Compliance Mission Statement

“Only legally and ethically correct behaviour ensures sustainable
business success!

 

The key to sustainability lies in our corporate culture, which is characterized by our corporate values of innovation, quality, performance and character. The corporate value of character also includes the commitment to integrity and honesty as well as the commitment to consistent compliance with legal and regulatory requirements.
Both our employees as well as our business partners adhere to this standard. The trust shown to us by our customers, business partners and investors is confirmed not only by the reliability and high standard of our products and services, but also by the integrity of our entire operation. Violations of the laws, rules or our ideals result in corresponding consequences and sanctions.

 

Our corporate values are the guiding principle for our legally and ethically correct behaviour in business life. We expect each employee to implement our values responsibly and that we together thereby create the basis for a successful economic and personal future.

 

Our goal is to efficiently utilize the global economic challenges in a value-oriented manner as an opportunity to solidify and further expand our successful market position together.”

 

CEO of Aiger Group Switzerland AG

Code of Conduct

Definition and scope

The Aiger Group (Switzerland) AG has created a code of conduct that contains the compliance policies of our company and the guidelines for behaviour in day-to-day work. This content is not exhaustive and will be supplemented by tailored-to-suit guidelines and special work orders. The code of conduct is equally valid in all strategic business units (sbu) and companies that belong to the Aiger Group (Switzerland) AG as well as in all regions or countries. The Aiger Group (Switzerland) AG code of conduct is always to be applied in compliance with the respective national laws and regulations. In the event that the code of conduct deviates from mandatory national law, the national law shall take precedence. Compliance with all relevant laws and regulations in an international environment requires a high level of personal attention and, in cases of doubt about the legal situation, is to be clarified through professional consultation. Every employee, every manager and every executive member is bound by this code of conduct. The top executives confirm once annually in writing the conformity of their business behaviour with this code of conduct. The confirmation is entered into the personnel file.

Objective

This code of conduct should be a guide for all employees of the Aiger Group (Switzerland) AG to behave correctly in daily business life in the sense of the law, our internal rules and our moral concepts. It offers assistance as to how to proceed correctly on one‘s own authority in certain situations of business life in a proper legal and ethical manner. All employees are encouraged to meet this code of conduct on a daily basis. The top executives and members of the managing board exercise a role model function, are aware of their special responsibility as supervisors and actively exemplify the content of our code of conduct. All employees outwardly shape the company‘s reputation through their appearance and their behaviour. They therefore understand that they are representatives of the Aiger Group (Switzerland) AG and pay attention to an appropriate and positive outward image. A business transaction that contradicts our compliance guidelines that are represented in this code of conduct or in other company policies does not result in any sustainable benefit for our company, but rather can lead to considerable damage for the entire Aiger Group (Switzerland) AG group.

ObjecBehaviour compliant with the law and rulestive

The employees and executive management members of the Aiger Group (Switzerland) AG consistently and responsibly observe the respective national and international laws and regulations that apply to them as well as the group‘s internal guidelines and rules, including this code of conduct. In cases of doubt regarding the scope or the meaning of certain provisions, the respective supervisor, legal and compliance manager or, where appropriate, an external legal advisor are to be consulted.

Integrity

Under integrity, Aiger Group (Switzerland) AG understands the conformity of our external action with our inner values based on righteousness and fairness. Integrity represents a kind of inner moral compass and offers – for example in the case of loopholes – an aid for decisions and actions that correspond to our moral concepts and coincide with a general understanding of righteousness. The employees and top executives’ members of the Aiger Group (Switzerland) AG always ensure integrity in everyday work behaviour.

Fairness, general non-discrimination precept and behaviour towards each other. A working atmosphere characterized by fairness promotes motivation and efficiency. The relationships between top executives and employees at all levels in all strategic business units (sbu) and all regions are guided by fairness, mutual respect, openness and the common understanding of trustful co-operation. Any form of discrimination has no place in our corporate culture. We do not discriminate against or favour anyone based on gender, race, religion, age, disability, sexual orientation, national origin or other legally protected characteristics and do not tolerate any discrimination in this respect. The measure for assessing employees is their professional skills, their performance and their ethical behaviour.

Every employee is emphatically encouraged to actively contribute to an atmosphere of respectful cooperation in which any kind of personal harassment is prohibited. In particular, this includes workplace harassment, unwanted sexual advances, unwanted body contact, immoral propositions, humiliation of any kind as well as abusive, offensive or degrading jokes, comments and actions. Violence in any form, assaults at work, including threats and intimidation, as well as workplace bullying are prohibited in our company. Violations of these laws in particular result in corresponding measures and sanctions.

