Code23

3. Compliance & Ethics – the benchmark for our behaviour in the workplace
3.1.4 Safety in the workplace
Our contribution:▪

We follow the instructions and specifications in▪

order to work safely and without accidents.
▪

▪

immediately if this is necessary and can be donesafely.

We always use the required personal protective
equipment.

▪

We inform ourselves about local fire protection
concepts and instructions at our site.

We eliminate unsafe working conditions

We report any unsafe working conditions to oursupervisor, HR, Facility Management or Health &Safety Management and inform them of possible
improvements.

The relevant regulations and measures relating to occupational healthand safety and fire protection can be found here:•

Laws, rules and regulations•

Emergency plans•

Fire safety plans•

Evacuation plans

CC Health, Environment & Safety

Jenoptik Integrity Code24

3.2 Integrity towards
employee representatives

3. Compliance & Ethics – the benchmark for our conduct in the workplace
3.2 Integrity towards employee representatives
Employee representatives are works councils, general works

Our contribution:

councils, representatives of the severely disabled, youth andtrainee representatives, the Group Works Council and theemployee representatives on the Supervisory Board.

▪

We always promote honest, constructive andrespectful interaction with employee
representatives.
▪

We discuss and develop solutions together withthe company parties that serve the well-being of
all employees and Jenoptik.

▪

We also adopt a solution-orientated approach inconflict situations.

▪

We ensure that every Jenoptik employee canapproach the employee representatives openly
and confidentially without suffering any
disadvantages as a result.

▪

Jenoptik Intranet▪

Law: Works Constitution Act▪

Works agreements▪

Tariff regulations

Responsible works council of the Group or therespective Jenoptik Group companies
Jenoptik Integrity Code26

4Compliance & Ethics –the benchmark for our conduct
in the market

4. Compliance & Ethics – the benchmark for our conduct in the market

We behave in a compliant
and ethical manner –to all stakeholdersof Jenoptik.

Jenoptik Integrity Code28

4. Compliance & Ethics – the benchmark for our conduct in the market
4.1 Selection of business partners
What does Jenoptik mean by the term

Why is it important for Jenoptik to select its

Such evidence shows:"business partner"?

business partners carefully?

− the selection process,The actions of business partners, such as suppliers,
consultants, sales partners, agents or subcontractors− the contractual organisation of the business relationship

Jenoptik defines all parties with whom it concludes legaltransactions as business partners, irrespective of content
and form. This includes, for example, customers, cooperation
partners, suppliers and subcontractors, sales partners,
agents and consultants as well as other contractors.

− the instructions of the business partner, andin compliance with due diligence.

commissioned by Jenoptik, can be attributed to ourcompany under certain conditions. Consequently, Jenoptik

This makes it possible to prove that there were no

can thus be held responsible for the actions of these

indications of acts of corruption or other relevant legal

business partners.

violations when the business partner was selected, and thetransaction was concluded.

For example, if business partners engage in acts ofcorruption or other unlawful acts to the advantage ofJenoptik, it is possible that this may be assumed to havebeen done with Jenoptik's tolerance or even on its
instructions. As a result, Jenoptik can suffer massive
reputational damage but also financial consequences.
Jenoptik will be able to exonerate itself in this case inparticular by providing evidence of careful business partner
selection.

Jenoptik Integrity Code29

4. Compliance & Ethics – the benchmark for our conduct in the market
4.1 Selection of business partners
Our contribution:▪

We adhere to the process for selecting high-risk▪

business partners in accordance with the internallyprovided third-party due diligence.
▪

We avoid risky agreements by thoroughly
checking the contractual provisions.

▪

We monitor critical business partners continuously,

We carry out adequate checks to ensure that weno later than three years after the last audit, andonly work with business partners who meet ouron an ad hoc basis if necessary.

compliance standards when selecting business
partners.
▪

We commit business partners to our compliancestandards.

