Compliance with legal requirements, a responsible attitude and moral integrity towards our employees, business partners and the company as a whole is part and parcel of our system of values. Our Code of Conduct serves as overall guidance in that it sets binding minimum standards for acceptable behaviour. This helps avoid breaches of law through raising awareness of possible legal risks. The principles set forth in the Code of Conduct are binding for the company's senior executives, middle management and employees.

Regulatory and legal compliance

Our daily activities and decision-making process are always guided by regulatory compliance at the local and national levels, as well as internationally. Any regulatory infringements are incompatible with our values and detrimental to the company's reputation. Therefore, no unlawful conduct will be tolerated. Any breach of statutory provisions or internal regulations can result in disciplinary actions, liability for damages and even criminal charges.

Bribery / Presents

All executives and employees are expected, both domestically and abroad, to demonstrate compliance with the applicable laws and regulations. Particular emphasis is placed on efforts to avoid the unlawful granting of advantages, and offering or accepting bribes and kickbacks. We make a special point of making sure that gifts, gratuities or any other business courtesies are received in accordance with the law in force and with the utmost transparency. When selecting a supplier, any and all purchasing decisions at NUKEM are based exclusively on objective and comprehensible quality criteria. Where gifts, gratuities or other courtesies are offered to decision makers, they are expected to refuse to accept it as a matter of principle or to concur with their superiors or the corporate compliance officer. Common and permitted gifts should also have no impact on decision-making.

Competition

We are committed to fair and open competition. Our executives and employees are not allowed to follow any practices which are unlawful and/or entail criminal liability. It is specifically forbidden to enter into unlawful agreements to fix prices, quantities or to allocate geographical areas as well as any other unfair practices that seek to prevent, restrict or distort competition.

Avoidance of conflicts of interest

NUKEM's employees make business decisions solely in the best interest of the company. Executives and employees shall avoid even the appearance of conflict between their personal interests and business or other activities of the company. Where conflicts of interest do arise, they shall be resolved in accordance with the applicable law and internal regulations.

To this end, all executives and employees are expected to maintain high ethical standards in handling conflicts of interest. Where family, partner, business, investment or any other relationships with individuals or companies doing business with NUKEM might lead to conflicts of interest, such circumstances must be immediately brought to the attention of the relevant superiors.

Information security and data protection

We consider data security to be of overriding importance. Our corporate data as well as our customers’ and employees’ personal data is protected against unauthorised access, improper use, abuse or loss. This said, every single employee is responsible, within the scope of their duties, to ensure a high level of data protection. We use a combination of technical and administrative controls to ensure that sensitive data is only collected and processed to the extent required and permitted by law, and exclusively for the purpose intended. No personal data may be collected or processed without the consent of the data subject or legal permissibility.

Confidentiality

Business and trade secrets, confidential information and business records shall be kept strictly confidential and suitably protected against unauthorised access by co-workers or third persons.

Business records

All business transactions shall be properly and fully recorded as required by law and NUKEM's internal regulations.

Responsibility for implementation

Responsibility for compliance with the Code of Conduct rests with every individual employee. To ensure this compliance, NUKEM actively promotes the principles set forth in the Code of Conduct. In this regard, our managers lead by example and have a particular responsibility to ensure that all employees are familiar with and understand the Code of Conduct. As part of their managerial responsibilities, the superiors seek to prevent unacceptable behaviours and take appropriate actions to make sure that their subordinates avoid regulatory breaches. Furthermore, our employees receive regular training on the topics of the Code of Conduct. Responsibility to monitor the observance of the Code of Conduct rests with the corporate compliance officer.

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