Code of Ethics

CompuGroup Medical is committed to acting in a socially responsible manner and will always achieve its goals by acting ethically. As an express commitment to this social responsibility, this Code of Ethics sets out the specific requirements for business practice and personal conduct. The Code of Ethics applies to all employees of CompuGroup Medical, including managers and employees of subsidiaries, as well as to all suppliers, business partners, consultants, and third parties acting on our behalf.

With this Code of Ethics, we commit ourselves to respect our customers, shareholders, employees, contractors, as well as the environment, and declare to always act in an honest, fair, and professional manner.

Compliance with laws, regulations, and standards

CompuGroup Medical is committed to comply with the applicable laws, regulations, and standards in Germany and the countries in which the Group operates.

Discrimiations and harassment will not be tolerated

CompuGroup Medical rejects any form of discrimination. No one may be disadvantaged, favored, or harassed because of his race, ethnic origin, skin color, nationality, gender, religion or belief, disability, age, sexual orientation, or other legally protected characteristics.

Any form of harassment at work is prohibited. Every manager is a role model with his own behavior and must ensure a working environment free of discrimination and harassment.

Diversity and personal behavior

Creating a positive corporate climate based on tolerance, respect, and esteem for each individual and their human dignity is essential and self-evident. Therefore, a responsible behavior of each individual in dealing with one another is important, which should always be determined and characterized by appreciation, mutual trust, openness, and fairness.

In international collaboration, CompuGroup Medical respects and considers other cultures and their cultural framework.

Conflicts of interest

Each representative of CompuGroup Medical is obliged to behave impartially in all business relations and not to grant unjustified advantages to any other company, organization, or person. Participation in activities which could lead to an actual or alleged conflict of interest or which could impair one's own freedom of action or decision-making is not permitted. To avoid conflicts of interest, the processing of or participation in unauthorized business activities in which the actor himself, his spouse, partner, a close relative, or any other person with whom he has a close relationship, is financially directly or indirectly involved, shall be prohibited. In addition, processing or participation in business activities that could compromise confidence in the impartiality of the employee concerned or the integrity of the work is prohibited.

Corruption, bribery, and trading in influence

CompuGroup Medical is against all forms of corruption, bribery, and "trading in influence" and actively seeks to avoid such actions in the Group's business activities. CompuGroup Medical prohibits the offer, distribution, and acceptance of bribes and kickbacks of any kind and the use of other ways and channels to give undue advantage to customers, agents, contractors, suppliers and their employees, or government officials. CompuGroup Medical also prohibits its employees from providing or accepting bribes or kickbacks from customers, agents, contractors, suppliers and their employees, or government officials in order to gain an advantage for themselves or their family, friends, partners, or acquaintances. The prohibition of bribery and "trading in influence" applies both to the party granting or offering an undue advantage and to the party requesting, receiving, or accepting such an advantage. In this context, the mere demand or offer of an unjustified advantage is already inadmissible. CompuGroup Medical understands kickback payments (payments in which the recipient uses the authority of his official position and the consequences of non-payment can be completely disproportionate to the small payment) as a form of bribery, which is therefore subject to the above rules.

Gifts, hospitality, and expenses

CompuGroup Medical prohibits the offer and acceptance of gifts, hospitality, or expenses if such gifts, hospitality, or expenses could influence the outcome of business transactions and are not reasonable expenses or benefits.

Gifts, hospitality, or reimbursement of expenses must comply with the Code of Ethics and the points listed below. Justification: The gift or hospitality should clearly be given as a form of recognition.

No obligation: The gift, hospitality, or reimbursement of expenses does not obligate the recipient in any way.

No expectations: No expectations are created for the donor or a partner of the donor, nor are higher expectations associated with the transaction than the recipient would attribute to a corresponding transaction.

Disclosure: If granted secretly, the purpose appears suspect.

Consistency with the views of stakeholders: The transaction would not be considered unfavorable by the stakeholders if it were known to them.

Reporting: The management should be informed about a gift, hospitality, or expenses, if these exceed the amount of $50 in individual cases.

Appropriate value: The value of the gift, hospitality, or reimbursement of expenses is in accordance with standard business practice.

Appropriateness: The nature of the gift, hospitality, or reimbursement is appropriate for the relationship in question and is in line with standard business practice.

Legality: The grant is subject to the law of the country in which it is granted.

Compliance with the regulations of the recipient: The gift, hospitality, or reimbursement is in accordance with the regulations or code of conduct of the receiving organization.

No regularity: The granting or acceptance of corresponding grants does not regularly take place between donor and recipient.

Donations and sponsoring

CompuGroup Medical is obliged to ensure that donations and sponsoring are not used as a pretext for bribery. CompuGroup Medical will disclose all donation and sponsoring activities.

Political donations

CompuGroup Medical, its employees, and third parties acting on behalf of the company may not make donations, directly or indirectly, to political parties, organizations, or persons active in politics in order to gain a business advantage. CompuGroup Medical will disclose all political donations.

Compliance with the Code

The Code of Ethics applies to all employees of CompuGroup Medical, including managers and employees of subsidiaries, as well as to all suppliers, business partners, consultants, and third parties acting on our behalf.

Violations of the principles set forth in this document will be prosecuted and may result in dismissal. If a violation of the Code of Ethics is suspected, a supervisor must be notified. If the supervisor is involved in the violation of the Code of Ethics or does not pursue the violation, the next hierarchical supervisor must be informed.

The Code of Ethics is published on the company's website and is generally accessible. New employees are informed about the Code of Ethics by Group HR.

Disclaimer

Nothing in this document shall be construed as conferring any right enforceable by third parties and all rights of third parties provided by law are excluded to the fullest extent permitted by law.