CC Compliance & Risk Management
CC Legal & IP
CC Supply Chain & Procurement"Business Partner-Compliance“ processdescription
Jenoptik Integrity Code30

4. Compliance & Ethics – the benchmark for our conduct in the market
4.2 Contract conclusions
Why is it important to follow a definedprocess when concluding contracts?
As the conclusion of contracts entails rights and obligations
which can give rise to risks for Jenoptik, it is important toadhere to a defined process for the conclusion of contracts

Our contribution:▪

▪

conclusion of a contract or the termination of contract▪

We check, before concluding a contract, whether

contract to be negotiated requires thethe subject matter of the contract to be negotiatedapproval/involvement of other departments.

is not already the subject of other agreements that

could prevent the conclusion of a contract or

We organise the negotiations in such a way thatby authorised colleagues.
▪

Process descriptions regarding the purchasing▪

influence the content of the contract to benegotiated.

voice”. Contract negotiations are only conductedviolate applicable law.

▪

applicable signature authorisations.

the Jenoptik contracting party speaks with “oneContracts may, of course, only be concluded if they do not"Contracts“ process description

approvals (e.g. IAM) and in accordance withWe involve CC Legal & IP as early as the contract
process description. We also check whether the

towards possible contract negotiations and ends with the

We only conclude contracts or submit binding
offers after documenting all internally required

initiation stage in accordance with the "Contracts"

departments. Contract initiation starts with the first steps▪

▪

contract negotiations begin.

and, if necessary, to involve the relevant specialist

negotiations.

We conclude confidentiality agreements before▪

We ensure efficient filing and archiving.

We always conclude contracts in text form, unlessthe law stipulates a stricter formal requirement.

CC Legal & IPprocesses
Jenoptik Integrity Code31

4. Compliance & Ethics – the benchmark for our conduct in the market

Legally compliant
conduct is a matter ofcourse for us and forms
the framework of ourbusiness activities.

Jenoptik expects its employees to know which laws and other legal provisions apply to their

If there is any uncertainty about which laws and other legal provisions apply to a specific area

professional activities and to comply with them under all circumstances. Only legallyof work, the supervisors or the specialist departments as well as CC Compliance & Risk

compliant business is business that we at Jenoptik want to conduct.

Management are available to provide information.
Jenoptik Integrity Code32

4. Compliance & Ethics – the benchmark for our conduct in the market
4.3 Protection of free competition
What is "free competition"?

Why is free competition important?

Free competition means that different companies competewith each other in terms of demand. Every company is

Restricting competition leads to a deterioration in thequality of supply and a simultaneous price increase. The

exposed to the risk that its own customers will switch to alegislator therefore provides for certain legal regulations tocompeting company if this competitor offers comparable

protect competition as far as possible.

products, services or other services at a lower price or better
quality.
In order to survive on the market under competitive
conditions, companies must continuously improve theirproduct and service quality and offer their products andservices at the most attractive prices on the market. This is
how innovation is driven forward.

Jenoptik Integrity Code33

4. Compliance & Ethics – benchmark for our conduct in the market
4.3 Protection of free competition
Our contribution:▪

We are committed to upholding the principles of fair▪

competition at all times.
▪

relevant under antitrust law to the Legal department

for review. This applies in particular to authorised

We do not make negative public statements about

dealer and sales representative agreements, research

the goods, services, activities or other circumstancesand development or cooperation agreements, andof a competitor.
▪

We always submit transactions that may be

We do not exchange sensitive information withcompetitors.

enquiries by the competition authorities.
▪

We immediately consult the Legal department whenassessing whether there is an abuse of a dominantmarket position, e.g. in the event of corresponding
allegations by a supplier.

“Conduct in line with competition law”
guideline

CC Compliance & Risk Management
Jenoptik Integrity Code34

4. Compliance & Ethics – the benchmark for our conduct in the market

Our intention is to excel against the competition on the basis of the performanceand quality of our products and services.
Jenoptik Integrity Code35

4. Compliance & Ethics – the benchmark for our conduct in the market
4.4 Anti-corruption and conflicts of interest
What is "corruption"?
Corruption is the misuse of entrusted power for private gain.
Corruption exists if the objectivity and independence of the

Our contribution:▪

recipient is to be influenced by the granting of anadvantage. Corruption is offered, promised, granted or

accepted in connection with business or official decisions.

