­Continental
Code of Conduct 2019www.continental-corporation.com

Continental Code of Conduct 20192

Continental Code of Conduct 20193

Dear Employees,
In 2019, we revised our Continental Code of Conduct (“Code of Conduct”). In this new edition, we describe the framework of our Continental values alliance for top value creationin greater detail. This alliance is based on our shared vision and mission, our four corporate
values of Trust, Passion to Win, Freedom to Act, and For One Another, as well as the sustainability of our actions.
The Continental Code of Conduct is an integral part of our global corporate culture. It applies throughout our organization. It guides our actions in accordance with laws, regulations and internal guidelines. This gives each of us greater clarity, security, and freedom ofaction in our own behavior.
We win by fair means. That is our passion to win. Illegal, unethical or irresponsible behavior does damage to our organization. It destroys trust. It undermines our success andgood reputation. We earn the trust of our customers, business partners, employees, andall other stakeholders primarily through integrity and reliability. Only in this way can wecreate value for all stakeholders, ourselves included. And by doing so, we can win in global
competition with our products, systems, and services.
We foster our corporate value For One Another in our worldwide Continental team. We
promote human rights and fair working conditions. We have committed ourselves to having working environments free of discrimination. Our diversity provides us with a varietyof perspectives, which in turn are the source of our capacity for innovation. With them
we enhance our performance and strengthen our team spirit.
It goes without saying that laws and regulations are to be obeyed. Only sustainable andresponsible actions make us fit for the future. In this regard, we conserve resources andpromote climate and environmental protection. We live up to our responsibility towards
our stakeholders and society. This applies to each and every one of us personally. In ourvalues alliance for top value creation, everyone takes responsibility for their actions andbehavior. Together we make a significant contribution to a healthy and successful organization, and a healthy world.
Please contact our Compliance organization with questions and suggestions.
It is your reliable partner for winning fair. And winning fair is what counts!

Hans-Jürgen Duensing

Dr. Ariane ReinhartFrank Jourdan

Dr. Elmar Degenhart

Helmut Matschi

Christian Kötz

Nikolai Setzer

Wolfgang Schäfer

Andreas Wolf

Executive Board
Continental AG

Continental Code of Conduct 2019

I. Preamble
Continental is committed to honesty andintegrity.
As described in our vision and mission
Continental is aware of its role in society
and the responsibility that comes with it toactively contribute to sustainable development. We are convinced that our company
values (BASICS) “Trust, Passion to Win, Freedom to Act, For One Another” allow us tocreate a sustainable value for all our stakeholders and the societies in which we operate. For Continental this means to act sustainably and responsibly, comply with laws
and regulations, save resources and promote the protection of the climate and theenvironment while acting responsibly towards our employees, partners, suppliers,
customers and society in general. We
strongly advocate for the implementationof the UN sustainable development goals.
Continental is committed to the United Nations Global Compact and supports its ten
principles on human rights, labor standards, environmental protection, and anti-corruption.
Continental recognizes that legal and cultural requirements vary in a global market.
This Code of Conduct, however (hereinafterreferred to as “Continental Code of Conduct”), confirms important standards which
serve – in addition to THE BASICS – as thebinding foundation for Continental’s activities worldwide.
Continental’s Code of Conduct mandates
that every employee, manager, executive,
and member of the Executive Board takes
responsibility for her or his actions and behavior, and aims to provide appropriate
guidance for our daily business. Furthermore, it outlines the ethical goals and prin-4

ciples for our business and the way wewant to work together.
Continental reserves the right to adjust thisCode of Conduct if developments require
it. Any adjustments will be publicized within
the corporation. The governing version will
be published on the Continental website
and on the intranet.

II. The Rules, Explanations,and Examples
Continental’s Code of Conduct contains
basic rules with which we must comply,
as well as explanations and examples. The
explanations and examples are not exhaustive and are intended for illustrative purposes only.

