Code Of Conduct

1. IT STARTS AT THE TOP

My Fellow Humans,

As individuals, as members of Akzis, and as participants in a broader business community, we find ourselves deeply integrated within a complex web of social and legal structures. This integration occurs not just in our personal lives but across all our global business activities.

This framework offers us numerous advantages. As individuals, it supports our ability to build social connections and pursue personal interests while protecting our rights and reputation. As employees at Akzis, it underpins our livelihoods. As a business, it allows us to participate in international markets, securing jobs, driving economic growth, and delivering substantial returns to our stakeholders.

Through our interactions within this framework—whether with colleagues, customers, partners, or governmental and institutional entities—we gain immeasurable benefits. However, the effectiveness and stability of this framework depend entirely on its constituents adhering to established social norms and legal standards at every level of operation.

Moreover, in today’s climate, we must be vigilant against threats like economic espionage that seek to undermine our competitive edge and compromise our integrity. Ensuring the security of our intellectual property and sensitive business information is crucial not only for our survival, but for maintaining the trust and confidence of those we serve.

Therefore, our commitment to open, fair, objective, and respectful engagement with all individuals and entities associated with our business is fundamental. Adhering strictly to all relevant regulations and norms is not just a responsibility but a core part of our ethos.

We, the team at Akzis, are therefore dedicated to embodying the principles laid out in this Code of Conduct. We believe firmly that the sustained success and ethical integrity of our company depend on our unwavering commitment to these standards.

I present to you below our most valuable code at Akzis. As a tech company built on superb code, this statement affirms my dedication to our company-wide ideals. Together, let us commit to these principles that not only define, but also drive our success in the global tech sector.

Gerald S. Wassum | CEO of Akzis

2. INTRODUCTION & PURPOSE

To ensure our continued success and growth, we at Akzis must maintain the trust we have earned from our customers, business partners, and employees. This trust hinges not only on the quality of our products and services but also on our commitment to values such as reliability, respect, and appreciation. It is essential that every division of Akzis acts responsibly.

This Code of Conduct articulates the values that guide our behavior in the global marketplace. Akzis sets these standards not only for us and our employees but also for all our business partners and suppliers. We recognize our duty to uphold these values, reflecting our commitment to our customers.

Inappropriate conduct by even one individual can severely damage our reputation and the trust we have built. Thus, we all share the responsibility to uphold our good reputation and safeguard Akzis from potential harm. By doing so, we continue to establish Akzis as a trusted and reliable partner.

This document outlines our corporate culture, which is built on trust and characterized by fair and respectful interactions. It serves as a binding guideline for ethical, moral, and legally compliant behavior towards our customers and business partners, and it reflects the values our leaders and employees embody daily.

Our motto captures the essence of our ambition: to be the best in tech in every interaction and every facet of our collaboration with customers, partners, and employees. To be the best in tech, we must also be the best in compliance.

3. WHO DOES IT APPLY TO?

At Akzis, compliance—adhering to all applicable rules—is the duty of every employee.

Each Akzis employee is personally responsible for following all laws as well as accepted social norms and must act ethically in their professional interactions. This Code of Conduct, along with all associated regulations, is binding for all managing directors, senior executives, and employees (including permanent, contract, and temporary agency workers) across the entire Akzis organization. It also applies to anyone engaged in any capacity with Akzis, including but not limited to commercial agents, authorized dealers, and service providers who have contracts with us.

Our senior executives play a crucial role by embodying the principles outlined in this Code of Conduct, thereby serving as role models. They are responsible for training their teams on these standards, ensuring compliance, and facilitating appropriate training.

Should any uncertainties or questions arise, employees are encouraged to first contact their immediate supervisor. For detailed inquiries regarding the Code of Conduct, employees should reach out directly to our Legal & Compliance Department, which functions as the independent compliance office for Akzis.

In interpreting these rules, employees should employ their common sense of justice and consider whether an action could be ethically or morally questionable, taking into account country-specific norms and customs. However, when statutory regulations are in place, discretionary judgment is not permitted.

