CUSTOMER VALUE THROUGH INNOVATION

Code of Conduct
Secure Connections

Valid from April 1, 2020 normagroup.com

TABLE OF CONTENT NORMA Group || CODE OF CONDUCT

Table of Content
1. Introduction 5
2. What “COMPLIANCE” is about 6
3. Raising Concerns and reporting Impropriety 7
4. Personal Integrity 8
4.1. Conflicts of Interest.............................................................................................................................8
4.2. Insider Trading .....................................................................................................................................9
5. Corporate Integrity 10
5.1. Anti-Corruption Law Compliance ............................................................................................. 10
5.2. Anti-Money laundering................................................................................................................... 11
5.3. Customer & Supplier Relations, Agents & Consultants..................................................... 12
5.4. Accurate Books, Records and public Disclosures ............................................................... 13
5.5. Cooperation with Investigations and Government Reporting........................................ 13
5.6. Embargo Laws, Trade Sanctions, Export Control ............................................................... 14
5.7. Fair Competition and fair Dealing ............................................................................................. 14
5.8. Antitrust ............................................................................................................................................... 15
5.9. Information Security & Data Protection................................................................................... 16
5.10. Environmental Protection............................................................................................................ 17
6. Employment & human Rights 18
6.1. Human Rights.................................................................................................................................... 18
6.2. Health & Safety................................................................................................................................. 18
6.3. Fair Employment Practices........................................................................................................... 18
7. NORMA Group Assets 19
7.1. Protection and proper Use of NORMA Group Assets........................................................ 19
7.2. Confidential and Proprietary Information............................................................................... 19
7.3. Social Media....................................................................................................................................... 20
7.4. Copyrights, Patents, and Trademarks...................................................................................... 20
8. Contact 21
9. Review 22

3
INTRODUCTION NORMA Group || CODE OF CONDUCT

1Introduction
Dear reader,
There is a norm we live and work by at NORMA Group: to build ‘secure’ con-
nections for every day of our working lives.
As a leader in Joining Technology, secure connections In every instance we expect you to act honestly, fairly
are the bedrock of everything we do. This fires our and with a view towards “doing the right thing”. Illegal,
commitment for building and maintaining integrity, unethical or dishonest behavior is strictly forbidden and
reliability, and transparency in our business practices. will be investigated and have consequences for involved
We are determined to drive positive change and make persons.
a relevant impact through the way we conduct our
business and build relationships with each other, as With this Code of Conduct we provide a guideline for
much as with every other person and business we come you to help understand the red line between ethical
in contact with. This is what Compliance at NORMA and unethical behavior. It is designed to help you make
Group is all about – because secure connections are the the right decisions but, obviously, cannot cover every
fundamentals of our business. situation you might have to deal with in your daily
business.
The reputation and integrity of NORMA Group SE and
its direct and indirect subsidiaries (“NORMA Group”) is a We expect that all our employees conduct themselves in
valuable asset that is vital to NORMA Group’s success. a manner consistent with our values and commitment to
ethical conduct. In case of questions regarding this Code of
Breaches of law or unethical behavior can destroy this Conduct or if you have suspicions of violations of this Code
reputation and cause great disadvantages for all of of Conduct, please contact your superior, a more senior
us. You and every other director, officer, manager and manager or NORMA Group´s Compliance organization.
employee of NORMA Group are responsible for our name
and our integrity. Maintal, April 1, 2020

Dr. Michael Schneider, Jan Löffler

Chairman of the Management Board/CEO Chief Compliance Officer

Compliance
Secure Connection

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 WHAT “COMPLIANCE” IS ABOUT NORMA Group || CODE OF CONDUCT

2What “COMPLIANCE” is about

“COMPLIANCE” is to act in accordance
with laws, external regulations as well as
internal regulations and guidelines.

Simply spoken:
COMPLIANCE is “correct behavior”.