1. Application
The Rule:
Continental’s Code of Conduct applies toContinental AG and all of its subsidiaries, including minority holdings in companies
where a company of Continental Corporation exercises management control (hereinafter collectively referred to as “Continental”
or “Continental Corporation”).
Further, Continental’s Code of Conduct applies to all employees, executive staff, executive directors, and the members of the Executive Board (herein referred to as “we”,“our”, “ourselves”, “you”, “your”, “yourself” or“us”, as appropriate).
In addition, the term “Continental rules”
covers all approved or published internal
policies, manuals, standards and instruc-Continental Code of Conduct 2019

tions of the respective level according to
the definitions of the “House of Rules”(Continental at a Glance > Guidance andRules > All Continental Rules). Separately
guidelines and instructions are in place.
Explanations:
The Continental Code of Conduct applies
to all legal entities of Continental Corporation, regardless of form, country of domicile
or operation, or location. Furthermore, itapplies to all of their employees, regardlessof their position, function, or level of employment, as well as to all members of thecorporate bodies of those entities.
Example:Continental’s Code of Conduct applies forexample to, without limitation, Continental
Automotive GmbH, Germany, Continental
Automotive Czech Republic s.r.o., Czech
Republic, Continental Tyres Ltd., UK,
Continental Tyre South Africa (Pty.) Ltd.,South Africa, Continental Tire the Americas,
LLC, USA, Continental Automotive Corporation (Lian Yun Gang) Co., Ltd., China, Benecke-Kaliko AG, Germany and Elektrobit
Automotive GmbH, Germany, all of theiremployees, and members of their corporate bodies.

5

No one should engage in any behavior that
one reasonably believes would violate theContinental Code of Conduct. Behavior that
violates the Continental Code of Conduct
may also violate applicable local laws.
Non-compliance with either can result in
disciplinary action, up to and including termination of employment.
Explanations:
The rules of Continental’s Code of Conduct
do not cover every issue that may arise.
Rather, these rules outline basic, mandatory
principles to guide you in your day-to-day
work.
If the application of the Continental Code of
Conduct appears unclear or raises further
questions, it is your duty to use good judgment and common sense. You can clarify
the requirements of the Continental Codeof Conduct with your supervisor, Human
Relations Department, Law Department,
Compliance Department, or Compliance
Coordinator. In case of any questions, contact information of the departments to be
involved can be found on the Continental
intranet.

3. Responsibility for Our Actions andBehavior
2. Compliance with the Continental Codeof Conduct
The Rule:
We commit ourselves to act in compliancewith Continental’s Code of Conduct and acknowledge the rules established therein as
mandatory and as an integral part of thedaily work of us all. Violations of our Codeof Conduct will not be tolerated (“Zero-Tolerance”).

The Rule:
We take personal responsibility for any andall of our actions and behavior and use ourbest judgment in all matters affecting
Continental.
Explanations:If you doubt or are uncertain about adirective you have received from yoursupervisor, you may contact your Human
Relations Department, Law Department,or Compliance Department to determineContinental Code of Conduct 2019

whether the directive is in compliance with
the Continental Code of Conduct or otherContinental rules as well as guidelines or instructions.

4. Compliance with Laws, Regulations,and Continental Corporate Rules, Standards and Instructions
The Rule:
We will comply with the laws and regulations applicable in the countries in which
we operate. In addition, we observe all
Continental rules, guidelines and instructions.
Explanations:
Compliance with applicable laws and regulations is mandatory. As such laws and regulations are diverse and may differ fromcountry to country, they cannot be specifically listed in this Continental Code of Conduct.
The violation of applicable laws and regulations, and consequently the Continental
Code of Conduct, may result in criminal
sanctions, fines, a loss of reputation forContinental, and personal sanctions.
In case of any questions or uncertainty
whether certain behavior is acceptable,please contact your Law Department, Compliance Department, or with respect to aninternal guideline or policy, the department
responsible for it.
Examples of Continental’s rules:
Continental rules are, for example,
the policies and manuals on:›› authorized signatories›› financial investments›› record retention