Confidentiality and trade secrets

The employees of Aiger Group (Switzerland) AG or companies and sbu, may not pass on to third parties confidential information without authorization, unless the information is not already known to the public. In particular, this includes technical data, financial data, operating data, customer information, file notes and other information that relates to the business of our group and its operational activities and future plans. Our inventions and our know-how are of fundamental importance for the long-term success of our company. This is why the employees of Aiger Group (Switzerland) AG must protect intellectual property against unauthorized access and knowledge by third parties. The intellectual property in particular includes trade secrets, confidential information, copyrights, trademarks and logos as well as customer lists and product specifications.

Anti-corruption

No employees may claim, promise or accept benefits – in particular invitations, gifts and other benefits – that, according to objective assessment, are likely to cause an unfair influence on business behaviour. The same applies for offering, promising or granting personal benefits – in particular invitations, gifts and other benefits – to third parties, especially to business partners and customers, that, according to objective assessment, are likely to cause an unfair influence on business behaviour. Even the appearance of such dishonest, passive or active influence is to be avoided. This is especially true when dealing with public officials or public employees.
Corruption is rejected in any kind of business dealings both domestically and abroad. We shall forego a business transaction and the achievement of internal targets if this can only be achieved by breaking the law.
The following are prohibited in particular:

Gifts and invitations by business partners within the scope of business relationships are exempted from the above prohibitions if they stay within the framework of common business hospitality, customs and politeness and do not violate any laws.
Violations of these laws in particular result in corresponding measures and sanctions. All employees deal with the resources provided to them by the company in a responsible, cost-conscious and careful manner. This is especially true for the financial means entrusted to them. Establishing or maintaining so-called „slush funds“ is prohibited.

Prevention of money laundering

Money laundering refers to the channelling of money or other assets that were acquired through prior criminal acts into the legal economic cycle. Employees shall distance themselves from businesses through which such a channelling is made possible or supported, for example, in the form of the receipt, exchange or transfer of illegally acquired money or assets. The employees of the Aiger Group (Switzerland) AG shall observe compliance with national and international laws and regulations to prevent money laundering.

Avoiding conflicts of interest

Employees and executive members are aware that mixing professional and private interests can be problematic. That is why employees and executive members ensure a clear separation of professional and private interests. Business or personnel decisions may not be made based on private interests or relationships. Possible conflicts of interest are to be immediately disclosed to the competent supervisor or to be resolved appropriately.

Donations and sponsorship

The implementation of donations or sponsorship actions requires the prior written approval of the competent supervisor or the managing board and is to be fully documented.

Data protection

Data protection refers the protection of the individual against the misuse of personal data. The basis for this is the individual‘s right to informational self-determination, which expresses that every person can in principle always decide which parts of his personal data should be accessible to whom and when. Employees must follow the relevant laws and company regulations with regard to personal data. The processing of personal data may only take place based on a legitimizing basis in compliance with the applicable laws. Identified violations of data protection regulations are immediately to be communicated to the supervisor or data protection officer.

Environmental protection

The Aiger Group (Switzerland) AG is aware of the ecological impacts of its business activity and feels committed to improving its environmental balance through preventative environmental measures and the use of environmentally friendly technologies. Every employee should protect natural resources and endeavour in his work to reduce to a minimum the load on the environment through material savings, energy-saving planning as well as by avoiding, reducing and recycling waste.

Health and operator safety

Employees deserve a safe and healthy working environment. The Aiger Group (Switzerland) AG therefore places the utmost importance on compliance with the health and occupational safety directives. The group strives to foster the physical and psychological well being of its employees. The Aiger Group (Switzerland) AG pursues health promotion as a key element for sustainable productivity and the quality of its services. The health and occupational safety policy at all locations worldwide also includes the prohibition of illegal drugs in the workplace.

System and product safety

Our systems are regularly examined and maintained. Our employees are thoroughly instructed, trained and supervised. Operational disturbances, accidents or faults can only be avoided if these measures are implemented.

Compliance organization

The Aiger Group (Switzerland) AG has a corporate compliance officer, CCO. The responsible chief compliance officer has a direct reporting path to the CEO of Aiger Group (Switzerland) AG. The office of the chief compliance officer is Plovdiv BG. His job is to build and lead a global compliance management system that is tailored to the specific needs of the Aiger Group (Switzerland) AG group, including all its subsidiaries. In addition, he is available as a contact partner and consultant for all questions regarding the topic of compliance.