We clearly distance ourselves from any form of▪

corruption - worldwide.
▪

prevention provided by the Compliance & Risk

Management department, especially in our business

We regularly participate in measures to prevent

dealings with authorities, public officials and elected

corruption.
▪

We adhere to the information on corruption

representatives.

We do not make any attempts to favour theconclusion of contracts through inadmissible
measures, in particular, we do not offer the prospectof inadmissible advantages in favour of the other▪

We do not agree to any kick-backs ('rebates’).

▪

We report suspected cases of corruption to CC
Compliance & Risk Management.

party.

"Prevent Corruption” guideline

CC Compliance & Risk Management

Jenoptik Integrity Code36

4. Compliance & Ethics – the benchmark for our conduct in the market
4.4 Anti-corruption and conflicts of interest
What are conflicts of interest and how do

Why does Jenoptik want to avoid conflicts ofthey arise?

interest?

Our contribution:

A conflict of interest in the work environment can arise, forexample, when we pursue certain interests in our private

It is important to Jenoptik that business decisions are madeon the basis of appropriate considerations and in the▪

life, but these interests are in conflict with the interests ofinterests of Jenoptik. Business relationships with third

our employer and/or could even harm the company.

parties must therefore always and exclusively be based on

Basically, a conflict of interest is a situation where two or

objective criteria, such as price, quality and reliability. The

more conflicting interests clash. A conflict of interest may

interests of Jenoptik as a company have top priority in thisexist, for example, due to family relationships, secondary

context. Our employees may not pursue their own private

employment or financial interests.

interests in this context. In order to avoid a situation inwhich one of our employees has to choose between

interests and personal interests could conflict.
▪

We disclose potential conflicts of interest to
Jenoptik.

▪

We report any secondary employment, executive
body participations or financial participation inan organisation or company that may affectJenoptik's interests to the respective supervisor
before taking it up and obtain prior approval.

Jenoptik‘s interests and personal interests arising fromprivate relationships, Jenoptik is keen to avoid conflicts of

We avoid situations in which Jenoptik's business▪

We do not participate in decisions in which thereinterest from the outset and, if necessary, to disclose themis or could be a conflict between the interests ofas early as possible.

Jenoptik and a secondary activity, executive bodyparticipations or financial participations.

CC Compliance & Risk Management

Jenoptik Integrity Code37

4. Compliance & Ethics – the benchmark for our conduct in the market
4.5 Gifts and benefits to business partners
What does Jenoptik mean by "gifts andWhy does Jenoptik set rules in connection

benefits"?

with gifts and benefits?

The term "gift" describes "a donation by which someone
enriches another person from their own assets if bothThe granting or acceptance of gifts and benefits in national
and international business transactions is only permitted

parties agree that the donation is made free of charge."

within a narrow legal framework and the boundaries toEssentially, this means that there is no consideration for a

corruption are fluid. For this reason, CC Compliance & Risk

gift. Non-exhaustive examples of gifts in the business

Management standardises globally applicable guidelines forenvironment include a bottle of wine or spirits, gift baskets,

the permissibility of gifts and benefits.

tickets to sporting or cultural events or invitations to VIPboxes.

Small gifts for special occasions or for promotional
purposes, hospitality and other Invitations are common inbusiness transactions and are not per se a sign ofcorruption. These can therefore be given or accepted aslong as they are only occasional, they are sociallyappropriate, and are unlikely to exert any influence or givethe impression of an attempt to exert influence.

CC Compliance & Risk Management
Jenoptik Integrity Code38

4. Compliance & Ethics – the benchmark for our conduct in the market
4.5 Gifts and benefits to business partners
Our contribution:▪

▪

We know that gifts and benefits are permitted to a▪

reasonable extent, both as a recipient and as a

may not be paid for from company funds unlessdonor.

there is a transparent process behind it and takes
all employees into account equally, e.g. gifts for

We use the workflow/self-test for assessing theanniversaries.

admissibility of gifts and benefits on the CC
Compliance & Risk Management intranet page for▪

all gifts.
▪

We are aware that gifts to individual employees

We pay particular attention to gifts and benefits toauthorities, public officials and elected

representatives and are aware that the thresholds

We contact CC Compliance & Risk Management inin this context are lower than in the generalcase of doubt, i.e. if at least one criterion in thebusiness environment.

self-test has been answered with NO.
▪

We comply with all tax regulations and pay tax on
any gifts or benefits received.