Being a NORMA Group employee, you are expected at all for all of us. If you are uncertain of whether or not a
times to conduct NORMA Group business in accordance particular action or transaction violates applicable laws,
with all applicable national, regional, local and foreign rules or regulations, please do not hesitate to contact
laws, and applicable NORMA Group policies. NORMA NORMA Group´s Compliance organization.
Group condemns all acts that violate any applicable law,
rule or regulation, even when such action appears to be This Code of Conduct will provide you with an overview
in NORMA Group’s best interest and is motivated by your of the most important topics in the area of “Compliance”.
best intentions. In most cases, simply doing the right It also provides guidelines that help you assess critical
thing will avoid any violations of law. However, some situations and choose ”correct” behavior.
legal concepts and areas of regulation are a challenge

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RAISING CONCERNS AND REPORTING IMPROPRIETY NORMA Group || CODE OF CONDUCT

3Raising Concerns
and reporting
Impropriety

NORMA Group encourages you to openly discuss The Whistleblower System can also be used for
Compliance issues. Often, asking a question is the best Compliance-related questions. However, we encourage
way to determine whether an action is proper and our staff to directly and openly contact a member of the
to ensure that we comply with applicable laws. Any Compliance organization in this regard.
question concerning this Code of Conduct, our guidelines
and policies can be addressed to NORMA Group´s Since internal reports are often vital to detect misbehavior
Compliance organization. and to take the necessary steps, a notification made in
good faith shall never cause any disadvantages for the
If you become aware of, or reasonably suspect that there reporting person.
will be or has been a violation of any laws, rules, NORMA
Group’s policy or this Code of Conduct, we expect you to Every whistleblower-report will be taken seriously and
take action. In this case, please consult your immediate followed-up by our Compliance organization who will
supervisor. He or she is responsible for taking necessary provide for an answer to the whistleblower within a
steps to resolve the issue. In case your immediate period of three months maximum.
supervisor does not take the necessary measures or in
case he or she may be involved in the alleged misconduct,
please contact a more senior manager or a member of
the Compliance organization. (The contact details of all
members of the Compliance organization can be found on
the intranet (Our Company/ Compliance), or the following
E-Mail contact:

[email protected].

If you wish to stay anonymous, you, any other NORMA

Group employee, as well as any third party can report
any kind of actual or alleged misconduct relating to
NORMA Group using our Whistleblower System.
The Whistleblower System is a web-based reporting
platform backed by the latest security technology. Only
selected members of the Compliance organization have
access to incoming notifications.

! https://www.bkms-system.net/normagroup

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 PERSONAL INTEGRITY NORMA Group || CODE OF CONDUCT

4Personal Integrity

4.1. CONFLICTS OF INTEREST

Regarding work-related aspects, you are expected to

put the interests of NORMA Group ahead of your per-
sonal interests or those of any other person or com-
pany. You must avoid Conflicts of Interest.

What is a Conflict of Interest?

A business decision affecting NORMA Group that

you (also) take because of personal interests and
which you would not have taken in this form if
you were not biased by personal interests. In a
Examples of Conflicts of Interest include:
nutshell, the risk of a Conflict of Interest always „„ Having outside employment or business
arises, if you make business for NORMA Group or civic affiliations or ventures (including
with companies (partly) owned by you, family
board memberships) that interfere with
members, friends or other persons close to you.
your ability to perform your duties for
NORMA Group in an objective, effective and
In such situations, there will always be the
timely manner.
suspicion that you are not acting in the interest
of NORMA Group. In your own interest you should „„ Having a direct or indirect financial interest
even avoid the risk that someone could believe in a customer, vendor or supplier.
you have a Conflict of Interest. If, however, a
„„ Engaging in personal investment or
Conflict of Interest, due to specific circumstances,
cannot be avoided, you are obliged to report this business ventures that compromise or
to the Compliance organization before entering give the appearance of compromising
a business relationship and request written your ability to make decisions in the best
approval. interests of NORMA Group.

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PERSONAL INTEGRITY NORMA Group || CODE OF CONDUCT

4.2. INSIDER TRADING

NORMA Group SE and some of the companies we do business with are publicly traded companies. This
puts you in a position to potentially obtain so-called “insider information”.