7›› standard by-laws›› product integrity›› information security
Example 1:
You would like to enter into a supply contract with a supplier regarding plastic shells
for keys. The negotiations are very toughand take a very long time. You have a customer mandated deadline to deliver the finished product in just two months. To meetthe delivery date, you think about skipping
the Continental signature and approval process and signing the supply contract yourself.
Action desired:
Despite any time pressure, you must observe the governing Continental rules. The
Corporate Policy “Sign-off authority andExternal Representation (formally known as
P 20.1) establishes the approvals that must
be obtained for any and all contracts.
Always observe the “ four-eye-principle”.
Example 2:
You believe that safety standards may not
be met at one of Continental’s facilities.
What should you do?
Action desired:
Please contact the department responsible
for enforcing the affected standard, such as
the ESH representative, the Quality Department, or the Human Relations Department
to review the issue.

5. Respect for Human Rights and fairworking conditions
The Rule:
As a company and as individuals we holdthe responsibility to respect human rights
and fair working conditions. We would likeContinental Code of Conduct 2019

to actively contribute to their implementation by treating every colleague, employee,
future potential employee, supplier, customer, and every other person with whom we
do business, with fairness and respect. Theinternationally recognized standards of theInternational Labor Organization (ILO)
among others guide our work. At a minimum these include: Every employee has aright to freedom of association and representation of her or his interests throughelected representatives. We firmly reject
any form of child labor or forced labor. Any
form of harassment or physical as well as
psychological abuse will not be tolerated.
We jointly commit to creating a working environment free from any form of discrimination based on gender, age, race, skin color,social or ethnic origin, nationality, sexual
orientation, religious or political beliefs, or
any other characteristics protected by applicable law. We therefore speak-up about
inappropriate behavior actively and constructively and aim to solve differences collaboratively. If you feel that inappropriate
behavior is taking place, please contact
your local Human Relations or ComplianceDepartment.
We are proud of the diversity that our employees contribute to our company worldwide. Together we want to make the bestuse of diversity characterized, for example,
by gender, culture, or religion to promote
innovation and performance by contributing different perspectives. Based on the
United Nations “Women’s Empowerment
Principles“ which we have signed, we especially want to empower women to participate fully in the economies of all countries
and sectors, in order to strengthen the societies that we operate in.

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Explanations:
At Continental human rights, fair working
conditions and mutual respect symbolize
our corporate value „For One Another “. We
are convinced that advocating for the respect of human rights and fair working
conditions strengthens innovation, performance, as well as team spirit, consolidates
our relationships with customers, suppliers,and other stakeholders and promotes economic development in our markets and regions. Regardless of the cultural or legal parameters of every country in which we as acompany operate, every employee should
actively contribute to creating a trustingand safe work environment beyond hierarchies. Therefore, this rule applies to every
employee and all processes of the company. In case of concerns or suggestions regarding this, you can contact your local Human Relations or Compliance Department.
Example 1:
You are searching for a candidate to hire asa sales manager for the sales department.
You believe that the sales business is “malebusiness” and ask yourself if you should
consider only male applicants for the sales
manager position.
Action desired:
You are not permitted to search only formale applicants, nor may you reject the applications of female applicants just because
they are female as this is discrimination
based on gender. Your search must be focused on the qualifications, skills, and experiences of the candidates and how theymeet the essential requirements of this position regardless of a candidate’s gender.
Example 2:
You notice that a colleague is criticized regularly by his supervisor for his poor performance. Three weeks ago, the supervisor

Continental Code of Conduct 2019

started screaming at the same colleague,
audible to everyone, insulting him as being
too obese to properly conduct his work.
Action desired:Feedback on performance is an important
tool for the personal development of every
employee at Continental. However, thisshould always be given in a constructive
and appreciative manner. The describedbehavior can be classified as verbal abuseor psychological harassment and can resultin disciplinary and potentially legal penalties for the supervisor. Please contact the
local Human Relations Department or notify the Compliance and Anti-Corruption hotline (anonymously) anytime if you witness
behavior like this.
Example 3:
You hear rumors that a supplier with whomyour plant is working has employed childlabor at one of its production sites.
Action desired:
Please inform your responsible Purchasing
Department or contact the Complianceand Anti-Corruption Hotline. Although
there is a presumption of innocence, there
is a need for further investigation. We do
not tolerate any child labor, neither in ourown business nor within our Supply Chain.
If verified, the business relationship with the
supplier requires a re-assessment.