Jenoptik Integrity Code39

4. Compliance & Ethics – the benchmark for our conduct in the market
4.6 Money laundering prevention
What is money laundering?

Our contribution:

Money laundering is a process by which money from unlawful
sources is redirected into lawful financial channels or lawful▪

money is diverted off for unlawful purposes. In order to avoid

We do not conclude cash transactions, as amatter of principle.

any involvement in money laundering activities, it is importantthat Jenoptik companies comply with all regulations for the▪

We do not enter into any transactions that

contain indications of money laundering.

prevention of money laundering and, if necessary, support nonprivileged obligated parties under the German Money▪

Laundering Act in implementing their Know Your Customer

We are all obliged to comply with the applicablemoney laundering regulations.

obligation.

▪

We never create or maintain unofficial or

unregistered Jenoptik funds, assets or liabilities("slush funds").

“Prevent Money Laundering” guideline from CC
Compliance & Risk Management

CC Compliance & Risk Management
CC Treasury
Jenoptik Integrity Code40

4. Compliance & Ethics – the benchmark for our conduct in the market
4.7 Prohibition of insider trading
What is insider trading?

− significant incidents relating to product liability or

Every employee may have access to confidential information
about our company in the course of their daily work that is− major claims or court action brought against Jenoptik

not generally known to the public ("insider information")and, if it becomes known, could influence Jenoptik's shareprice ("price-sensitive information"). Examples of insider
information include:− the conclusion, amendment or termination of important
contracts− the failure of key debtors− the acquisition or disposal of key holdings− key changes in or deviations from target figures andfinances, including results in annual financial statements

environmental damage

Our contribution:▪

It would constitute insider trading if we were to buy or sell
Jenoptik shares on the basis of this knowledge or instructanother person to do so or pass on this knowledge andstock market transactions were then carried out on this

We do not conduct or attempt to conductbusiness using insider information (e.g. purchaseor sale of Jenoptik shares).

▪

We do not recommend the acquisition or sale ofinsider securities (e.g. giving their family a 'tip' tobasis.

quickly buy Jenoptik shares).

Why is preventing insider trading important?
Insider trading is a criminal offence in Germany and mostmember states of the European Union a criminal offence, as
it impairs the functioning of the capital market.

or interim reports compared to previous results or market
forecasts (surprising business figures)▪

We consult with CC Investor Relations &Sustainability and Legal & IP if we are unsure

whether a particular piece of information
constitutes inside information or whether aparticular purchase or sale of Jenoptik shares is
prohibited.

CC Legal & IP
CC Investor Relations & Sustainability

CCI Capital Market Guide

Jenoptik Integrity Code41

4. Compliance & Ethics – the benchmark for our conduct in the market
4.8 Other specific regulations
Some areas of work provide for very specific regulations that are
only relevant for certain groups of colleagues and specialist
areas. There is no doubt that we also adhere to and comply withspecific regulations that are not explicitly mentioned in thisIntegrity Code due to its generalised nature.

The following is an exemplary, but not exhaustive list of such
topics and regulations:

Foreign trade law, export
control and customs

Group Trade Compliance Policy

Data privacy

Information on data protection provided by CC Compliance& Risk Management on the intranet Data Protection |Intranet | Jenoptik

IT & Information security

All information provided by the IT & Information Security
departments on the Intranet Information Security | Intranet |Jenoptik

Financial integrity

CC Finance - Accounting

For further information on these and other compliance-relevant
topics, we can contact our supervisor or the specialist

departments of the Corporate Center or the divisions at any time.
Jenoptik Integrity Code42

5Compliance & Ethics –the benchmark for our conduct in
the Jenoptik market environment

5. Compliance & Ethics – the benchmark for our conduct in the
Jenoptik market environment
5.1 Jenoptik's external image
What does the external image of Jenoptik

Why is a coordinated external image

comprise of?

important for Jenoptik?