Employees are required to report any violations of laws, this Code of Conduct, or other directives (anonymously if preferred) through our Transparency Line (detailed in Section 8). Any instructions that contradict this Code are not binding and do not justify actions or omissions that breach this Code.

Non-compliance with our Code of Conduct can result in disciplinary actions and might also lead to criminal or civil consequences.

This Code of Conduct may be amended or expanded as necessary to reflect changes in our operations or in the legal landscape.

4. GENERAL RULES OF CONDUCT

4.1 OUR POINTS OF REFERENCE

In the course of performing their designated business roles, all management and employees at Akzis consistently adhere to relevant national and international laws, directives, and standards, along with the stipulations set forth in Akzis’ Code of Conduct.

Our employees act reliably, objectively, and conscientiously. They perform their duties using the best of their professional knowledge and judgment, fully aware of the implications of their actions. They demonstrate a strong willingness to learn and a high degree of self-motivation. It is imperative for all employees to stay informed about the rules (both internal and external) applicable to their areas of responsibility and to seek clarification from the appropriate sources in case of uncertainty.

4.2 APPRECIATION, RESPECT, AND INTEGRITY

In all business dealings, Akzis upholds fundamental human rights and respects the personal dignity, privacy, and rights of individuals. We are mindful of the cultures and customs of the countries where we operate, particularly valuing the personality and individuality of each employee. Our corporate culture acknowledges and embraces the uniqueness and worth of each person, who should be respected for their individual talents and contributions.

4.3 EQUAL TREATMENT

Committed to the principles of diversity, Akzis emphasizes equal opportunity and fair treatment for all employees. As such, any form of unacceptable, degrading, harassing, or discriminatory behavior is strictly prohibited. This includes discrimination or harassment based on nationality, race, skin color, age, political or religious beliefs, disability, gender, or sexual orientation. Examples of prohibited behaviors include overt advances, demeaning comments, inappropriate jokes, offensive language, suggestive gestures, or the display of objectionable material within our facilities. Such conduct is considered harassment even if not intended as such.

4.4 CORPORATE COMMUNICATION

Our business processes are governed by a commitment to honesty, and our actions are performed in good faith.

External Communication

Akzis employees are attentive listeners, personable, and customer-oriented. They demonstrate appreciation for their business partners and effectively advocate their points through strong identification with their arguments. We are careful not to disseminate information that could harm Akzis’s reputation and ensure that confidential information is not shared with those outside the company. For more on confidentiality, information security, and data protection, refer to Section 7.

Internal Communication

Akzis is dedicated to providing employees with all necessary information to excel at their tasks. Regular updates are provided by the Executive Board through various channels such as the intranet, employee newsletters, and large group meetings, detailing internal changes, project statuses, and external developments that might affect our business. This includes proactive communication about compliance-relevant changes.

Communication within Akzis is open, clear, and respectful. Executives actively communicate and swiftly relay essential information and new developments to their teams. In situations involving crisis communication or sensitive topics, communication is coordinated exclusively through the internal Communications Department.

Recognizing the significant role of social media today, we have established Social Media Guidelines, which dictate how we communicate both internally and externally on social platforms. These guidelines are mandatory for all Akzis employees. For information on IT use, see also Section 7 (“Handling of Corporate Information”).

4.5 HANDLING OF CORPORATE PROPERTY

At Akzis, we manage all corporate assets—whether tangible, such as property and equipment, or intangible, such as intellectual property—carefully and purposefully. We structure our business processes and workflows to be rational and efficient, and we steward Akzis’s resources responsibly. Unnecessary expenses are avoided, and business decisions are made based on a transparent commercial analysis of opportunities and risks.

Given our status as a leader in innovation, the research and development sector is highly valued at Akzis. Therefore, we place particular emphasis on protecting our intellectual property, which includes our inventions, academic and technical research, product developments, the creation of new technologies, and self-generated computer software, among other assets. We actively protect this intellectual property by registering or filing for registration of trademarks, patents, and designs, or by granting exclusive or non-exclusive licenses, depending on the requirements.

Moreover, while protecting our intellectual assets, we also respect and uphold all property rights of third parties, ensuring that we do not infringe upon such rights.