What is Insider-Trading? Non-public information includes, but is not

Insider Trading means to make an investment limited to:
based on non-public information that was „„ development of new products or services;
illegally obtained to have an illegal advantage
„„ unannounced mergers and acquisitions;
towards the market.
„„ advance notice of changes in senior
management;
Regardless of whether you are listed in an insider
„„ non-public financial results; and
list or not, you must refrain from using or disclosing/
communicating any non-public information you have „„ pending or threatened litigation.
learned about NORMA Group SE or any other publicly
traded company for purposes of making investment
The consequences of violating insider trading laws can
decisions.
be severe. In the event that you may have inadvertently
disclosed insider information or have questions about
whether your actions or the actions of another person
may violate the Code of Conduct or insider trading
laws, please contact the Compliance organization or
Legal Dept.

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 CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5Corporate Integrity
5.1. ANTI-CORRUPTION LAW COMPLIANCE

One of the biggest risks in international business relationships is corruption. If employees of companies en-
gage in corruption, this does not only result in penalties for the involved persons but also for the companies
they represent. Very high fines, bans from markets or reputational damage are just some of the possible
consequences.

Never let your actions be driven by the goal to

„„ improperly obtain or retain business,

„„ to gain influence,

„„ favorable treatment or

„„ any other advantage

for NORMA Group or another party.

You are furthermore expected never to request, never to

agree to receive, and never to accept any such improper
advantage for you personally or for another person or entity.

The best way to avoid corruption is to always act

transparently and to use a common sense approach.
However, to facilitate decision-making in this regard,
NORMA Group’s Anti-Corruption Policy1 identifies
the prohibited conduct and defines clearly which
What is Corruption? advantages to be given or received are subject to
Corruption, in the broadest sense, means mandatory pre-approval.

„„ giving a personal advantage to public

officials or to representatives/employees of a Special Risk: Public Officials
company
Anti-Corruption laws around the globe are
„„ influencing these persons with regard especially strict when it comes to giving/promising
to their duties towards their employer/ personal advantages to public officials. In this
authority in favor of the giving person regard, may the public official be a customer or
an authority involved in your business (e.g.) for a
NORMA Group does not tolerate corruption or bribery permit, allowance, etc., the granting of personal
in any form. All applicable anti-corruption laws must be advantages, even if they are very small, are strictly
followed. Anywhere in the world you are expected never prohibited without prior approval by NORMA
to engage in any kind of corrupt conduct. Group´s Compliance organization.

1.
 ORMA Group´s Anti-Corruption Policy can be accessed under: https://www.normagroup.com/Compliance
N
It is also available on the intranet pages of NORMA Group (Our Company/Compliance)

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CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.2. ANTI-MONEY LAUNDERING

NORMA Group is committed to complying with all applicable anti-money laundering laws, rules and
regulations.

Be alert, in particular, to the following circumstances:

What is Money Laundering?
In the broadest sense, money laundering „„ Cash payments
means to use illegally “earned” money in a „„ Country where a business partner is located
separate business to disguise its origin and to deviates from country where its bank is located
transfer it into legitimate assets. ”Dirty” money
„„ Unreasonable splitting of transactions
is thus to be ”laundered clean” again to return it
to the regular financial and economic cycle. „„ A business partner uses multiple bank accounts
or suddenly changes its bank accounts without
reasonable explanation
Money laundering results in high fines and
other severe consequences – both for the
company and the people involved, e.g. high Therefore, in case you recognize any suspicious facts, you
fines and long prison sentences. are obliged to immediately consult with NORMA Group
Compliance or NORMA Group´s Treasury Dept.

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 CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.3. CUSTOMER & SUPPLIER RELATIONS, AGENTS & CONSULTANTS

Our success depends upon deep and trusting relationships with our customers and suppliers. When dealing
with customers and suppliers, you must act ethically, fairly, courteously, competently and timely.

