Business Ethics Policy

ASERVO Software GmbH not only places the highest quality demands on its products and processes, but also on its behavior and communication.

The corporate values form the basis for this:

• • Respect,
  • Trust,
  • Responsibility
  • Integrity

The management and employees of ASERVO Software are firmly convinced that respecting and upholding these values will continue to be the basis of our success in the future. ASERVO Software has therefore introduced rules and procedures to ensure that all employees can meet these high standards. These guidelines are constantly updated and adapted to current and legal requirements and are publicly accessible.

These regulations are summarized in the Code of Conduct, which ASERVO Software also requires all its business partners to comply with. The following guideline on corporate ethics provides a detailed overview of ASERVO Software’s most important principles on ethics and compliance in dealing with

• • Customers
  • Vendors
  • Business partners
  • Employees
  • Puplic

Strict compliance with these rules is one of the principles of good corporate governance for the management and employees of ASERVO Software.

1. Dealing with business partners

1.1 Combating corruption

ASERVO Software has a zero-tolerance policy toward all forms of bribery, corruption, extortion and embezzlement, which constitute an abuse of power for personal gain or to distort competition. Bribery is unethical, illegal, and poses a high risk to our employees and our business. Therefore, any form of bribery is not in the best interest of the Company and must be avoided at all times. At no time may material or immaterial benefits be solicited, promised or accepted that could be perceived as influencing business decisions. ASERVO Software also does not tolerate extortionate behavior, such as enrichment through threats of serious harm or other forms of coercion or blackmail. ASERVO Software does not offer or take advantage of any improper benefits to its business partners. Furthermore, ASERVO Software does not make any accelerated payments (e.g. for routine official acts). If a violation of these rules becomes known, the company will terminate the existing business relationship without notice and with immediate effect.

1.2 Fair Competition/Antitrust

ASERVO Software does not accept or expect any price fixing or any form of unfair distortion of competition from its business partners. Employees who negotiate and enter into agreements with customers, vendors or competitors of the company as part of their duties are obliged to know and comply with the requirements of applicable competition and antitrust law in order to maintain ethical relationships.

1.3 Anti money laundering

The ASERVO software ensures that the applicable legal regulations against money laundering, i.e. the smuggling of illegally earned money or illegally acquired assets into the legal financial and economic cycle, are complied with.

1.4 Export controls and economic sanctions

ASERVO Software complies with all applicable import and export control laws or temporary economic sanctions and embargoes that affect specific business transactions and that apply to countries, regions, organizations, or individuals. The company respects international regulations and does not engage in transactions or business with goods or technologies subject to restrictions. Affected business partners are screened as necessary.

2. Conflicts of Interest

Conflicts of interest arise when a person or company (whether private or public) may use his or her professional or official position in any way for personal or corporate gain. The business activities and decisions of employees must be for the benefit of ASERVO Software and must not be influenced by personal interests and relationships with vendors, customers, competitors, other employees or persons associated with the employee. This also applies to secondary activities for, or financial interests in, our competitors, customers or vendors. Competition with the employee’s primary job is prohibited. Applicable working hours must be observed.

3. Intellectual Property

Intellectual Property is recognized as patents, trademarks, copyrights, designs, models, samples and business information such as specialized knowledge or information entrusted by customers or suppliers. ASERVO Software also respects as intellectual property literary and artistic works, as well as symbols, names and images used in commerce. These shall not be used or published without authorization. All employees and vendors of ASERVO Software must ensure that the intellectual property of ASERVO Software is protected against access by unauthorized employees and third parties.

4. Transparency and protection of information

4.1 Financial Responsibility

ASERVO Software properly documents business transactions, records financial information in a timely manner, and complies with legal requirements and accepted accounting principles. Documents are stored either physically or digitally in accordance with legal requirements. Overall, ASERVO ensures that its accounting and financial practices meet the required standards.