4.6 PRODUCT SAFETY, HEALTH, AND THE ENVIRONMENT

At Akzis, our products are synonymous with continuity and the highest standards of quality and safety; these elements are at the forefront of our priorities. We continuously monitor the performance and quality of our technologies and services to ensure they meet our stringent standards.

Akzis develops and delivers products that fully satisfy our customers’ requirements for usage and quality. Collaborating with our customers on risk prevention is also a fundamental aspect of our service.

We are committed to providing our employees with a secure and healthy work environment to prevent any work-related accidents or illnesses. We comply with all applicable workplace safety laws, regulations, and standards in every country where we operate, without exception.

Environmental responsibility is a critical focus at Akzis. We use natural resources efficiently and strive to minimize waste and environmental pollution. We are dedicated to reducing our environmental footprint as much as possible and continually enhancing our environmental protection measures.

Each employee at Akzis is encouraged to make a conscious and proactive contribution to these goals. We regularly review our practices in quality assurance, workplace safety, and environmental protection, and implement enhanced standards where necessary.

For more information on our Environmental Policies, please visit this page.

5. CONDUCT IN RELATION TO BUSINESS PARTNERS

At Akzis, we strive for long-term, cooperative relationships with our customers, suppliers, and other business partners. Our business operations are guided by the following principles:

5.1 CORRUPTION – CORRECT HANDLING OF GIFTS OR INVITATIONS

Corruption involves the misuse of entrusted power for private gain. Forms of corruption include bribery, accepting improper advantages, and other prohibited interventions. Akzis maintains a strict no-tolerance policy towards corruption or bribery in any form, whether direct or indirect.

All Akzis employees are required to comply with the laws of the respective legal systems without exception. The offering or acceptance of gifts, invitations, or other benefits is prohibited if they are intended to improperly influence business operations, or if they might give the impression of such influence.

Acceptable gifts or invitations, such as invitations to business dinners or promotional items like pens and calendars, are permitted within reasonable and proportionate limits, provided they do not appear to unduly influence business decisions. Cash or cash-equivalent benefits, including vouchers, are strictly forbidden, regardless of the amount.

5.2 BUSINESS PARTNERS

We rigorously vet our business partners, especially those like commercial agents or authorized dealers who are closely associated with our name, before initiating any business relationships. This is crucial because improper conduct by a business partner can also implicate Akzis and damage our reputation. In assessing potential partners, we consider not only economic capability and performance but also adherence to ethical conduct and compliance with our Code of Conduct.

Consequently, we avoid entering into business relationships if our evaluation process reveals concerns such as:

• Negative reports from the past.
• Proposals for contract processing through third parties or split payment flows.
• Requests for unreasonably high fees or transaction settlements involving high-risk countries.

5.3 FAIR COMPETITION

Competition and anti-trust laws are designed to protect free competition. Akzis is committed to a free market and to promoting fair competition. We comply with both national and international competition laws and do not engage in any activities, whether actively or passively, directly, or indirectly, that could restrict competition.

Violations of competition rules can lead to substantial consequences for Akzis, including significant monetary fines, civil litigation, and claims for damages by customers or competitors. Prohibited anti-competitive business practices include price fixing, market sharing or allocation of customers, suppliers, territories, or business areas, establishing production restrictions or quotas, submitting fictitious offers (bid rigging), or any other agreements that may suppress or restrict competition.

We recognize that oral agreements and any concerted practices are just as relevant and prohibited as formal written agreements. Therefore, we do not enter into any agreements with competitors that could restrict competition, whether related to prices, terms of sale, production volumes, customer sharing, sales territories, or product groups, etc.

Our know-how is a vital corporate asset (refer also to paragraph 4.5 and Section 7). During discussions or contacts with competitors, Akzis employees are prohibited from discussing confidential matters, such as:

• Prices and terms of sale
• Costs
• Production capacities or inventory levels
• Manufacturing plans
• Market surveys
• Other confidential information

We do not enter into agreements with distributors or customers that would restrict competition, especially in cases where the customer is a retailer. Akzis will never abuse any position of market dominance.