In furtherance of these objectives: From time to time, our business may require us to hire
agents, consultants, or other third parties for rendering
„„ You must act in a professional and courteous
manner at all times and avoid misleading services regarding the sale of NORMA Group products
customers and suppliers. and receiving salaries, provisions, rewards, finders’ fees
or similar consideration from NORMA Group (“Third Party
„„ You must never willingly or incomprehensively give
Representative”).
false statements towards customers, authorities
or other third parties about technical specifications
of NORMA Group’s products or give misleading If such Third Party violates the law, this might create
statements regarding their quality. liability risks for NORMA Group. This does in particular
apply to any case of corruption. Therefore, NORMA
„„ You must only make claims about our services that
Group carefully chooses Third Party Representatives after
you know to be true or have adequate information
analyzing potential Compliance-Risks and monitors Third
to support.
Parties Representatives already employed. Please refer to
„„ You must not misuse or disclose confidential or our Anti-Corruption Policy3 for more details.
proprietary customer or supplier information.

„„ You must truthfully represent the nature and

quality of our services, prices, contractual terms
and other information.

„„ When dealing with suppliers, vendors or

customers, you must ensure full Compliance with
our Anti-Corruption Policy.2

2.
 ORMA Group´s Anti-Corruption Policy can be accessed under:
N
https://www.normagroup.com/Compliance
It is also available on the intranet pages of NORMA Group (Our Company/Compliance).
3.
Please refer to footnote 2

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CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.4. ACCURATE BOOKS, RECORDS AND PUBLIC DISCLOSURES

The effective operation of NORMA Group’s business, reflect NORMA Group’s transactions and provide full, fair,
and the integrity of NORMA Group’s public disclosures, timely, accurate and understandable disclosure.
is dependent on accurate business records. You must
prepare and maintain all company records accurately If you are responsible for any aspect of our internal
and honestly. You must maintain all paper and electronic accounting controls and financial and tax reporting
records in accordance with applicable laws on data systems, you must be vigilant in recording entries
retention and NORMA Group’s policies on records accurately and honestly and in a manner consistent with
management, including applicable retention periods. all legal requirements. If you are uncertain about proper
recording of company transactions or accounting or tax
No false or misleading entries must be made in any matters, you should consult with a manager.
books, records or accounts of NORMA Group and no
NORMA Group funds must be used for any purpose You must not take any action to fraudulently influence,
other than as described in the documents supporting the coerce, manipulate or mislead any auditor engaged
disbursement. in the performance of an audit of NORMA Group
financial statements. Complaints or concerns regarding
NORMA Group personnel engaged in the preparation accounting, internal accounting controls or auditing
of these filings, submissions and communications matters should be reported as indicated in section 3 of
must endeavor to ensure that NORMA Group’s filings, this Code of Conduct.
submissions, and communications accurately and fairly

5.5. COOPERATION WITH INVESTIGATIONS AND GOVERNMENT REPORTING

If you are notified by any member of the Compliance

organization or Legal Counsel of NORMA Group that
you have electronic or paper records that are relevant
to anticipated or pending litigation, investigation inquiry,
formal proceeding or audit, you must follow the guidelines
for retaining documents set forth in that notice. Do not
destroy any records contained in the notice.

You must follow all requests made by NORMA Group

management or the government for information or
records related to any investigation or government
report. Do not conceal, alter, falsify or destroy any records
management or the government requests, as this could
lead to criminal prosecution for you and NORMA Group.

If you believe documents are being concealed, altered,

falsified or destroyed, you should immediately report this
in accordance with section 3 above.

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 CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.6. EMBARGO LAWS, TRADE SANCTIONS, EXPORT CONTROL

NORMA Group’s international operations can trigger recognize embargoes put in place by another country.
issues under applicable trade sanctions and trade You must act in accordance with all applicable laws,
embargo laws. Trade embargo laws and regulations rules and regulations relating to embargo laws and trade
generally prohibit companies located in a particular sanctions. NORMA Group monitors these embargoes
country from doing business in another specific country. and sanctions and implements controls to make sure we
On the other hand, sometimes a country makes it illegal follow them.
for companies operating within their jurisdiction to

