We developed the eps guidelines together with employees in the team. We also made these available to every employee. Therefore, the result is a transparent collection of basic ethical values. These values shape eps and serve as a benchmark for all actions and interactions, internally and externally. We expect every team member within the company to abide by these values.

The guidelines serve as a code of conduct. This code regulates, supports, and accompanies cooperation, interaction, and business relationships.We consider compliance to be the set of measures to ensure the legal and ethical behavior of eps and all its officers and employees.

Moreover, these rules cater to all requirements and prohibitions imposed by law and the company itself.The guidelines apply to all employees and board members of eps, our business partners, and suppliers. However, we first need to influence them.

The rules here are intended to ensure legal compliance at all levels of our operations. Similarly, they also recognize and develop standards for our industry. We aim to provide a framework for developing our products and services.
Even if we explain various important possible situations in this way, we cannot depict every imaginable situation. Therefore, it is the responsibility of every person to follow the applicable laws and to subordinate their behavior to basic ethical rules.
To achieve all of our goals, we recommend reviewing the following points in the event of an unclear situation:#

Is this measure legal?

Is this action in compliance with this policy?

What is the impact on our customers, shareholders, employees, and our community?

What would be the community’s reaction if this measure was made public?

eps expects the same from suppliers as from employees and customers:

• Compliance with all applicable laws
• The omission of corruption
• Respect for human rights
• Compliance with the laws against child labor
• The observance of the legislation of international economic traffic
• Protecting the health and safety of all employees
• Compliance with the relevant national laws and international standards on workplace safety, environmental protection, and data protection
• The implementation of and compliance with these points in our supply chain

Each team member must educate themselves about the laws, regulations, and internal instructions applicable to their area of responsibility. For this purpose, they get a legal register containing all valid and current laws relating to their activities. In case of unresolved questions or doubts, they can get guidance from the legal or responsible departments.

We aim to provide our customers with high-quality products and services that meet their needs at all times. Therefore, our measurement tool measures our customer’s satisfaction with our service. However, it can happen that we do not fully meet expectations.
For such situations, our customers have access to a comprehensive complaints management system. So, they can contact the system directly via the project manager, the site manager, or the compliance officer. We take every suggestion and criticism seriously. So, we see it as an opportunity to improve our service and respond even more specifically to customer needs.

All employees have access to a transparent complaints management system for internal complaints within the workgroups, the entire organization, or in the direction of superiors. This system documents occasions, supports optimization measures, and reports results to eps management.

Respect, fairness, and a sense of responsibility, as well as team spirit and open-mindedness, honesty, and clarity, are the guiding values of our communication culture. Communication and information take place transparently within the individual teams and areas.

Corruption damages competition. Moreover, it is not consistent with our corporate values. Similarly, it exposes eps and each team member to liability risk. We are committed to maintaining the highest standards in our business activities.
We do not grant or accept unlawful, unwarranted benefits. A “conflict of interest” happens as soon as the interests of someone conflict with those of the company. In fulfilling their professional obligations, the company’s interests guide our employees. So, they avoid activities that conflict with business interests or fulfill these obligations.
They do not misuse their position, company information, or company property for personal purposes or improper advantages of third parties.

Invitations and gifts are part of human interaction and polite dealings. Employees may extend invitations and give gifts to business partners. Moreover, they may accept invitations and gifts from them, provided they are within an appropriate framework. To avoid even the appearance of corruption, the following applies:

• Employees must refuse invitations and gifts if they are connected with a concrete expectation of some consideration. The same applies to gifts to business partners.
• We permit and encourage employees to participate in specialist events. The same applies to the implementation of specialist events.
• Invitations to and participation in social, civic, and recreational events in the business environment are permissible if they are within reasonable bounds. They must not give the impression of harming fair competition or mixing interests.

We require and demand that our business partners and suppliers comply with all applicable laws, as we do. Accordingly, we only work with business partners operating within the framework of the legal regulations.

We have a duty as a company to take an interest in and challenge the value chain of the products and services we purchase. With our purchasing behavior, we want to contribute to the demand for good work and ethically correct services. eps expects the same from suppliers as it does from employees and clients:

Compliance with all applicable laws

The omission of corruption

Respect for human rights

Compliance with the laws against child labor

The observance of the legislation of international economic traffic

Protecting the health and safety of all employees

Compliance with the relevant national laws and international standards on workplace safety, environmental protection, and data protection

The implementation of and compliance with these points in our own supply chain

We expect our employees, suppliers, and service providers to participate in the achievement of environmental goals and to make visible efforts.
We treat service providers, distributors, and manufacturers honestly and fairly. Therefore, we maintain stable, long-term business relationships with our suppliers, all characterized by respect.
Our purchasing behavior is always based on quality and our sustainability values. eps recognizes the importance of local suppliers in procuring goods and services.

Employees are obliged to handle personal data sensitively in all business processes. Moreover, they only collect personal data per the applicable data protection laws. Therefore, this applies to employee data and data from customers, suppliers, competitors, and other persons.

Similarly, data processing is only permitted if the data subject has given their prior consent or if this is legally permissible for other reasons. Personal data must be used carefully; its processing must be necessary in every case.
eps has appointed a data protection officer to ensure effective data protection. Moreover, we have issued a freely accessible corresponding data protection policy.

Each supervisor must establish an organization in their area of responsibility that protects company assets from the risk of loss and misuse. So, they must not use company assets for private purposes.
The purchase and sale of company assets must be transparent, understandable, economical, and at market conditions. Individual employees and their interests must not influence decisions and economic transactions.

We represent fair and ethically correct competition. Therefore, we instruct all our employees to implement this Code. We do not support price or regional differentiation agreements to the detriment of our customers. Conditions may not be exchanged or agreed upon with competitors.

Our company’s observance of compliance guidelines is the highest priority. We want to thank all employees for their strong support and daily efforts in implementing these values.
Violations of the Compliance Guidelines can have far-reaching consequences for the employees and eps. The consequences range from warnings and effective termination of employment to claims for damages by third parties and by eps, from fines to criminal prosecution, public litigation, and the associated loss of image.