Jenoptik is in contact, day in, day out, with a wide variety ofinterest groups, such as people from the media, politics andHaving a professional, uniform appearance is the only way
to present ourselves credibly on the market as a company

the public, but also business partners or investors as well aswith a strong brand. To ensure our company profile remains

potential future employees. It is therefore particularly

consistent, coordinated specifications governing

important that the presentation of the company and its

communication and corporate design are in place. These

specifications of this Integrity Code in our

products to the outside world is appropriate and consistent.

apply regardless of whom the communication is addressing

external image.

(the media, investors, public authorities, customers, suppliers
or other business partners) and, in addition to creating auniform professional company profile, they also help to
speed up internal processes. For example, new presentations

Our contribution:▪

We comply with the CC Communication &Marketing specifications for the external imageof Jenoptik.

▪

▪

We also adhere to the Jenoptik values and theWe deal with others in a respectful and dignified
manner, free of any discrimination.

▪

We only use the Jenoptik brand in the manner

can be prepared in a more structured fashion and businessregulated in the corporate design and do notcorrespondence can be drafted more quickly.

make any changes to the brand.
▪

We contact CC Communication & Marketing in
the event of enquiries about the use of the brandby third parties or enquiries from the press orother media.

CC Communication & Marketing

Jenoptik Integrity Code44

5. Compliance & Ethics – the benchmark for our conduct in the
Jenoptik market environment
5.2 Sustainability and environmental protection
What does Jenoptik mean by"sustainability"?
Sustainability plays a crucial role in our corporate culture
and is firmly anchored in our corporate strategy. The clear
commitment to greater sustainability is reflected in thewide range of sustainability targets, some of which aretaken into account in Executive Board remuneration andGroup financing. The diversity rate, which describes the
proportion of women and international colleagues inmanagement, the proportion of green electricity at themain sites, the CSR rate for measuring sustainability in our
supply chain and the Vitality Index, which indicates the

proportion of new product sales, are important key figuresachievement of the United Nations Sustainable
Development Goals (SDGs) through our products andsolutions. By joining the UN Global Compact - the world's
largest initiative for responsible corporate governance Jenoptik is committed to complying comprehensively withthe ten principles in the areas of human rights, labour
standards, environmental protection and anti-corruption.
Implementation of statutory and company measures toprevent air, soil, and water pollution is binding on all staff

members and the use of hazardous materials must be kept
to a minimum. All staff members are required to handle
hazardous materials in an environmentally responsible
manner and in accordance with the risks involved.

that we use for management and which we publish

Waste is to be collected and recorded in accordance withregularly.

environmental rules, and recycled where possible. Waste

As an enabler, Jenoptik not only enables customers tomake a contribution to more resource conservation andshould always be disposed of properly as permitted by
local facilities.

environmental protection, but we also support the

Jenoptik Integrity Code45

5. Compliance & Ethics – the benchmark for our conduct in the
Jenoptik market environment
5.2 Sustainability and environmental protection
How is Jenoptik committed to protecting the

Why is environmental protection importantenvironment?

at Jenoptik?

Our contribution:▪

The term “environmental protection” refers to all measuresthat are useful for the protection of nature and human

Only by acting in an environmentally conscious manner,
especially in the corporate environment, can we conserve

health. At Jenoptik, environmental protection encompasses

limited resources and thus preserve our natural livingin particular the topics of energy and emissions

environment. From a business perspective, measures to savemanagement, water and wastewater management, wasteenergy and resources lead to considerable cost savings inmanagement as well as contaminated sites andthe medium and long term, even if investments have to besustainability. We at Jenoptik also see it as our responsibility

made first.

management, energy management andhazardous materials management.
▪

We are required to save energy, use resources
sparingly and efficiently, and to actively

cooperate in corresponding controls, audits,reviews and inspections.
▪

to grow sustainably in harmony with the environment andsociety and to use resources efficiently at all locations. As a

We actively operate systems for environmental

We always consider and promote environmental
compatibility in the development, manufacture,transport, use and disposal of our products.

manufacturing company, our focus is on efficient resource

management in order to reduce energy consumption and▪

We strive to constantly minimise waste andcorresponding greenhouse gas emissions as far as possible,

emissions to air, water and soil and each of us

to use raw materials sparingly and safely and to avoid

makes our own individual contribution to this.

hazardous waste as far as possible.

