Compliance

Today, compliance is more complex than ever before. There are ever-increasing legal challenges in a global environment. That’s why we are constantly adapting our processes and systems to the legal framework. To emphasize the significance of compliance for us, we have firmly anchored it into our corporate policy: “We comply with applicable laws and internal guidelines.” Compliance is therefore an active component of our corporate culture. We operate a compliance management system that makes it possible for you as a customer, business partner, or employee of the company to act based on standardized and binding structures.

It is important to identify potential misconduct at an early stage to ensure that we can live up to our corporate policy. One of the ways we are able to do this is by having any information about possible compliance violations reported to us.

A compliance violation exists if applicable law or internal policies are violated in Germany or abroad by our employees or vis-à-vis our employees in the performance of their duties. Such violations include corruption, competition and antitrust offenses, data privacy violations, as well as accounting, financial and tax offenses.

To detect compliance violations and be able to prevent them, we rely not only on our employees, but also on our customers and business partners.

Should you notice any sign of a compliance violation, you can make a report through various channels.

Regardless of the method you choose to raise your concern, we assure you that every report will be handled in strict confidentiality – even anonymously if you so desire.

Compliance Officer

Please contact our Compliance Officer to raise serious concerns regarding compliance violations, or if you have questions on the topic of compliance in general.

Schwarz Dienstleistung KG

Compliance

Stiftsbergstraße 1

74172 Neckarsulm, Germany

E-mail: compliance@mail.schwarz

Online Reporting System

As an additional reporting option to provide information on potential compliance violations, we have established an online reporting system. All incoming information is processed by our Compliance Officer.

Our online reporting system is an Internet-based application and can be accessed from any Internet-enabled device via the following link: Online reporting system.

External Compliance Counsel

We invite you to direct your concerns to our external compliance counsel, Dr. Margarete von Galen. You may contact her at any time and report information on potential company-related or employment-related criminal acts and offenses. We assure you that Dr. von Galen will carefully review the details of your report and forward your report to our compliance officer if there is concrete evidence indicating a compliance violation.

As our external compliance counsel, Dr. von Galen is bound to professional secrecy. She will only forward your personal information to us with your express consent.

You may contact Dr. von Galen as follows:

Dr. Margarete Gräfin von Galen

Specialist lawyer for criminal law

Mommsenstraße 45

10629 Berlin, Germany

Phone +49 (0)30 - 3101820

Fax +49 (0)30 - 31018220

E-mail: galen@galen.de

Please be assured that we will handle all indications of compliance violations with utmost care and in strict confidentiality and act on any confirmed misconduct in a firm and appropriate manner. Please note that matters bearing no relation to non-compliance will not be dealt with.