Our code of conduct

1 . - Preamble

The trust of our customers and business partners, public authorities, the general public and other interested parties in the responsible and lawful conduct of all Iturri employees is of great importance for the reputation and success of our company.

A high level of social and ethical competence is expected from all employees. This standard also applies to the selection of our business partners.

In order to empower employees, Iturri will inform and actively support them through its managers.

Responsible and lawful behaviour should be a matter of course. This Code of Conduct illustrates the requirements for our behaviour both externally and internally in the fulfilment of our tasks. In this regard, employees are bound exclusively to the company and not to individual superiors. Compliance with the laws and regulations of all countries in which we operate is our highest priority. We do nothing that would lead to a violation of the law. Exceptions to this are not permitted, not even on the basis of customary or regional practices.

We are aware that the ethical standards expressed in local regulations vary from country to country. Should the regulations of this Code of Conduct or international legal provisions and conventions differ from local regulations, the stricter regulation always applies. Not every individual case, not every situation can be foreseen. The Code is necessarily broad and general in nature. It is not intended to replace detailed regulations or codes of practice. Rather, it is intended to provide all employees with a clear understanding of Iturri's principles and ethical values by identifying the core elements of individual and corporate responsibility.

Furthermore, Iturri is committed to the values recognised and applied in liberal democracies.

2 - The basic rules of conduct

2.1 Fair competition

The purpose of antitrust law is to secure and maintain free and undistorted competition in the interest of all market participants.

Antitrust law commands and prohibitions concern in particular:

• the prohibition of agreements between competitors on prices, territorial divisions, customer groups or production quantities,
• the prohibition of abuse of a dominant position.

Collusive behaviour, informal discussions or agreements that have the object or effect of restricting competition are also prohibited. In discussions with competitors, no confidential information about prices and upcoming price changes or customer and supplier relationships may be exchanged.

Fair competition also includes in no case offering or granting unjustified advantages to third parties in connection with business activities, either as monetary payments or in the form of other benefits. This also applies to countries in which there may be different customs.

2.2 Prohibition of corruption and granting of advantages

Corruption and the granting of advantages - in whatever form - will not be tolerated at Iturri. No personal advantages may be demanded, accepted, offered or granted in connection with our business activities. If an employee is confronted with such an offer or request, he or she must immediately report it to his or her superior.

Gifts and invitations may not be distributed or accepted as a matter of principle. Exceptions apply only in the case of generally customary occasional or promotional gifts and gifts that are in keeping with the customs and courtesies of a country.

The same applies to invitations. Cases of doubt must be clarified with the supervisor.

2.3 Data protection

The protection of personal data of our customers, suppliers and employees as well as the respect of national and international data protection regulations are a matter of course for us. Our business partners are also encouraged to handle such data with care.

2.4 Quality, Environment and Health Protection

As a company, we are committed to the protection of our employees, the environment, customer needs and systematic management.

As a company, we recognise our special responsibility for quality, the environment, our employees and the public, as well as for our customers.

We have therefore anchored guidelines for action, which apply to every employee, in our company policy. We see the awareness of quality, the protection of the environment and the guarantee of the health of our employees, especially from an economic point of view, as an important factor that contributes to maintaining and improving the competitiveness of our company.

Our integrated management system is a basic prerequisite for a forward-looking design of operational processes and for the organisation of our company.

It takes into account the requirements for a quality management system in accordance with the requirements of ISO 9001:2015, environmental management system in accordance with ISO 14001:2015, as well as the requirements for an occupational health and safety management system in accordance with BS 18001.

The associated management system documentation is a binding working basis for all managers and employees of the company.

Compliance with all safety regulations is also indispensable, regardless of whether they are prescribed by law, issued by the responsible authorities or regulated in company guidelines.

To ensure that we are permanently in a position to do this, we offer further training measures. We promote sustainability through a comprehensive range of information for our employees.