6. Health, Safety, Environment and Product Integrity
The Rule:
Safety and health are integral parts of our
responsibility and business activities. We
have a duty to take care of safety andhealth measures, follow the relevant regula-

9

tions and work instructions, and to use theprotective equipment required by law.
Environmental protection is a fixed component of our company policy. For us the
economy and the environment need not
be mutually exclusive. They form a basis ofsustainable value creation at Continental.
We are committed to the development andmanufacturing of safe products. With ourprocesses and products, we will make a
substantial contribution to the sustainable
use of resources, environmental protection,and climate protection. We strive to save resources by aligning our production, quality,and performance of our products with environmental soundness and by reducing
our consumption of energy, water, raw materials, and supplies.
All managers and employees are required
to comply with these standards on environment, safety and health (ESH). In case you
have any questions or comments regarding these topics at your workplace, pleasecontact your supervisor or if needed yourlocal ESH-manager or your Human Relations Department.
Example:During work, you are required to wear asafety helmet and safety boots. One day
while arriving at your workstation you realize you have forgotten to put on your safety boots. You ask yourself if you should goback to the changing area in the otherbuilding to retrieve them and put them on.
Action desired:
Employees are expected to adhere to safety regulations, this Continental Code of
Conduct, and to wear the required protective gear as required by their specific job requirements. Therefore, you are required toContinental Code of Conduct 201910

retrieve and wear your safety boots before
commencing work.

protect free and fair competition and ensure the best interests of the consumer areserved.

7. Fair Dealing

Example 1:
At a trade show, you meet by coincidence
a former colleague who now works for acompetitor. You revel in old memories,
when suddenly you are being asked whether Continental will adjust their prices fora certain product in light of the increaseof raw material prices. How do you react?

The Rule:
We will deal fairly and honestly with
Continental’s customers, suppliers, and distributors. We will also deal fairly and honestly with Continental’s competitors in advancing Continental’s business interests. We will
not spread unsubstantiated rumors or
make false statements about the competitors and/or their products or engage in other unfair practices intended to damage
competitors.

8. Compliance with Antitrust Laws
The Rule:
We will strictly obey all applicable antitrust
laws, including but not limited to, tradepractice laws and regulations dealing withmonopolies, unfair competition, restraintsof trade and competition, and relationships
with competitors and customers.
We are aware that violations of antitrust
laws may result in invalid contracts, criminal sanctions, fines, and harm toContinental’s reputation.
Whenever questions arise whether a situation complies with antitrust laws, please immediately consult the Compliance Department.
Explanations:
Like every corporation, Continental wishes
to increase its business and to become themost successful company in its markets.
This, however, must be done in compliancewith the laws. Antitrust law is designed to

Action desired:
You end the conversation and make clear
you are not allowed to talk about such issues with a competitor. Under no circumstances may you provide any information/
response to this question or any similar
question/conversation related to the exchange of commercially sensitive information with competitors. Inform the Compliance Department.
Example 2:
You receive a call from a customer (fromthe Automotive segment) with whom
we conduct business in similar sectors, requesting how Continental evaluates/assesses our suppliers. How do you react?
Action desired:
You explain to the customer that no information will be provided. Although the request comes from a customer, we conductbusiness in similar sectors, and we most
likely are competitors on the demand-side.
In case of doubts or questions, contact theCompliance Department.
For further information please see theContinental Manual “Antitrust Compliance”(located on intranet page: Continental at a
Glance > Guidance and Rules > Compliance> Compliance main page – get the full infor-

Continental Code of Conduct 2019

mation > Compliance Handbook & Guidances > Antitrust > Corporate Manual Antitrust).

