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Code of Business Conduct and Ethics
for all PM-International© 2024 by PM-International, Luxembourg | PM_BusinessConductEthics_CORP_2024_II_D7 | Valid as of 04/07/2024

Code of Business Conduct and Ethics

Table of Contents
Message from CEO & Founder

3

4. Confidentiality and Privacy

7

Vision statement

4

5. Passion for our Team Partners

7

1.

Who we are and what we believe in4

Trust and respect for individuals

7

Our Culture and Values

4Conduct towards customers

7

Our Customers

4

Concurring Distribution Activity 8

Our responsibility

4

6. What about Corporate Governance?

8

Our communication

4Policies

8

Our motivation

4Fraud and Bribery8

Our CODE

4Corruption

8

2. Our social engagements

5Conflicts of interest

8Mission statement

5Fair competition

9Charity

5Sports marketing3. Our Employees

7. How we care about the Environment

95

8. What we do to guarantee respect of the CODE

96

9. Updates

9

Respect in the Workplace6

Our employee’s human rights

6

Environment, Health and Safety

6Equal Opportunity 6

Discrimination

6Anti-Harassment

7Contact information:Legal & Compliance Departmentcompliance@pm-international.com

2Code of Business Conduct and Ethics

Message from CEO & FounderDear PM-International Family,
We at PM-International are creating and maintaining a culture of integrity and compliance in all businessactivities, in all places, and at all times. We want to strengthen our organization’s commitment to creating anorganizational culture of ethics and respect.
We want to be known for our ethical leadership and our core values, as well as our PremiuM company withPremiuM products. We want to be a company where our employees are proud to work, our customers keep
enjoying our products, our team partners want to be part of and our suppliers want to do business with.
In our company, we strive for high integrity and high performance–this is why we have created a Code of BusinessConduct and Ethics (the “CODE”).
Here you will find all the information regarding our responsibilities as part of the PM-International Family. These
guidelines are intended to help us make the right choices and stimulate awareness of ethical issues that we may
encounter on our day-to-day business. Bear in mind that we are all expected to use our own judgement anddiscretion, having regard to these standards, to determine the best course of action for any situation.
This CODE is a resource for all of our directors, employees, customers, suppliers, Team Partners and sponsors
who represent us and are part of the PM-International Family (the “Stakeholders”).
If a situation arises that is not specifically covered in the CODE or if you have any concerns or questions, pleasecontact your management or contact the Compliance Department.
Please read the Code of Business Conduct and Ethics carefully. Remember each of us is responsible forPM-International’s reputation.
Thank you for your commitment to maintaining the highest standards of integrity and performance

Rolf Sorg
CEO & Founder3

Code of Business Conduct and Ethics

VISION STATEMENTWorldwide market leadership in the development
and distribution of high-quality products for health,fitness and beauty.

1.

Who we are and what we believe in

OUR CULTURE AND VALUESOUR COMMUNICATION

We are a company of strong values and ethics.

Openness, honesty, courage, the ability to accept
criticism, trust and straightforwardness enable us tocommunicate openly without fear.

Performance and commitment are crucial to achieving
our goals and everyone contributes to this. We canonly give our values and goals content throughassimilation and loyalty to PM.

OUR CUSTOMERSThe customer is the most important person in ourbusiness. Every day we work to recognize their needs
and even exceed their expectations! We always offer
our customers a solution as a discussion won is abusiness lost.

OUR RESPONSIBILITY
The title isn’t what counts but our daily performance.
Each of us is valuable and always willing to takeresponsibility.
Each of our Stakeholders reflects the image of PM, so
all of them should be reliable in professional mattersand act with personal and professional integrity.

We learn from our mistakes as well as tackle and solve
challenges together.
The decisions made are always shared with one
another.

OUR MOTIVATIONAs an example for others we live what the “PM” in
PM-International stands for: PremiuM.
For that, we all do our best in every area, every day –each individually and everyone together!

OUR CODEOur Code of Business Conduct and Ethics is a key
resource to Ethics and Compliance information at PM.
It contains helpful answers to questions, tips and red
flags to assist our PM-International Family in applying
our shared values in situations that may come up in
day-to-day business.
PM is an international company with offices in over 44
countries. The CODE cannot contain policies relevant
to every country. Remember there are other policies
and regulations that shall be followed and have to beenforced. Where the laws of a country in which PM
is present or represented are stricter than the rules
contained in this CODE, the local laws apply.

4Code of Business Conduct and Ethics

2.

Our social engagements

MISSION STATEMENT
Improve life quality worldwide through premium
experiences.
CHARITY

SPORTS MARKETING

PM is committed to making the world a better placebeyond its day-to-day business.

We have been working closely and confidently withvarious sporting associations, national teams andworld-class athletes for many years.