2.5 Social responsibility

Respect for human rights and fundamental social standards is a principle of all human coexistence.

Working conditions that violate such rights and standards contradict this principle. This applies within our company as well as in our cooperation with business partners. Each employee is responsible for ensuring that human rights and fundamental social standards are not violated within his or her area of responsibility and influence.

2.6 Prohibitions on discrimination

All employees have the right to fair, courteous and respectful treatment by superiors and colleagues.

No one shall be discriminated against on the grounds of race, colour, nationality, descent, sex, creed or belief, political opinion, age, physical condition, sexual orientation, appearance or any other personal characteristic. We are all obliged to respect the personal dignity and sphere of other employees. Harassment and any form of unwanted physical contact are prohibited.

2.7 Protection of Company Property and Trade Secrets

Iturri's property may only be used for business purposes. As trustees, each of us has a duty to protect it from loss, damage or theft. Office and work materials, samples and products are also company property. Trade secrets and other sensitive information must be kept confidential and protected from disclosure to unauthorised persons. Employees who have access to trade secrets and confidential information must not disclose them to third parties (including family members and friends) or use them for purposes other than business.

2.8 Protection of intellectual property

Each of us is responsible for and must do everything necessary to protect Iturri's intellectual property, such as patents, trademarks, brands or know-how, from attack or loss. This includes refraining from conduct that may damage the reputation and value of the "Iturri" brand in particular.

We respect the intellectual property of others. This also applies to this Code of Conduct. We have used the text from freely accessible sources* insofar as it is consistent with our principles.

(*Sources cited upon request)

2.9 Avoidance of conflicts of interest R11; private activity

Conflicts of interest between an employee's official duties and his or her personal interests must be avoided. Behaviour that may affect Iturri's interests should also be avoided in the private sphere. When expressing private opinions in public, employees should not refer to their function in the company.

2.10. Economical use of company resources

The economical use of company resources is a matter of course. Each use of resources must be assessed to determine whether it is in the best interests of Iturri. If different solutions are possible and of equal value, the more economical one should be chosen.

2.11. Ambassadors of the company

We are all perceived as representatives of the company in our actions. We must be aware of this every day. Iturri supports and welcomes voluntary work by its employees.

In 2008, we received an award from the Minister of the Interior of the State of North Rhine-Westphalia for our special support of voluntary work in emergency response.

By contributing to the positive perception of Iturri through our work, we also support the economic success of the company.

3 - Validity and implementation of this Code of Conduct

The rules of this code apply to all employees of Iturri Feuerwehr- und Umwelttechnik GmbH, not only verbatim but also in spirit.

Insofar as rules of conduct for individual areas of activity are laid down in separate guidelines, these guidelines apply without restriction alongside the Code of Conduct. In cases of doubt, the stricter rule in each case shall be observed.

A violation of the Code of Conduct may lead to measures under labour law for all employees, i.e. also for managers.

Management shall ensure that the principles and ethical values of this Code are communicated to all employees of the company in an appropriate manner and on a regular basis.

In addition to their function as role models, all superiors with disciplinary responsibility have the task of carrying the Code of Conduct into the company and monitoring compliance with it. Within the scope of his or her management responsibility, each supervisor is responsible for ensuring that all employees in his or her area of responsibility understand and comply with the rules of the Code.

Every employee is entitled and encouraged to report violations of this Code of Conduct or other policies in force at our company.

The Company agrees not to hold any employee responsible for bringing a violation or suspected violation of this Code to the attention of management or any officer.

In addition to the works council or the supervisor, violations of the rules can be reported at any time - even anonymously - to the compliance officer.

The Compliance Officer will investigate and initiate a process that will lead to an appropriate solution.

No one will be held responsible for business disadvantages resulting from compliance with the Code.

3.1 Review of our business partners abroad

All foreign business partners and intermediaries are checked for compliance with the Code of Conduct, for entries in sanctions lists and for their creditworthiness.

(Government end customers are excluded).