When participating in professional associations and their meetings, we strictly adhere to the principles outlined above. Should we encounter any anti-competitive behavior in these settings, we will immediately withdraw as representatives of Akzis from such committees and associations and notify the relevant manager.

5.4 SUPPLIERS

When selecting providers and suppliers, Akzis conducts a fair and transparent evaluation and assessment, grounded in economic reasonableness.

To consistently ensure high quality for our customers, we impose the same stringent standards on our suppliers that we set for ourselves. These standards are detailed in the “Akzis Vendor Code of Conduct.”

5.5 FOREIGN TRADE AND EXPORT CONTROL

As a global technology company with extensive export activities, Akzis is acutely aware of the complexities and risks associated with cross-border trade. We are committed to full compliance with all relevant national and international regulations governing foreign trade.

From the initial customer inquiry to the final dispatch of our products, we adhere strictly to all trade and export control laws, including all applicable sanctions and embargoes. This compliance ensures that our operations not only meet legal standards but also support global peace and security.

To maintain compliance, Akzis implements robust monitoring systems designed to track changes in export control regulations and sanctions. Our compliance team regularly reviews and updates our policies and procedures to align with these changes.

Additionally, Akzis provides comprehensive training for all employees involved in the export process, ensuring they understand and can effectively apply the relevant laws and regulations. This training includes identifying red flags and understanding the penalties for non-compliance, which can range from fines and trade restrictions to criminal charges.

By prioritizing rigorous adherence to export controls and continuously educating our team, Akzis maintains its reputation as a responsible and trustworthy partner in international trade.

6. AVOIDING CONFLICTS OF INTEREST

At Akzis, we respect the personal lives of our employees, but we recognize that conflicts between personal or family interests and the interests of the company can arise during business operations.

A conflict of interest occurs when personal interests influence, or appear to influence, business decisions. We are committed to acting in the best interests of Akzis, adhering to the principles of this Code, and making professional judgments without being swayed by personal relationships or personal gains.

Given that such conflicts, or at least the appearance of them, cannot always be completely avoided, Akzis requires employees to handle these situations with transparency.

All employees must immediately, fully, and proactively disclose any current or potential conflicts of interest to their line manager; this disclosure does not require a specific request and, where necessary, employees should seek special approval. This requirement also applies if there is only a possibility of a perceived conflict of interest. Situations that particularly warrant this include the following…

• Engaging in secondary employment, especially on a freelance basis.
• Owning shares in a company outside the Akzis Group of Companies.
• Conducting transactions (such as purchasing goods or services, including leasing office space) with oneself, or with family, friends, or businesses owned by them.
• Hiring close relatives or friends within the company.
• Participating privately in organizations whose activities could adversely impact Akzis or its employees.
• Working directly or indirectly for a foreign government known to desire the reduction or termination of democratic processes.

In many cases, actual or potential conflicts of interest can be resolved satisfactorily for all parties involved. To facilitate this, it is crucial and mandatory for potential conflicts to be disclosed promptly and appropriately. The activities listed above always require prior written approval from an employee’s line manager, along with notification to the HR Department/Legal & Compliance Department.

By fostering an environment where such disclosures are handled openly and ethically, Akzis ensures that all business decisions are made in the best interest of the company and uphold the trust placed in us by our partners and customers.

7. PROTECTION OF CORPORATE INFORMATION

7.1 CONFIDENTIALITY OF INTERNAL COMPANY INFORMATION

At Akzis, we take pride in our significant innovative capacity. Our know-how is the engine of our innovation and constitutes one of our most vital business assets. As such, actively protecting Akzis’s intellectual property and preventing unauthorized transfer of knowledge to competitors or other unauthorized third parties is a critical part of our operations.

We handle all confidential company information with utmost care during and after the term of employment, regardless of the form or medium in which this information is processed, transferred, or stored. This includes sensitive information such as pricing, business ideas, strategies, forecasts, financial data, plans, and personal data of our customers, suppliers, or employees.