Therefore, we have built up our number of active
sponsorships for children in need to over 6000, some
now on every continent in the World.
Everyone within PM is helping to make a better life
possible for people everywhere in the world: ourcustomers and our business partners. A portion of theprice of every product sold is dedicated to making it
possible for those children to get an education andgain access to medical care and helping whole village
communities on the long term: “aid to self-aid, “RolfSorg said and his wife Vicki Sorg added „and it is great
to see how everyone is pulling together, and what wehave already achieved.“Among our partners are Association of Tennis
Professionals (ATP), Alpine Canada Alpin (ACA), AustrianSki Association (OeSV), Austrian Sport Aid Foundation(ÖSH), Belgium Handball Association (URBH),
Finnish Athletics Federation (SUL), German Athletics
Association (DLV), the German Ski Association (DSV),
German Ice Hockey Federation (DEB), Association ofGerman Cyclists (BDR), Italian Basketball Federation(FIP), Luxembourg Basketball Federation (FLBB), Korea
Paralympic Committee (KPC), Korean Golf Association(KPGA), Korean Table Tennis Federation (KTTA), Korea
Wrestling Federation (KFW), Olympic Base Hamburg/
Schleswig-Holstein (HH/SH), Spanish Handball
Federation (RFEBM), Swiss Handball Association (SHV)and Swiss Sport Aid (SHH). The quality and standardsof our FitLine products and our exemplary support inelite sports has led to us being the go to nutritional
supplements brand worldwide.
As a company, we have voluntarily agreed to have
all the FitLine nutritional supplement products tested
regularly for doping-relevant substances.
More information under: www.koelnerliste.com.

5Code of Business Conduct and Ethics

3.

Our Employees

RESPECT IN THE WORKPLACE

EQUAL OPPORTUNITY

Everyone in PM shall behave in a respectful manner
towards others.

We take pride in the diversity of our workforce, whichbrings together staff from varied backgrounds, culturesand experiences. We embrace this diversity and view it
as an advantage.

We are expected to maintain a climate of friendlinessand harmony. The conduct of an employee may not
impair the reputation of PM or disrupt the harmonious
working climate.
Mentoring and motivating are actively encouraged.

OUR EMPLOYEE’S HUMAN RIGHTS
PM is present or represented in many countries and
we are particularly careful about the respect of theFundamental Conventions of the International Labor
Organization, such as, notably, the prohibition of childlabor and forced labor, the freedom of association, butalso promotion of diversity, women’s rights and theright to equal remuneration.
In our daily business, we take the following steps toensure compliance with these principles:

We strongly commit to promoting equality and theprinciples of social justice, respect and freedom ofexpression.

DISCRIMINATION
PM is a discrimination-free environment wherepeople’s differences are worth and rights are respected.
Discrimination can refer to any kind of direct or indirect
negative action or attitude towards any form of
diversity including but not limited to:•Gender•

Sexual orientation•Ethnicity or nationality•

We do not tolerate unfair treatment.

•Religion or beliefs•

We do not accept underage labor.

•Age

•

We limit work to fair working hours in adherence
to the applicable Labor Laws and Regulations ofeach country.

•Disability•

Medical history•

Marital status•

We promote equal employment and selfemployment.

ENVIRONMENT, HEALTH AND SAFETY
All of our employees have a right to a healthy, safe
and secure working environment and safety at work
depends on all of us.

PM engages in preventive, as well as affirmative actionto ensure equal opportunity including hiring, training,performance evaluations, promotions, compensation,
benefits and termination.
PM will strictly refrain from demonstrating bias orprejudice towards individual differences which will bevalued and protected.

We ask our employees and visitors to follow all safety
guidelines and immediately report any act or threat ofviolence, unsafe working conditions, health hazards, orworkplace accidents.

6Code of Business Conduct and Ethics

ANTI-HARASSMENT
We are committed to providing a workplace free ofharassment. All our Stakeholders are expected torespect the personal dignity, private life and personal
rights of each individual.
Harassment, bullying and discrimination take manyforms, including but not limited to:•4.

Unwelcome remarks, gestures or physicalcontact.

Display or circulation of offensive, derogatory
or sexually explicit pictures or other materials,including by email and on the Internet.

•Offensive or derogatory jokes or comments.

•Verbal or physical abuse or threats.

We do not tolerate any use of violence or threatening
with the use of violence or physical punishment.
We do not tolerate sexual advances, actions orcomments, racial or gender-based jokes or comments,
or any other comments or conduct that create,encourage or permit an offensive, intimidating or
inappropriate work environment.

Confidentiality and Privacy

The protection of confidential company information, as
well as nonpublic information entrusted to us by ourStakeholders, is essential for our company’s success.
Confidential information can be any information, in
whatever form, which is not public, i.e. not disclosed inany media that is publicly accessible.
We should use confidential information only forbusiness purposes and disclose it only to those whoare authorized and have a need to know.

5.

•We request all our Stakeholders to protect ourconfidential information and proprietary data aspart of our business relationship. This obligation ofconfidentiality continues even after the business
relationship between the Stakeholder and PM ends forany reason.
We are committed to protecting the privacy of
everyone with whom we do business, including ourStakeholders. We each have the responsibility tocomply with our privacy and security requirements.