9. Anti-Corruption
The Rule:
Our business relations are governed by integrity and we will strictly comply with allapplicable anti-corruption laws and regulations, including those focused on foreign
corrupt practices.
We work to build positive and collaborative
relationships with our customers, suppliers,
and stakeholders. While hospitality and tokens of appreciation can strengthen relationships, we will not use them to buy or
unduly influence business relationships ordecisions.
We will neither engage in, nor tolerate any
form of corruption, bribery, theft, embezzlement, extortion, or the use of illegal payments. We will not make any illegal payments or confer any other type of illegal
benefit on any individual, company, international organization, or public body for the
purpose of influencing the decision-making
process in violation of applicable laws.
We will not offer, grant, demand, or accept
bribes, illegal payments, payoffs, kickbacks,
incentives, or lavish gifts, entertainment, favors, or other benefits in exchange for business opportunities with or related toContinental’s business operations.
Violations of anti-corruption laws may invalidate contracts and result in criminal sanctions and fines. Any involvement in corruption harms Continental.
Explanations:
Corruption occurs when a person given a
position of trust by the public or by private

12

persons willingly abuses that power or trust
by exercising it contingent on promises or
receipt of undue benefits.
Giving and accepting incentives, gifts andfavors may be part of everyday businesslife. The most common benefits are meals
and invitations to events. For further details
on the acceptability of such benefits as wellas other typical anti-corruption related topics, see the Continental Corporate Policy
Anti-Corruption (located on the intranet
page: Continental at a Glance > Guidanceand Rules > Compliance > Compliancemain page – get the full information > Compliance Handbook & Guidances > Corruption Prevention > Corporate Policy Anti-Corruption).
The above rule on contributions does notprevent Continental or its employees from
communicating their views to legislators,
government agencies, or the general publicwith respect to legislation or governmental
policies or practices.

Example 1:
You have received a request for a pricequotation regarding the delivery of tires toan OEM. You recognize your competitors
have also been asked for a price quote. You
expect them to have better prices, andtherefore be favored by the OEM. You think
about inviting members of the OEM’s purchasing department, including their families, to a sports event with travel and accommodation expenses paid to give thema personal reason to favor Continental’s
bid.
Action desired:
Since such an invitation would reasonably
be seen to influence the OEM’s decision-making process, it is likely to be de-Continental Code of Conduct 201913

fined as corruption. Such an invitation
should not be offered. Study theContinental Corporate Policy on Anti-Corruption.

Cayman Islands and you are the only person authorized to access the account. You
have doubts and concerns regarding how
to react.

Example 2:Continental plans to have a new tire production plant in Country A. Building the
new facility requires several permissions
and concessions by the respective authorities. After waiting for the respective documents for several months, you ask yourself
if it is possible to accelerate the approval
procedure by giving an incentive to themember of the authority who is handlingthe application.

Action desired:
You should refuse the “special deal” and explain that such business behavior may violate the applicable laws and clearly violates
the Continental Code of Conduct. You
should also immediately disclose this proposal to your supervisor, Law Department,
Compliance Department, or Internal Audit.

Action desired:
Even if you have the legal right to have that
permission granted, such attempted influence on the decision-making process is –under the laws of most countries – definedas corruption and a clear violation of theContinental Corporate Policy on Anti-Corruption. You must refrain from this idea andstudy the Continental Corporate Policy on
Anti-Corruption. Please be aware that gifts
to or favors involving public officials, suchas people working for governmental bodies, require a critical evaluation and internal
scrutiny from the highest levels of the Compliance Department. In case of uncertainty
whether you are dealing with a public official, please contact the Compliance Department.
Example 3:
You work in the purchasing department,
and a potential trade agent you are dealing
with offers you a “special deal”: You are supposed to order specific services from him
at a higher amount than the offers of theagent’s competitors. The balance between
his offer and the competitors’ offers will be
paid to a numbered bank account in the

Example 4:
You work for the sales department. Due tovarious products competing with the product you sell, there are sales difficulties. A
customer makes you the offer to give him arebate for the product Continental desires
to sell to him. The rebate is within the margin you are allowed to give. He proposesthat regarding the balance between theusual price and the reduced price, theamount should be divided between the twoof you. He would provide you your share after each deal in cash. What should you do?
Action desired:
You should refuse his offer and explain thatsuch business behavior can be illegal, may
violate applicable laws and regulations, andclearly violates the Continental Code of
Conduct. You should also immediately disclose this proposal to your supervisor, Law
Department, Compliance Department, orInternal Audit.