5.7. FAIR COMPETITION & FAIR DEALING

NORMA Group’s mission is to maintain its status as a Group through fraud, concealment, misrepresentation
global market and technology leader in Engineered Joining of material facts, or illegal means. NORMA Group also
Technology solutions through ethical and legal conduct, does not condone theft of trade secrets and you must
and not resort to anti-competitive behavior. Although avoid unauthorized use of any patented, copyrighted,
we recognize the importance of identifying NORMA privileged or confidential information.
Group’s strengths and our competitors’ weaknesses,
you may not seek a competitive advantage for NORMA

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CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.8. ANTITRUST

NORMA Groups strictly prohibits any behavior

To give you an idea on possible antitrust related
that could give reason to suspect violations of matters, please read the following examples of
applicable antitrust law. prohibited behavior carefully and refrain from:

„„ communication about sensitive information

with competitors, for example prices,
output, capacities, sales, bids, profits, profit
margins, costs, methods of distribution
or any other parameter that determines
or influences NORMA Group’s competitive
behavior;

„„ informal discussions and unwritten agree-

ments in relation to behavior that could have
an impact on competition;

„„ communication with competitors to:

– raise, lower or stabilize prices or other

terms and conditions of sale;

– influence the award of a tender;

What is a Violation of antitrust law?

Any communication with competitors or – boycott or refuse to deal with certain

customers that aims at restricting competition customers or suppliers;
and is in disfavor of the free market principle.
– reduce output of services;

 – allocate clients, services, market,

This includes but is not limited to any attempts of production programs or geographic
competitors territories;
„„ to secretly agree on pricing, purchasing
– coordinate on employees’ wages and
conditions or
benefits, except as permitted by specific
„„ to split any markets, regions or customers or to labor laws;
boycott third parties.
– submit offers when not intending to
obtain a contract.
Even arrangements with resellers that aim at providing for
maximum or minimum prices are illegal. The consequences „„ influencing the resale prices charged by our
of violating antitrust laws are severe, both for individuals as customer or set a minimum resale price;
for corporations. Even the appearance of anti-competitive
behavior must be avoided. To avoid participating in „„ providing our services at predatory or
prohibited anti-competitive behavior, always act as below-cost pricing;
transparent as possible when it comes to competitors
„„ entering into exclusive arrangements that
and contact your superior or a member of the Compliance
deny a competitor access to an excessive
organization when you have the feeling that any behavior
proportion of the market.
related to NORMA Group could restrict competition.

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 CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.9. INFORMATION SECURITY & DATA PROTECTION

Being confronted with the global phenomenon of ever-increasing collection, storage, transfer, and use
of data through modern technology (e-mail, internet, mobile phones, social networks, etc.) and the
consequent increased risk of data loss or misuse, NORMA Group is committed to protecting confiden-
tiality, integrity and availability of information and to protecting the privacy of employees, customers
and business partners.

What is Information Security? NORMA Group treats personal data of employees,

customers, suppliers and other affected individuals
Information Security’s primary focus is confidentially and protects their personal data at all
the balanced protection of confidentiality, times.
integrity and availability of information.

Information Security encompasses not only NORMA Group only collects and processes personal
the security of the IT systems and the data pro- data, if NORMA Group is required to do so by law or if
cessed with them, but also the security of in- necessary for business or employment purposes. NORMA
formation that is not processed electronically. Group thereby ensures to only process personal data in
accordance with the applicable data protection regulations
and to adhere to the rights of all affected individuals.
Measures undertaken to ensure confidentiality are
designed to prevent sensitive information from reaching
What is Data Protection?
the wrong people. Access must be restricted to those
authorized to view the data in question (e.g. via data The aim of Data Protection is to secure the
encryption, user IDs and passwords). Measures fundamental right to informational self-
undertaken to ensure integrity are designed to prevent determination of the individual. It protects
data from unauthorized changes or removals (e.g. via file personal data against misuse.
permissions and user access controls). Availability ensures
What is Personal Data?
access to information when needed.
Personal data is data that can be assigned to a
We expect you not to make any transcripts or copies specific person. This includes, but is not limited to,
of information for other than operational purposes and
„„ Name,
not to access information that is unrelated to your own
activities. Do not save/store information in insecure „„ Address,
locations (e.g. public clouds).
„„ Telephone number,