▪

We endeavour to keep the impact of our
products and services on the environment as low

as possible and drive forward the continuous
prevention and reduction of pollution.

CC Investor Relation & Sustainability

Jenoptik Integrity Code46

6Compliance with the
Jenoptik Integrity Code

6. Compliance with the Jenoptik Integrity Code

Reporting channels andcontact persons

Training

Consequences andInternal control systemfollow-up measures

Jenoptik Integrity Code48

6. Compliance with the Jenoptik Integrity Code
6.1 Prevention: Trainings
Jenoptik firmly believes that regular training and the continuous
sensitisation of our staff members to ethical and compliancerelevant topics are an investment in the future. Only those whoknow our guidelines and values and are regularly reminded ofthem will behave in accordance with them.

Jenoptik offers all staff members easy access to training
programmes via its own learning management system SAP
SuccessFactors, which is an ethics & compliance programmethat focuses on values, culture and the learner experience. CC
Compliance & Risk Management ensures that the courses
offered are adapted to the needs of the target groups within theworkforce. As Jenoptik employees, we are committed to regularparticipation in the assigned courses.

Jenoptik Integrity Code49

6. Compliance with the Jenoptik Integrity Code
6.2 Internal control system
The internal control system is the responsibility of Jenoptik's

Managers and employees are obliged to continuously

management.

monitor the effectiveness, efficiency and safety of theprocesses for which they are responsible, as well as to carry

The fulfilment of the obligations arising from this Integrityout planned control measures in a timely manner andCode and from process requirements and otherdocument them in a comprehensible manner.

specifications is carried out in all companies and in all

business processes by means of suitable procedures and

CC Internal Audit monitors Jenoptik's internal control system

controls that are appropriate to the respective risk and are

independently of processes. To this end, the effectivenessestablished by management.

and appropriateness of control measures are reviewed on arandom basis, on a case-by-case basis together with internaland external expertise.

Jenoptik Integrity Code50

6. Compliance with the Jenoptik Integrity Code
6.3 Reporting channels and contact persons
Any staff member with questions, concerns or doubts

A reporting system is also available to all Jenoptik

regarding this Integrity Code can contact the relevant

employees on the intranet and internet for reporting

contact person in confidence. This also applies in the event

significant violations where confidentiality must beof violations of this Integrity Code as well as laws, legal

maintained. The online form provided can be accessed on

regulations and internal guidelines and process descriptions.

the intranet under the search term "whistleblower system“.

▪ Jenoptik whistleblower system▪ by e-mail to compliance@jenoptik.com

The responsible contact persons can be people from theThis reporting channel is also available externally via the
Jenoptik website.

immediate working environment, for example supervisors,

Our reporting channels:
Reports can be submitted in the following ways:▪ or by telephone or e-mail directly to− the Director Compliance & Risk Management

the works council or management, as well as the Director

Alternatively, the external reporting office of the Federal

and Human Rights Officer Thomas Glassl at

Compliance & Risk Management or the Director Internal

Ministry of Justice is also available at their website in the

Audit.

event of violations of the law. It should be noted that the+49 3641 65-2235; +49 151 58771523 |thomas.glassl@jenoptik.com; orprotection afforded by the Whistleblower Protection Act− the Regional Compliance Officer, Chris Qu, forIf employees are unsure whether actions or behaviour could

only applies to information provided via the designated

the Asia-Pacific region at +86 021 38252380

violate the principles of this Integrity Code, they can get inreporting offices or by contacting CC Compliance & Risk

243 | chris.qu@jenoptik.com; ortouch with the contact persons named in the individual

Management directly. Every report is checked and followed

sections and discuss the next steps with them.

up consistently and confidentially.

