CODE CONDUCT General

CODE OF CONDUCT | 5 1.2. General rules of conduct The principles of conduct are a fixed part of the WALTER GROUP business culture. Integrity begins with management. Our managers are to communicate the content and significance of our Code of Conduct to employees by means of exemplary personal conduct and social compe- tence, and to help employees implement the same. In acknowledging the Code of Conduct, each employee bears personal responsibility for upholding these principles. The principles of conduct apply both internally as well as towards our business partners. Each employee is entitled, and invited, to report any violations of the Code of Conduct or laws and provisions to their line manager(s), higher-ranking manager(s) (traffic board, commercial management, etc.) or head(s) of shared services or services. They are then obliged to deal with the report in strict confidentiality and look into it with the utmost care and consideration. No employee shall suffer any disadvantage in the company as a result of making a report of this kind. The WALTER GROUP Code of Conduct is brought to the attention of new employees as part of their training. By signing, they agree to comply always with the rules of conduct. 1.3. Compliance with the law Compliance with the laws and provisions in force on a national, European and international level is a basic principle of the WALTER GROUP. Each employee, regardless of position in the company, is obligated to observe the internal rules of conduct (such as circulars or work instructions) as well as all legal provisions within their field of responsibility, and act accordingly. The WALTER GROUP legal department must be consulted for any queries regarding legal provisions. Each employee regardless of possible civil or penal consequences must expect disciplinary action in the case of deliberate violation(s) of these basic principles.