Confidentiality of postal correspondence and tele‑ „„ E-mail address,

communications must be maintained at all times. There‑ „„ and information that can be linked to a
fore, also pay particular attention to IT aspects of specific person by linking it to other data
confidentiality such as data security and protect your
sources (e.g. IP address, customer number).
computer from unauthorized access by necessary
appropriate measures (e.g. changes of password). Please For more details, please consult NORMA Group’s Data
consult the ICT policies and contact NORMA Group´s
Protection policies or contact NORMA Group´s Data
ICT Risk & Security Manager in case of any question.
Protection Office:

[email protected]

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CORPORATE INTEGRITY NORMA Group || CODE OF CONDUCT

5.10. ENVIRONMENTAL PROTECTION

NORMA Group complies with all applicable environmental laws, standards and requirements and
takes a proactive and long-term view on environmental matters to prevent pollution and continuously
improve environmental performance.

Environmental protection and product safety is and manufacturing its products. We support national
of great importance, not only for NORMA Group’s and international efforts to ensure the health of the
reputation but also for our customer’s safety and future environment. It is everyone’s responsibility to take care
generations. NORMA Group is conscious of the great that environmental laws are properly observed and
importance of environmental protection in developing resources are used efficiently.

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 EMPLOYMENT & HUMAN RIGHTS NORMA Group || CODE OF CONDUCT

6Employment
& Human Rights
6.1. HUMAN RIGHTS 6.2. HEALTH & SAFETY

Aware of its social responsibility NORMA Group is It is the policy of NORMA Group to comply with all
committed to ensure that all people working for NORMA applicable environmental health and safety laws and
Group or on its supply chain are treated fairly, equitably regulations. NORMA Group is committed to creating and
and in consistency with fundamental human rights. maintaining a safe working environment and preventing
We respect and promote the principles of the Universal workplace injuries. You are responsible for recognizing
Declaration of Human Rights and the ILO Declaration on hazards, taking steps to correct them, making certain
Fundamental Principles and Rights at Work. We strongly that safe working conditions exist and that safe
condemn forced labour, child labour and all practices operating practices are observed. If you observe an
in which people are exploited or exposed to dangerous unsafe condition, you should warn others, if possible,
conditions. and immediately report the condition to your manager or
local workplace safety contact.
NORMA Group does not tolerate any form of forced or
compulsory labour at any of its subsidiaries or suppliers
in any form. Any person employed or engaged by our 6.3. FAIR EMPLOYMENT PRACTICES
suppliers must have voluntarily chosen to do so. Any type
of slave or forced, bonded or prison labour is prohibited.
NORMA Group is committed to complying with all
Employees must not be in any way restricted in their
laws relating to freedom of association, working
personal freedom of movement.
time, wages and hours, as well as laws prohibiting
forced, compulsory and child labour, and employment
We comply strictly with laws regulating the minimum discrimination.
age for employment and other employment conditions.
The minimum age for employment at NORMA Group Any person employed or engaged by NORMA Group
corresponds to the ILO Conventions No. 138 and No. 182 or their suppliers is entitled to form or join an employee
and/or the age prescribed under local law if this is higher. organization (or union) of their choice with the aim of
conducting collective bargaining and defending their
interests.

All persons employed or engaged by NORMA Group

or their suppliers must be treated equally. We do not
tolerate discrimination with regard to sex, religion,
age, race, social background, caste, nationality, ethnic
and national origin, membership in an employee
organization, disability, sexual or political orientation
or any other personal characteristic.

NORMA Group condemns and will not directly or indirectly

support harsh and inhumane treatment including any
sexual harassment, sexual abuse, corporal punishment,
mental or physical coercion or verbal abuse of workers,
nor the threat of any such treatment.