▪ by post to JENOPTIK AG, CC Compliance & Risk
Management, Carl-Zeiss-Strasse 1, 07743 Jena,
Germany▪ to external reporting offices in accordance with theWhistleblower Protection Act

Jenoptik Integrity Code51

6. Compliance with the Jenoptik Integrity Code
6.3 Reporting channels and contact persons
Any pressure or other reprisals against whistleblowers oragainst as a result of their report, they should also contact

other persons who help to promote correct behaviour will

CC Compliance & Risk Management via the channels

not be tolerated. Until the violation has been proven beyond

mentioned above.

doubt, the persons concerned are presumed innocent.
The protection and confidentiality of whistleblowers,

Each report should be reported via one of the reporting
channels specified by Jenoptik, so that whistleblowers canaffected persons and the employees involved inbenefit from full protection under the Whistleblower

investigating the report is a priority for us. Jenoptik prohibits

Protection Act. Only in this way can CC Compliance & Risk

any form of reprisals (e.g., adverse actions underManagement ensure that whistleblowers are adequately

employment law, such as denial of a pending pay increase,protected.

disciplinary action, threats, intimidation or other sanctions)for good faith reporting of a violation or other cooperation

Intentionally making false reports with malicious intent isby employees in internal investigations and does notitself serious misconduct, which in turn leads totolerate such actions or in any respect.

investigations and measures. Such measures as aconsequence of deliberate false reports do not constitute
In some cases, sanctions can also take subtle forms (e.g.
transferring a person or limiting opportunities/

retaliation.

responsibilities or any form of harassment anddiscrimination) aimed at penalising a person for making areport. If whistleblowers feel that they have been retaliatedJenoptik Integrity Code52

6. Compliance with the Jenoptik Integrity Code
6.4 Intervention: Consequences in the event of violations
Jenoptik does not tolerate any violations of this Integrity

A detailed description of the process can be found in the

Code and necessary measures and consequences will be"Procedural Description for Whistleblowing under the

taken in the event of non-compliance. Jenoptik emphasises

German Whistleblower Protection Act (HinSchG) and thethat these measures and consequences follow the principle

German Supply Chain Due Diligence Act (LkSG) ", which isof proportionality and are appropriate, suitable andavailable both on the intranet and on the internet.

Our contribution:▪

Integrity Code or legal requirements
immediately.

necessary in individual cases.
Where compliance breaches are established, consequences

We undertake to report serious violations of this▪

We can contact our direct supervisor. This

The internal assessment of compliance violations is carried

under employment law may follow, depending on theout by the Director Compliance & Risk Management and/or

ensures that complaints are checked locally,

severity of the breach. Consequences under criminal law are

the Director Internal Audit or by authorised employees, if

also possible. Staff members who report possible breaches

necessary with the support of external partners. All reports
are treated with absolute confidentiality and information istaking local rules into account, and prompt
measures are taken to rectify any breach of thein good faith will suffer no disadvantage, unless theyrules or other misconduct.

only passed on a "need-to-know" basis.

themselves are involved in the breach.

▪

We can also contact the responsible HR business
partner if we have any questions or are unsure.

▪

We can also contact the works council in case ofconcerns or uncertainties.

Jenoptik Integrity Code53

7

Scope, version & contact person

7. Scope, version & contact person

Scope of application

VersionContact person

This Jenoptik Integrity Code applies to all Jenoptik companies

Jenoptik Integrity Code Version 1 (01/2024)

JENOPTIK AG · Compliance & Risk Managementin which JENOPTIK AG directly or indirectly holds a majority

Carl-Zeiss-Strasse 1 · 07743 Jena · Germany

interest. It also applies to companies or joint ventures in which

T +49 3641 65-2235 · compliance@jenoptik.com

Jenoptik companies hold more than 50 % of the shares orvoting rights or to companies which operate in the market

under a Jenoptik brand name. Representatives of Jenoptik inaffiliated companies or joint ventures should ensure that any
form of anti-competitive behaviour in business activities isprevented within the scope of contractual or company law

possibilities.

Jenoptik Integrity Code55