10. Anti-Money Laundering
The Rule:
Continental is subject to certain obligations
under national anti-money laundering laws,
which may apply internationally. Hence,Continental Code of Conduct 201914

Continental Code of Conduct 2019

Continental entities must investigate questionable or dubious transactions and payments and monitor their business relationships.
Explanations:
Money laundering is the process of transforming the profits from criminal activity,for example tax evasion, into ostensibly legitimate assets. An increased risk exists under money laundering aspects if payments
are made by third parties and not the customer itself.
Example:You conduct business with a customer located in Country A. During the payment
process, the customer explains without any
plausible reason that a third party locatedin Country B will fund the costs. Do you accept this?
Action desired:
We at Continental generally do not accept
payments from third parties, especiallywhen the customer and/or the third party
are located in high risk countries. Please getin touch with the Law Department or Compliance Department. In case a payment already was made by a third party, it should
stay in the account as a payment which has
be refunded to the party making the payment and not to be processed as a payment of the receivables.

11. Conflicts of Interest
The Rule:
Our private interests and personal considerations shall not affect our judgment to
act in the best interest of Continental.
We will avoid any activity or situation that
may lead to a conflict between our privateinterests and Continental’s business inter-15

ests. If a potential conflict of interest exists,
please notify your supervisor, Law Department, or the Human Relations Department.
Explanations:Continental respects the rights of employees to engage in activities outside of theiremployment which are private in natureand that in no way conflict with or reflect
upon Continental and/or its corporate image. Thus, you will not maintain, directly or
indirectly, any outside business or financial
interests or relationships that conflict with
Continental’s interests or that may interferewith your abilities to fully perform your employment responsibilities in Continental’s
best interests.
The following situations may lead to a conflict of interest:›› You are employed by another firm whilein the employment of Continental, particularly if the firm is a competitor, customer or a supplier (or one that may
become a competitor, customer or a
supplier in the foreseeable future);›› You have a business relationship with acompany in which a relative has an ownership interest, is engaged in managing
or otherwise holds a substantial interestin the company;›› You hold substantial financial interests in,or are engaged in the management of a
firm that is a supplier or customer ofContinental;›› You speculate or deal in materials, equipment, or supplies purchased byContinental, or deal for your own accountin products sold by Continental;›› You borrow money from customers,

Continental Code of Conduct 2019individuals, or firms from which
Continental buys services, materials,
equipment or supplies, or with whom
Continental does business.
The list above are examples only and by
no means exhaustive.
Example 1:
Continental wants to assign a new supplier.
The supplier chosen is managed by yourbrother.
Action desired:
It may be acceptable for Continental to enter into a contract with your brother’s company. Disclose the relationship to both yoursupervisor and purchasing and make sure
not to be involved in the tendering process
or any decision related thereto. If uncertain,
contact the Law or Compliance Department.
Example 2:
You realize a supplier of Continental delivers defective products. You know the warranty period has not expired yet. However,this company is owned by your sister andyou think about not having such defects
remedied.
Action desired:
Ensure that you are not involved in thebusiness decision to enforce the warranty.
Before your sister‘s company was hired,
you should have disclosed the relationshipto your supervisor and all involved departments. In case of uncertainties, please contact the Law or Compliance Department.

16

12. Use of Continental Company Property
The Rule:
We use the corporate property ofContinental with due care and responsibility. Unless otherwise permitted in local
Continental rules, we use Continental’s corporate property only within our sphere ofbusiness activity.
Explanations:
The corporate property of Continental contains tangible assets such as products manufactured by Continental, production andoffice equipment, tooling, facilities, vehicles,
and intangible assets such as know-how
and intellectual property rights.

