COMPLIANCE


A) Code of conduct of Alpha Industrieservice GmbH


Preamble

The Code of Conduct of Alpha Industrieservice GmbH (Alpha IS) was defined with the aim of establishing principles according to which Alpha IS maintains its relationship with employees and business partners. They apply equally to all employees of Alpha IS, both to all members of the management and to all employees.

We always strive to ensure that these principles are also lived by our suppliers, consultants and other business partners.

1. corporate principles

1.1 Law abiding

Alpha IS shall comply with the laws applicable in each country in which it operates. In situations where there are no legal regulations, each of us will base our conduct on our corporate values and culture.

In all cases where there is a conflict between applicable laws and the principles of this Code of Conduct, the applicable law shall prevail.

1.2 Dealing with business partners, fair competition & antitrust law

The business relationship between Alpha IS and your business partners shall always be characterized by fairness. We must not offer rewards or benefits to potential customers, government agencies, regulatory bodies or other representatives of such entities that are contrary to applicable law or good morals.

We are committed to complying with applicable antitrust law. The main purpose of antitrust law is to ensure fair and uniform competition. All unlawful restrictions on competition are to be prevented. No agreements may be made between competitors which would be detrimental to competition. This includes agreements on prices, price changes and calculations, as well as agreements among competitors on bidder and offer behavior in tenders.

Our employees must not accept any payments, gifts or other remuneration from third parties that could lead to decisions being influenced by them and not being made with due objectivity.

1.3. accounting and bookkeeping

All financial transactions of Alpha IS must be documented in accordance with generally accepted accounting principles. All entries must be accompanied by a clear, unambiguous and non-misleading designation as to the content of the transaction. It must always be possible to present all business transactions in a comprehensible manner.

1.4 Conduct in accordance with obligations

Employees and members of the management of Alpha IS are obliged to organize their private and other activities as well as financial interests in such a way that they do not conflict with the interests of the company or could give rise to conflicts. Should such a conflict arise, the person concerned must report this immediately to his or her superior.

1.5 Money laundering. Combating money laundering

Money laundering is the infiltration of illegally obtained proceeds into a legitimate economic and business process with the aim of concealing the illegal origin of the funds. Money laundering is a criminal offense. The actions of all employees must therefore be geared towards uncovering any suspicious transaction that could consciously or unconsciously constitute a violation of the Money Laundering Act.

1.6 Disclosure of information

No employee of Alpha IS may, during or after his or her employment with the company, disclose or otherwise use confidential information obtained in the course of his or her employment without express permission. This policy also applies to nondisclosure or confidentiality agreements that govern our business partners' handling of confidential information.

1.7 Financial responsibility

Financial responsibility means acting economically on the basis of ethical and legal principles. For our company, this means ensuring that the employee has good working conditions and that products/services do not have an impact on the employee's health. In addition, there is a responsibility to employees and investors to operate in a sensible and healthy manner.

1.8 Export Controls & Economic Sanctions

The respective applicable laws and regulations in the areas of export and import control

and customs are to be observed insofar as they are applied in our company.

1.9. data protection

We undertake to take all measures to ensure legal compliance with the GDPR when handling data. Our company is obligated to protect the data of affected persons, such as employees, customers and business partners, and to take special measures for this purpose.

These measures include:

All devices and resources provided to Alpha IS employees and access to e-mail and the Internet are intended for the performance of business activities. In principle, Internet use should be limited to work-related activities.

However, personal use, such as for private e-mails, text messages and reasonable Internet use, may be granted. Private use is only permitted if it does not jeopardize the business or reputation of the company or could be considered offensive.

Company equipment and systems must not be used to access or create illegal or distasteful content. Employees should always exercise special caution when receiving emails that may contain viruses or other hidden threats to IT security or the security of data and information. In addition, employees are prohibited from copying or installing content or software for which they do not have permission or a valid license. To ensure security and confidentiality, passwords must never be shared with unauthorized third parties. Employees should always log off their computer before leaving their desk. Confidential information may only be stored on a Group data server for which appropriate access restrictions have been created. Confidential information may only be exchanged via the Alpha IS e-mail system and the company's data network. In case of doubt, the IT system administrator of Alpha IS must be contacted immediately.

1.10. Respectful treatment

The following behaviors are prohibited for Alpha IS employees:

Any discrimination on racial or sexist grounds, on the basis of an employee's faith, sexual orientation, age or physical disability

Sexual harassment, moral violations

Infliction of bodily injury

Insulting another person (verbally or in writing)

Intimidation and/or threats

Sabotage of activities of others

1.11. Intellectual property

Intellectual property rights must be respected and technology and know-how transfers must be carried out in such a way that intellectual property rights and customer information are protected. This also includes the intellectual property of third parties.

1.12. Plagiarism

Methods and processes must be developed, implemented, and maintained to

Minimize the risk of introducing plagiarism into deliverable products and services and detect plagiarism at an early stage.

2. responsibility of managers and employees

Alpha IS management is responsible for exemplifying and communicating the content and meaning of these policies to their employees. They are obliged to encourage employees to behave in accordance with these principles. Reports of violations of the rules of conduct set forth herein may be made anonymously and confidentially to management. Persons who report violations in good faith will not suffer any disadvantage as a result. Their identity must be preserved and retaliation of any kind must be prevented.


