Compliance means adhering to laws and guidelines as well as regulations and internal instructions within a company. These compliance guidelines are intended to help the employees of ARAN Holding GmbH and the employees of its subsidiaries and affiliates to meet the legal and ethical challenges they face in their daily work. These compliance guidelines are mandatory for all employees and managers of ARAN Holding GmbH and also constitute the code of conduct for the entire group. 

The companies of the ARAN group – subsidiaries and affiliates, or their subsidiaries and affiliates – may either adopt these compliance guidelines or issue their own compliance guidelines provided these do not contradict these guidelines.

Every employee of the ARAN Group has the following obligations:

• All laws and directives as well as regulations and internal instructions applicable in their own area of responsibility must be complied with.
• Fairness and respect govern all activities and business relationships.
• The reputation of ARAN Holding GmbH and the ARAN Group must be respected and fostered.
• Conflicts of interest between business and private matters must be avoided.
• No unlawful advantages must be obtained for oneself or for others.
• Compliance with the provisions on occupational safety, environmental protection and data protection
• Protection of the company's assets against loss and misuse
• Immediate reporting of violations to superiors, the management or the external compliance officer (see point 14.)

The following obligations apply to all managers of the ARAN Group:

• Compliance with the guiding principles of ARAN Holding GmbH
• Evaluation of employees solely on the basis of performance
• Compliance with this compliance guideline in their own area of responsibility

All employees of the ARAN Group must keep themselves informed about the applicable laws, guidelines, regulations and internal instructions relevant for their own area of work. In case of doubt, the respective superior must be consulted. Superiors themselves must seek legal advice if necessary.

The ARAN Group does not tolerate any discrimination on the grounds of race, ethnic origin, gender, sexual identity, ideology, religion, disability or age. Discrimination or harassment of any kind will not be tolerated. This applies in particular to the behaviour towards colleagues, employees and business partners but also to the hiring, promotion or release of personnel.

• Corruption is strictly prohibited.
• It is prohibited to grant, offer or promise unlawful personal advantages to employees or representatives of domestic or foreign companies.
• It is prohibited to carry out acts of bribery with the help of others, e.g. relatives, friends, agents, consultants or intermediaries.
• Promotional items with a value of less than €10 per item are excluded. Gifts of up to €35 per person and year to business partners are permitted in Germany and can be claimed as business expenses.
• It is forbidden to support the unlawful actions of others.

• Strict compliance with antitrust and competition law applies.
• The property rights of third parties must be respected.
• Agreements with competitors, e.g. on prices, quantities and conditions, and market sharing are prohibited.

The disclosure or publication of internal company or group information is prohibited.

• Private interests and the interests of ARAN Holding GmbH and its subsidiaries and affiliates must be strictly separated. It is prohibited to
• place orders with related persons (family, spouses, friends, private business partners) unless their services and conditions stand up to an arm's length test
• place orders with companies in which related persons (see above) work
• place orders with companies in which related persons (see above) hold an interest of more than 5%
• take on secondary employment with competitors
• performing sideline work for business partners
• Exceptions may only be approved by the management or the shareholders' representative.

• Employees of the ARAN Group must not accept personal benefits for themselves or related parties (see above) and must not request or accept promises of such benefits.
• Certain personal benefits such as invitations to dinner or sports events or gifts may only be accepted if
  • no service in return is expected
  • they do not create the impression that a service in return is expected
  • the benefit is within the bounds of generally accepted business practice
  • the benefit does not violate any law.

Employees of the ARAN Group provide authorities with all required information in full, correctly and in good time.

ARAN Holding GmbH and its subsidiaries and affiliates only work with reputable business partners who do not use illegal funds. Employees of the group must comply with the laws against money laundering and immediately report any suspicion of money laundering to the management.

Donations of money or in kind must be approved in writing by a member of the management. Donations exceeding € 1,000 per year require the approval of two members of the management.

The consequences of compliance violations by employees of ARAN Holding GmbH or its subsidiaries and affiliates range from a written warning to termination of the contract of employment and claims for damages by third parties. If laws have been violated, fines or imprisonment may also be imposed.

The external compliance officer is Volker Schmied, lawyer, Am Burgfeld 10, 23568 Lübeck.

Bad Schwartau, 28 February 2025