13. Data Protection and Cybersecurity
The Rule:
We will comply with applicable laws, regulations, and Continental’s rules, guidelines
and instructions concerning data protection and Cybersecurity.
Explanations:
Disregarding Cybersecurity and safetymeasures may have serious consequencessuch as loss of data, disclosure of confidential information and trade secrets, and theftor abuse of personal data. Therefore, incase you have any questions related todata protection, contact Continental’s dataprotection and Cybersecurity officers or
your Human Relations Department.

14. Confidential Information and Intellectual Property
The Rule:
The protection of confidential business information and trade secrets (“Confidential

Continental Code of Conduct 2019

Information”) is vital to the interests andsuccess of Continental. It is our responsibility to ensure Confidential Information
gained by virtue of our business activities
with Continental is held in strict confidence,
not improperly used, and not disclosed tofellow employees or third parties.
We acknowledge that if we improperly use
or disclose Confidential Information, we
might be subject to disciplinary action, up
to and including termination of employment, even if we do not personally benefit
from the disclosure. If we leave Continental,
we may not disclose or use Confidential Information and are required to return all
such property promptly, including without
limitation, Confidential Information.
Furthermore, we will respect the Confidential Information belonging to our suppliers,
customers, and other stakeholders and use
them only in accordance with applicablelaws and/or contractual obligations.
Explanations:
Confidential business information includes
any and all information and data, including,but not limited to the terms of contracts,
any kind of business, commercial, financial,intellectual property, customer or technicalinformation, and data disclosed between
business partners in connection with theirbusiness relationship or the definition, development, marketing, selling, manufacture
or distribution of products, unless available
from public sources. This includes, for example, information about personnel, customers, costs, price lists and sales information, collection policies, reports, financial
statements, salaries, and business operations. Confidential business information
may not be disclosed in any way, whether
orally, in writing, or electronically.

17

Example 1:
You have been in a contractual relationshipto Supplier A for several years. As the product’s quality has never been to your satisfaction, you decide to terminate the contract with Supplier A and enter into a contract for the same product with Supplier B
who delivers the product at a lower price.
After not being able to solve serious quality
problems, Supplier B asks you to provide
the detailed and confidential technical documentation you received from Supplier A.
Your customer asks your urgent attention
to solve the quality problems, but you are
not sure if you should honor Supplier B’s
request.
Action desired:If the technical documentation is considered Confidential Information of Supplier A,
you are not permitted to disclose or otherwise share such information with Supplier
B. Whether the technical documentation is
confidential depends on the contractual
agreement between Continental and Supplier A, and any confidentiality agreement
you may have entered into with Continental.
For example, Continental may have a confidentiality agreement or confidentiality
clause in the contract with Supplier A prohibiting the disclosure of such information.
Furthermore, it should be determined if theuse of the technical documentation is prohibited due to other reasons (e.g. copyrightor patent law restrictions).
Example 2:
Due to a technical error Continental inadvertently receives the bid of a competitor
taking part in an online bid organized by apotential customer of Continental. You ask
yourself if you should open the file.

Continental Code of Conduct 2019

Action desired:
You should not open or otherwise use
the file and you should send it back to
its sender.
Example 3:
During a business trip you do some business work on your laptop. Suddenly you
become aware that the person sitting next
to you on the plane is very interested inyour work, watches your screen observantly, and begins making notes.
Action desired:
You should immediately stop working on
your laptop until you may do so in a moreprivate setting.

15. Export and Import Regulations
The Rule:
We are required to comply with all applicable export and import laws, including without limitation, sanctions, embargoes, andother laws, regulations, government orders
or policies, including any guidelines of theContinental Executive Board controlling thetransmission or shipment of commodities
and technology by Continental.
Explanations:
There are situations where Continental
products, software, or technology cannot
be shipped or transmitted to certain countries due to an embargo, or other restrictions. If there are any license requirements,
Export Control must be involved to obtainsuch license.
If the application of an export or importregulation appears unclear or causes morequestions, you must clarify the matter withthe department or person responsible forexport control or customs.