B) Declaration on human rights and working conditions

of Alpha Industrieservice GmbH


Preamble

The management of Alpha Industrieservice GmbH (Alpha IS) is aware of its social responsibility. Through value-oriented corporate management, employees should experience fair and respectful treatment at all times, thereby also strengthening the company's goals. The internationally recognized human rights are respected by Alpha IS. Throughout the entire business activity, national laws and regulations are observed as well as the principles of the International Labor Organization (ILO).

1. principles on human rights and working conditions

1.1 Free choice of profession

Employment with Alpha IS is freely chosen. No one may be forced to accept a particular job or to perform a profession that he or she rejects. This includes the prohibition of any forced or compulsory labor.

1.2 No discrimination

Equal opportunities and equal treatment, irrespective of ethnic origin, skin color, gender, religion, nationality, sexual orientation, social background or political views are guaranteed, insofar as they are based on democratic principles and tolerance towards those who think differently.

Employees are neither favored nor disadvantaged because of their membership in a trade union or company employee representative body.

1.3 No child labor

In accordance with ILO Conventions No. 138 and 182, children must not be hindered in their development. Their dignity must be respected and their safety and health must not be impaired. Alpha IS always complies with the minimum age requirements for employees.

1.4 Forced labor and human trafficking

All work at Alpha IS is performed voluntarily. Forced labor, compulsory labor and generally any form of involuntary work is rejected. This results in a clear distancing from these issues. All employees are free to terminate their employment at any time, taking into account the agreed or legal notice periods. Furthermore, no actions or measures will be tolerated which, within valid legal and social norms, are likely to restrict the freedom of movement of employees.

1.5 Freedom of association

The right of all employees to form collective employee representations and to conduct collective negotiations to regulate working conditions is recognized. Alpha IS will cooperate with the respective employee representatives in a spirit of trust. The aim at all times is to maintain a fair and cooperative partnership in the long term.

1.6. remuneration

The remuneration of Alpha IS observes - irrespective of the difference in gender - the minimum wages guaranteed by law in each case and the minimum standards of the respective economic sectors with orientation to the corresponding labor market.

1.7 Working time, recreation and free time

At Alpha IS, applicable rules and regulations regarding working hours and regular paid vacation are observed and complied with.

1.8 Occupational health and safety

At Alpha IS, occupational safety and health protection at the workplace are ensured at least within the framework of the statutory provisions. Attention is always paid to health, safety at work and the humane design of working conditions. For monitoring and ongoing advice in these areas, an external occupational safety specialist is employed and internal safety officers are trained by the Employer's Liability Insurance Association.

1.9 Qualification and promotion opportunities

At Alpha IS, employees are generally selected, hired and promoted on the basis of their function-specific qualifications and skills. A targeted and continuous qualification of all employees is supported in order to enable a high level of performance and high-quality work. All Alpha IS employees have the same opportunities for advancement, taking into account length of service and ability.

2. implementation principles

2.1 Communication

The objectives and implementation principles of this declaration are part of the corporate culture of Alpha IS. The employees of Alpha IS, in particular employees with managerial functions, are always required to observe the principles laid down and also to encourage other employees to observe them.

2.2 Regular exchange of experience

Compliance with the objectives as well as the implementation of the implementation principles of this declaration is regularly discussed within the framework of our site manager meetings.


C) Company policy for health, safety, occupational safety and environmental protection of Alpha Industrieservice GmbH.


Preamble

As a service company, our employees are our most important asset. Healthy and satisfied employees who work for us in a pleasant environment thus make a significant contribution to the satisfaction of our customers and thus also to our success. Our goal is therefore to always prevent accidents, injuries and occupational health hazards and to protect the environment. The following points help us to achieve these goals:

1. corporate principles

1.1 Economy and ecology

Our actions must be in harmony with the economy, ecology and responsibility for our environment and our fellow human beings, not least with regard to future generations. All employees always take care to act in such a way that hazards or unnecessary burdens on the environment are avoided. Applicable laws and regulations must always be complied with. In addition, they must act at all times in a manner that appears reasonably appropriate.

1.2 Health, safety and occupational safety

Health, safety and occupational safety are important components of our company policy. All employees are provided with a safe and healthy working environment, with appropriate facilities and suitable protective equipment. All workplaces are constantly checked for hazards and hazardous substances in order to prevent accidents.

2. implementation principles

2.1 Accident prevention and behavior in case of accidents

Employees are trained with regard to accident prevention regulations, conduct in the event of accidents and emergencies, and the use of protective clothing and equipment. Our employees are offered the opportunity to take part in first-aid courses or first-aid courses at regular intervals in order to be able to provide the victims with the fastest and best possible first aid in the event of an accident.

2.2 Ecological sustainability

All operations and processes are assessed from the perspective of environmental sustainability (recycling, reduction of CO2 emissions, waste management, etc.). From this assessment, measures and environmentally friendly targets are set to meet legal and other requirements. Energy and raw materials are used as sparingly as possible to avoid unnecessary pollution. The environmental awareness of our employees shall always be promoted. The environmental policy is taken into account in the entire value chain and can save the company costs and effort at the same time.

2.3 Responsible procurement of raw materials

We support activities that ensure the responsible procurement of raw materials. The procurement and use of raw materials that are obtained illegally or through ethically reprehensible or unreasonable measures shall be avoided. The use of raw materials, such as conflict minerals, that are affected by embargoes or other import restrictions shall be excluded.

2.4 Hazards and/or security vulnerabilities

If potential hazards and/or security vulnerabilities are identified, appropriate measures must be taken immediately to avoid or reduce as far as possible the resulting risks and hazards.

3. final provision

This declaration becomes effective on the day of signing. Claims of third parties cannot be derived from this declaration.