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NORMA Group ASSETS NORMA Group || CODE OF CONDUCT

7NORMA
Assets
Group

7.1. PROTECTION AND PROPER USE OF NORMA GROUP ASSETS

NORMA Group property and assets may only be You may not provide third parties with any NORMA
used for legitimate NORMA Group-related busi- Group property, unless you are authorized to do so in a
legitimate business transaction.
ness purposes. You are responsible for ensuring
that NORMA Group’s property is not misused, wa-
NORMA Group property includes, but is not limited to:
sted or damaged.
„„ Work equipment (i.e. laptops, internet, email,
mobile phones), including approved personal use
Unless authorized to do so, you are also prohibited from
authorized in accordance with applicable NORMA
using or taking NORMA Group property for your personal
Group policies.
benefit or gain.
„„ Office supplies, materials and services.

7.2. CONFIDENTIAL AND PROPRIETARY INFORMATION

Confidential and proprietary information is one

Examples of confidential or proprietary informa-
of a company’s most valuable assets.
tion include inter alia

Without prejudice to any obligation contained in your „„ non-public sales, pricing and marketing strategies;
employment contract or any other document, you may „„ accounting information and non-public
not disclose NORMA Group’s confidential and proprietary financial data, customer lists and contacts;
information without authorization.
„„ non-public information regarding NORMA

Similarly, you may not disclose the confidential Group’s products, processes, practices,

information of NORMA Group’s customers, vendors or methods, designs, developments, production

suppliers without authorization. manufacturing or services;

„„ development or experimental work in progress;

These obligations apply whether or not the information
„„ trade secrets of customers and NORMA Group;
is specifically designated as “Confidential” or
“Restricted”, and extend beyond your employment with „„ possible acquisitions and divestitures; and
NORMA Group. „„ non-public information relating to customer
agreements.

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 NORMA Group ASSETS NORMA Group || CODE OF CONDUCT

7.3. SOCIAL MEDIA

Social media forms an important part of today’s business and is becoming more and more important.
Social media include social networks (e.g., Twitter, Facebook, LinkedIn), blogs, wikis and video strea-
ming websites (e.g. Youtube). NORMA Group manages the contents of the official company pages on
social media in a centralized manner. Therefore, do not create any NORMA Group pages on any social
media platform.

Keep in mind that postings, both personal and Therefore, when you are active on social media, you
professional, may ultimately be connected to NORMA must
Group, even if your affiliation with NORMA Group is not
„„ be honest, accurate and respectful;
disclosed.
„„ be open about your affiliation with NORMA Group
if it is relevant to the issue;
Have a healthy distrust especially when it comes to
business-related topics in social networks or other public „„ make it explicitly clear that your opinions are
portals. personal and may not represent the position of
NORMA Group.

Please also consult NORMA Group’s Social Media

Guidelines.

7.4. COPYRIGHTS, PATENTS, AND TRADEMARKS

Intellectual property forms an important part of our economic success and the success of our business
partners and customers. You are expected to protect our intellectual property, including any patents,
trademarks, trade secrets, technical and scientific knowledge, and expertise developed in the course
of our business. You are required to respect the intellectual property of others. Unauthorized dupli-
cation or misappropriation of another’s intellectual property may subject you and NORMA Group to
significant fines and criminal penalties.

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CONTACT NORMA Group || CODE OF CONDUCT

8Contact
If you have any questions regarding this Code of Conduct or Compliance, please contact NORMA
Group Compliance or any member of the Compliance organization.

Chief Compliance Officer Group Compliance Officer

Jan Löffler Dr. Gisa Ortwein

Edisonstr. 4 Edisonstr. 4

63477 Maintal 63477 Maintal

Germany Germany

Phone: +49618161027610 Phone: +49618161027611

Email: [email protected] Email: [email protected]

The contact details of all members of NORMA Group´s Compliance organization can be found on the
intranet (Our Company/Compliance).

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 REVIEW NORMA Group || CODE OF CONDUCT

9Review
This Code of Conduct is subject to regular review by NORMA Group Compliance and can be amended
due to changes in applicable law or in NORMA Group’s business. It is therefore necessary to make
sure that you rely on the up-to-date version which can be accessed under:

https://www.normagroup.com/Compliance

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3-1Z-6-200301-SE

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