18

Example 1:
You are asked by a customer to deliverproducts to a new customer located in acountry which is subject to export restrictions. You do not know if you can or should
accommodate the customer’s request.
Action desired:
Please ask Export Control how to handle
the request. The ability to ship will dependon many factors, including the country thecustomer whishes you to ship to, the product being exported, how the product will
be used, and by whom.
Example 2:
You are employed by a Continental entity
located in the US and would like to deliverproducts from the United States to Israel
and Cuba, but do not know if you can. Whatshould you do?
Action desired:Before doing any kind of business directly
or indirectly linked with a sensitive country
you must contact Export Control.
Example 3:
You are working in Regensburg and arepreparing for a meeting in a Non-EU country. For presentation purposes, you intend
to bring samples of production material tothe meeting. Since the production material
is of rather small size, you think about oftransporting it with your hand luggage.
What do you do?
Action desired:
Please be aware that so called “Hand Carry”
scenario described above bears the risk ofcommitting customs/ tax evasion. Everymaterial that is exported or imported has toundergo proper customs declarations andexport control checks. For import, hand-­carried shipments are not allowed to passContinental Code of Conduct 201919

Continental Code of Conduct 2019

customs at the “green-channel”. Make surethat you educate yourself prior to your departure about all relevant export and import regulations (including export control)of the respective countries and inform your
Customs Department or Export Control.
Ensure you have all necessary documents(regarding export and import) prepared
and with you at the point of entry. These
explanations apply for onboard couriers as
well.

16. Tax Compliance
The Rule:
We are aware of our social responsibility tomeet our obligations with regard to taxes,
and we explicitly endorse compliance withnational and international legislation. We
ensure that taxes are paid correctly andthat our obligations to cooperate with authorities are fulfilled.
Explanations:
Our global operations and the development of new markets mean that we mustcomply with a raft of different regulations
relating to tax law. Observing tax regulations builds trust with customers, financial
authorities, and the general public. Any irregularities can cause significant financial
damage to Continental Corporation, also
seriously impacting the Corporation’s reputation and having negative consequences
for the employees responsible.
Example:You are responsible for booking certain
business transactions, such as general
overhead (maintenance expenses) and production costs, in the statutory financial
statements. One project exceeds certain
controlling parameters early in the financial
year. You therefore receive instructions

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to make an entry under maintenance expenses even though the transaction unquestionably relates to an investment andmust therefore be treated as capitalized
production costs.
Action desired:
Post the entry in line with legal requirements. All business transactions must be
correctly reported pursuant to commercial
law and tax regulations because theseaccounting records form the basis for tax
returns. Accounting errors could therefore
result in incorrect tax returns and leadto serious consequences under tax law
for the Company.

Continental Code of Conduct 2019III. Reporting of Violationsof the Code of Conduct andProtected Disclosure
Continental encourages people to raise
concerns in good faith, in confidence andwithout fear of reprisal.
Continental will not tolerate retaliation,
discrimination, or disciplinary action against
anyone who in good faith, raises reasonable
concerns of attempted, actual, or suspected misconduct or violation of any provisionof the Code of Conduct.
Violations of the Continental Code of Conduct can be reported via the Continental
Compliance and Anti-Corruption Hotline.
Continental takes every report seriously.
We will protect the identity of individuals
who want to remain anonymous at all
times. All submissions will be addressed.

Contact Information for the Complianceand Anti-Corruption Hotline:
International Number
0049 (0) 1802 38 44 27
Internet Link
https://continental.integrityplatform.org

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Continental Code of Conduct 201923

Continental Aktiengesellschaft
Vahrenwalder Str. 9, D-30165 Hannoverwww.continental-corporation.com
For all its subsidiaries© 2019PhotosNikolaj Georgiew, Hannover (Cover)Continental AG (Page 3)
Getty Images (Page 11), AdobeStock (Page 6, 14 & 19)