Passion for our Team PartnersWe encourage our Team Partners to safeguard andpromote the good reputation of PM and its products
and avoid all deceptive, misleading, unethical orimmoral conduct or practices.
We ask our Team Partners to always act as anindependent and responsible entrepreneur and to avoid
any possible appearance of acting as an employeeof PM or of being entitled to make declarations in thename of PM.
Everything a Team Partner says about PM andour products has to be in accordance with PM’s
stipulations, especially those in the product catalog, on
the product labels and in other product information. On
no account may a Team Partner attribute therapeutic orhealing properties to our products.

TRUST AND RESPECT FOR INDIVIDUALS
We treat our Team Partners as we treat one another,with dignity and respect. We respect their differences
and understand their cultural backgrounds.

CONDUCT TOWARDS CUSTOMERSWe encourage our Team Partners to:•Refrain from deceptive or unfair sales practices.

•Provide accurate and complete productdescriptions and refrain from using comparisons
which are likely to mislead or which areincompatible with principles of fair competition.

•Give accurate and understandable answers toall questions from customers concerning theproduct and the offer.

•Only make promises concerning the products
which are authorized by PM.

•Inform customers if the products ordered areunavailable.

•Respect the privacy of customers.

•Not unfairly denigrate another company, its
products, its sales and marketing plan or any
other feature of that company.

7

Code of Business Conduct and Ethics

CONCURRING DISTRIBUTION ACTIVITY
Exercising another distribution activity can pose apotential conflict if it competes with the work a Team
Partner does for PM, is in a similar business as PM or
if the other company offers goods or services throughpersonal direct marketing or via a network marketingsystem.

6.

We ask our Team Partners to keep such other activities
completely separate from their activities for PM andour products.
No Team Partner should offer our products together
with goods or services of another company or cause
other Team Partners of PM to purchase goods orservices from the other company in any way, or to startan activity with such other company.

What about Corporate Governance?

POLICIES

received or given by PM in exchange for personal
business courtesies.

PM adheres to the codes and policies establishedby our partner organizations and the Direct Selling
Associations in which we are a member.

We ask all our Stakeholders to avoid any behavior
which could be interpreted as fraud or bribery. Our
Stakeholders should lead by example.

FRAUD AND BRIBERYCONFLICTS OF INTEREST

PM strictly prohibits any type of fraud or bribery.

Everyone at PM is expected to avoid any personal,
financial or other interests that might affect thecapability to perform the job duties or that may bedamaging to PM. We have to avoid any relationshipor activity that might impair, or even appear to impair,
our ability to make objective and fair decisions whenperforming our jobs.

Fraud involves deliberate, intentional deception ormisrepresentation of information for personal gain.
Examples of fraud include theft of cash, checks, orproperty; manipulation of accounting records.
A bribe is the giving or accepting of money, fees,commissions, credits, gifts, favors, or anything of valuethat is either directly or indirectly provided in return forfavorable treatment.
We avoid any actions that create a perception thatfavorable treatment of outside entities was sought,

We will always act in the best interest of PM.
Determining whether a conflict of interest exists is notalways easy to do. Before engaging in any activity,transaction or relationship that might give rise to aconflict of interest, employees have to seek review fromtheir managers or the Compliance Department.

8Code of Business Conduct and Ethics

FAIR COMPETITION
We are dedicated to ethical, fair and vigorouscompetition. None of our Stakeholders should
participate in any activities which aim to achievecommercial advantages through illegal or unethicalpractices.
When conducting PM business, we all have to:•

Avoid making false and misleading statements
about competitors.

•

Respect the property rights of others.

•Not acquire or seek to acquire by impropermeans any of competitor’s trade secrets orconfidential information.

7.

•

Not induce a third party to breach an existing
agreement.

•Not discuss pricing, production or markets withcompetitors.

•

Never act in a manner that could be seen as anattempt to exclude competitors or control themarket.

Sharing any type of information such as pricing, costs
or marketing plans with competitors can lead to theappearance of price fixing, territorial division or othertypes of manipulation or distortion of the free market.
In most countries, there are very strict laws in this area
which we need to be aware of and comply with.

How we care about the Environment

PM conducts its worldwide operations in a manner thataims to preserve the natural environment.

the consequences of their actions on humans, theenvironment and society.

We respect the environmental laws, regulations andpermits in the countries in which we do businessand encourage all our Stakeholders to consider

We strive to conserve water and other natural
resources and manage waste properly.

8.

What we do to guarantee respect of the CODE

It is PM’s desire to establish transparent and flexible
communication paths. Communication creates work
conditions that are favorable to productiveness and aperfect environment.
We encourage everyone to speak freely and openly
about significant matters and promote reporting of

9.

non-compliant behavior via our Whistleblowing System
which is accessible for everyone via our homepage
www.pm-international.com.
Alternatively, any non-compliant behavior may also bereported to us via e-mail at
confidential@pm-international.com.

Updates

PM-International may amend this CODE from time totime as it deems necessary or appropriate.

9