The unauthorized disclosure of technological and commercial secrets (business and trade secrets) could cause significant damage to Akzis. Therefore, we ensure that:

• Information on new products is not disclosed before patents or other commercial property rights have been secured.
• Confidential information is not discussed with customers, suppliers, or competitors.
• Confidentiality agreements are executed promptly before confidential information is shared, or negotiations with potential cooperation partners begin.

In instances requiring exceptional confidentiality, such as sensitive development projects for customers or corporate acquisitions, we maintain secrecy even among colleagues.

7.2 INFORMATION SECURITY

We utilize IT systems provided by Akzis to perform our tasks and strive to protect these systems and devices from both internal and external misuse. Business-critical data, especially when transferred via mobile storage media, requires extra precaution and should only be stored on such media temporarily for the purpose of transfer. The individual user is responsible for the secure handling and transportation of mobile storage media.

The storage or transfer of business-relevant data using third-party or personal devices, or external services (e.g., cloud storage), is strictly prohibited unless explicitly approved by Akzis in advance. In these cases, specific operational guidelines where and when applicable, such as Work Instruction DAW 10, must be adhered to.

By upholding these practices, Akzis safeguards its proprietary information and technological advancements, ensuring continued leadership and trust in the competitive technology market.

7.3 DATA PROTECTION

The protection and security of data belonging to our employees, customers, and business partners are paramount at Akzis. We treat all information and data with the strictest confidentiality and only collect, store, or process such data when necessary for specified, clearly defined, and legally permitted purposes. We support this commitment through adequate technical and organizational measures, along with regular training and updates for our employees.

Every Akzis employee has a personal responsibility to contribute to data protection and information security.

8. CONTACT INFORMATION & REPORTING MISCONDUCT

At Akzis, if employees identify or even suspect breaches of internal or external rules, they are obligated to report these incidents immediately, as such violations can severely harm our business operations and/or reputation. Ignoring or overlooking such issues can ultimately be viewed as complicity in unethical conduct.

Akzis enforces a zero-tolerance policy towards misconduct. Any allegations of such behavior are investigated thoroughly and discretely. We recognize that violations of legal rules, internal guidelines, this Code of Conduct, or other regulations may result in disciplinary actions against involved employees, and potentially lead to criminal or civil consequences.

The primary point of contact for reporting concerns is typically the employee’s direct line manager. Additionally, breaches of the Code of Conduct can be confidentially reported to the Legal Department, the HR Department, or the employee representative body. All reports are treated with the highest confidentiality.

While it is easier to address a report when the reporter’s identity is known, we strongly encourage anonymous reports as well. Employees or others wishing to report misconduct anonymously can send an email directly to the ethics and policies dept by filling out this form. Our Transparency Line, operated by the Compliance Officers within our internal Legal Department, serves as a whistleblowing hotline and maintains strict confidentiality.

To foster an environment of open communication and trust, Akzis assures that no employee will face any repercussions for making a disclosure in good faith. All reported issues are investigated without exception. During these investigations, confidentiality is maintained, and, if necessary, full support from Akzis is provided to ensure a swift resolution. All necessary resources are made available to conclude investigations efficiently and effectively.

"At Akzis, compliance is not just about following rules—it's about embodying our core values and guiding principles in everything we do."

Gerald S. Wassum

CEO

THE GUIDING PRINCIPLES OF ALL AKZIS ACTIONS

Accountability

• … adhere to all internal and external applicable rules.
• … are committed to the responsible management of Akzis’s assets and avoid any action that could be detrimental to the interests of Akzis.

Knowledge

• … continuously educate ourselves and others about compliance and ethical business practices.
• … stay informed about the latest regulations and best practices to ensure the highest standards of compliance.

Zeal

• … reject corruption in all its forms.
• … enthusiastically support initiatives that enhance corporate transparency and integrity.

Integrity

• … dedicate ourselves to fair and ethical competition.
• … ensure that our dealings with business partners and competitors are honest and transparent.

Safety & Sustainability

• … prioritize quality and safety in all our products and services, minimizing risks to people and the environment.
• … commit to sustainable practices that respect and preserve our natural resources.

These principles are what make us AKZIS, and we proudly uphold them in every aspect of our operations.