4.2 Disclosure of Information

ASERVO Software employees who communicate financial and non-financial information to ASERVO Software stakeholders in the course of their work are required to do so openly and in accordance with applicable laws and regulations and best practices.

4.3 Protection of personal data

ASERVO Software takes the protection of personal data of its employees and contractual partners very seriously. In accordance with national data protection laws and the company’s data protection policy, personal data is processed only to the extent necessary for the employment relationship or for the purposes for which it was provided. Acts against an employee’s privacy, family, home or correspondence, as well as attacks on an employee’s honor or reputation, are prohibited.

4.4 Confidentiality

All employees and suppliers of ASERVO Software are obligated to protect confidential information (documents, digital data), regardless of whether such information is generally known or whether employees have been given explicit access to such information. Therefore, no employee or business partner may disclose new knowledge, confidential information or trade secrets to third parties in any form. This applies even after the employment or business relationship has ended. Employees and vendors are expected to observe and comply with the Company’s guidelines, policies and contracts regarding information security and confidentiality. ASERVO Software uses and protects non-personal data resulting from a business relationship in an appropriate manner. The Privacy Policy also ensures that sensitive data is collected, processed, secured and deleted appropriately. Under no circumstances will confidential content be published, passed on to third parties or made available in any other form without authorization. Legal requirements and, where applicable, individual confidentiality agreements with our business partners apply.

4.5 Whistleblowing, protection of identity and protection against retaliation

In the event of any doubt as to the fulfillment of the above obligations, and in order to avoid unauthorized activities, the employee must contact his or her immediate supervisor or, in justified circumstances, management. In the case of data protection violations, the report may also be made to the Data Protection Officer. In the case of such reports, ASERVO Software attaches particular importance to protecting against retaliation and to protecting the identity of employees, business partners or other third parties who report known or suspected misconduct or violations. Under no circumstances may the reporting of violations or suspected violations result in negative or retaliatory action against the reporting party. ASERVO Software therefore prohibits any direct or indirect action or retaliation against any person who, in good faith, reports an actual or suspected violation and/or participates in an investigation. Whistleblowers need not fear dismissal. However, reports must always be made truthfully.

5. Human Rights

The management and employees of ASERVO Software expressly and consistently support internationally recognized human rights. All employees of the company must be treated with dignity and respect, even in the case of disciplinary measures. Such measures may only be taken in accordance with applicable national and international standards and internationally recognized human rights. ASERVO Software respects the rights of local populations, minorities, indigenous peoples and other vulnerable groups and strives to avoid negative impacts on them.

5.1 Non-Discrimination / Equal Opportunity / Ethical Recruitment

ASERVO Software does not tolerate discrimination based on origin, nationality, gender, age, color, religion or belief, sexual orientation, disability, illness, or pregnancy. ASERVO Software offers equal opportunities both in the search for new employees and during the employment relationship. ASERVO Software will not deceive or mislead potential employees about the nature of the work. ASERVO Software never steals identity documents or charges recruitment fees. Applicants receive a written employment contract at the beginning of the hiring process, in a language they understand, which clearly and honestly describes their rights and obligations.

5.2 Protection from child or forced labor

ASERVO Software strictly rejects child labor and any form of exploitation of children and youth and expects its business partners to do the same. School-age children (under the age of 15) may not be employed, even if the legal requirements of the respective country of our supplier would allow it. Any form of forced, bonded, indentured, or slave labor, slavery, or similar conditions is prohibited. Company employees may not be compelled to work, either directly or indirectly, by force or intimidation.

5.3 Compensation, Employee Rights

All employees should receive a fair wage for their work. Employees‘ rights to freedom of association, assembly and collective bargaining will be respected to the extent permitted by law and possible in each country.

5.4 Working hours

Working hours comply with the applicable national law, the industry standard or the relevant ILO conventions. Overtime must be voluntary.

Munich, 29.04.2024

Rainer Heinold