Compliance with the code of conduct

Each employee is to be given this code of conduct. The top executives are responsible for ensuring that the content of this code of conduct is understandable by all employees. The code of conduct forms the basis for all internal regulations in the Aiger Group (Switzerland) AG that specify the code of conduct and therefore are also to be observed. To take into account regional specificities, regional guidelines may be provided with supplementary provisions, provided these do not conflict with this code of conduct.

Violations of the code of conduct may result in disciplinary action as well as civil or criminal action.

Providing information

Information about violations of legal or internal regulations is to be addressed to the respective superior, the competent regional compliance officer, the chief compliance officer or existing technical registration offices. Abusive or deliberately false provided information shall result in corresponding measures and sanctions.
The group‘s own e-mail address for inquiries, suggestions and notes about compliance is: Antonia.Yancheva@aiger.com
If necessary, you can also directly and confidentially contact the chief compliance officer:
Antonia Yancheva
– Telephone +359 32 905 000

Self-check for employees on the topic of integrity

A quick self-check could offer assistance if you are unsure about whether a certain action could be critical from compliance considerations. In such a situation, the employee may ask the following questions:

While the responses to these questions cannot replace informed legal consultation, they can provide an initial assessment of the situation. In the case of uncertainty, the employees should consult their supervisors, the regional compliance officer or the legal department. In addition, the chief compliance officer is available for questions regarding the code of conduct or about the topic of compliance in general.

Anti-trust and competition law

The Aiger Group (Switzerland) AG is in business competition with many other companies within and also outside
of our industry.

We are committed to fair and unrestricted competition in compliance with the requirements of the anti-trust and competition law. All employees are required to comply with the anti-trust and competition law. This includes the prohibition of agreements that are not anti-trust as well as the prohibition of the abuse of a market dominating position. In particular, employees shall refrain from agreements or understandings with competitors both inside and outside of our industry regarding the prices of our products and services. This applies both for purchasing as well as for sales prices.

Furthermore, agreements or understandings concerning production and sales volumes of a product as well as concerning the distribution of markets and customers are prohibited. Employees are also aware of the fact that exchanging competitively sensitive information violates the applicable law.

As regards suppliers and dealers, price fixing, exclusive supply or exclusive purchasing obligations, abusive discounts as well as imposed linkages of different products or services upon purchase or supply (packages) are not permitted. The prohibited abuse of a market dominating position as a provider or consumer of a certain type of goods or commercial services can, for example, be reflected in the determination of inflated prices, forced linking of different products or services upon purchase or supply (package deals), price discriminations or other unfair discrimination against third parties.

Upon participation in a tender, no consultation shall take place with other participants of this tender.

Competitive conduct

Antitrust laws are intended to secure and maintain free and genuine competition in the interest of all market participants.
Each employee is thus obligated to observe the applicable antitrust laws and other laws intended to regulate competition.

Trust

Corporate Responsibility

Our Fundamentals and Values describe rules of behaviour and notional Values, which we take into account when making decisions. This is because we consider these to be important and worth striving for. They are the basis for our standards in business behaviour, and offer our employees support and a sense of orientation. We are determined to render outstanding performances – although solely on the basis of our Corporate Values. We are firmly convinced that corporate success can only be sustainable if this is achieved in a lawful manner.

Compliance

Our behaviour must at all times correspond to our values and principles, legal regulations as well as social norms. This applies in all of the countries in which we are active. Adherence to external and internal rules is obligatory for all those who work in the Aiger Group (Switzerland) AG. We have laid this approach down in our Code of Conduct for Managers and Employees.

Sustainability

The Aiger Group (Switzerland) AG has from the outset pursued a strategy of sustainability. Our strategy aims to bring economic, ecological and social objectives into line with each other.

Economic responsibility

Our goal is to create values and to boost the value of the company.

Long-term positive development is more important to us than short-time success. This also applies to our expenditure on research and development, which is consistent, as well as to the high levels of investment and the development of new business fields.

Ecological responsibility

Environmental protection is one of the central objectives of Aiger Group (Switzerland) AG. This is not distinct from other goals, but is instead an integral component of the long-term corporate strategy. An inherent part of the striving for the highest-possible product quality is the efficient use of resources. This applies not just to our production processes, but also to our products. The aim of our environmental policy is to strike a balance between environmental protection and business efficiency.

Social responsibility

Our economic actions are based upon social principles, which we have undertaken to exercise vis-à-vis our employees, customers, suppliers and other business partners. We are keen to ensure that the capital at our disposal is deployed in such a manner that we are able to offer our employees interesting and secure places of work. Of particular interest to us in this conjunction is our determination to provide young people with training, thus giving them a good start to their professional careers. Safeguarding the future, health protection, further training, industrial safety and the encouragement of diversity within our company are important issues when it comes to promoting our sustainability.