About us - introduction to Interzero

1. Code of Conduct for the compliance management system
Personal integrity and good judgement are essential qualities for the effective delivery of our services. To achieve this, it is essential that each employee (collectively referred to as "employees" for simplicity) is aware of the relevant rules of our business and is aware of the implications of a particular action or decision.
This Code of Conduct is therefore considered the main guideline for proper conduct in all business matters relating to our company. It sets out in a binding manner the requirements for legally impeccable conduct and is intended to guide all employees as to whether an action or decision is acceptable or not. Our corporate values are also part of the Code of Conduct.
The Code of Conduct is supplemented by individual guidelines and specifications on specific important issues.
In order to remain successful, we have established a compliance management system in our company that helps us all to comply with corporate and legal requirements.

2. Principles and social responsibility
For us, it is a matter of social responsibility and credibility to commit to sustainable business, to ensure social and environmental standards and to care about society as a whole. That is why we have clear rules and standards in this regard.

2.1 Human rights and child labour
We respect internationally recognised human rights and support their observance. We will not tolerate any behaviour that ignores them.
We do not accept illegal employment of children and young people in our company.

2.2 Equal opportunities and non-discrimination
We promote equal opportunity and avoid discrimination in the recruitment of employees, as well as in the promotion or provision of training and continuing education. We treat all employees equally, regardless of gender, age, colour, culture, ethnicity, sexual identity or orientation, disability or religious affiliation.

2.3 Respect for law and order
We expect all employees to comply with applicable laws and regulations. All managers in our company must familiarise themselves with the core values. In this respect, they act as role models and instruct employees to comply with laws and regulations.

2.4 Compliance with social norms
Together with management, we strive to ensure that all employees are treated with dignity and respect. All employees must be able to work in a work environment free from physical violence and sexual, psychological or verbal harassment. We investigate indications of violations with respect for the interests of victims and potential witnesses, regardless of the category involved.
We expect our employees to uphold democratic principles.
We comply with the law to ensure fair working conditions and fair pay, hours and privacy protection.
As part of vocational training, we promote the improvement of employees' professional qualifications through relevant training and continuing education.
We also expect our business partners to meet equivalent social standards in these areas: Human rights, regulatory compliance, child and youth protection, proper treatment of employees, equal opportunities, health and safety, wages and social benefits.

2.5 Health and safety
Occupational health and safety is an essential part of all operational processes in our company.
At all workplaces, we take the necessary measures to prevent accidents and health hazards and to ensure compliance with health and safety regulations. All managers are obliged to support their employees in this regard.
We expect subcontractors and all companies working with us to meet comparable standards.

2.6 Environmental protection / Sustainable development
As a waste management and recycling company, environmental and climate protection as well as the efficient use of resources are of paramount importance to us.
We attach great importance to avoiding or reducing environmental pollution by reducing energy and water consumption, emissions and waste.
We focus on the use of eco-efficient technologies and materials to protect the environment, we prioritise economy and the reusability of materials.
We support the sustainable business activities and environmentally friendly actions of our managers and employees.
Every employee has the duty to treat natural resources with care and to contribute to the protection of the environment and the climate through his or her individual conduct.
Through our sustainability reporting, we provide comprehensive information on our social and environmental performance. This enables customers, employees, suppliers and other stakeholders to understand the social and environmental impact of our operations.

2.7 Quality management
Our quality management system ensures that the products and services we develop and sell meet our customers' requirements in every respect. Accordingly, every employee is responsible for the satisfaction of our external and internal customers.
Along with environmental and health and safety management, quality management is regularly certified externally by the company as part of our integrated management system in accordance with the European ISO standards.

3. entrepreneurial behaviour

3.1 Behaviour towards each other
We place great value on all employees treating each other in a trustworthy, open and respectful manner. We actively fight discrimination, harassment and other derogatory behaviour towards employees.

3.2 Company values
We act in accordance with our values of respect, mutual sharing and responsibility ("we are one").

Knowing each other with RESPECT
We meet with curiosity and interest and acknowledge our differences. We pay attention to manners and tone during the meeting and assume good intentions. We recognise and appreciate (others') performance and productivity.

Permanent EXPERIENCE/INFORMATION EXCHANGE
We actively network and take time to establish personal contacts. In interaction, it is important for us to listen and ask questions. We ensure that knowledge and information is communicated and obtained in a targeted, timely and audience-oriented manner. We are open to change, prioritise and develop ideas.

Acceptance of shared RESPONSIBILITY
We honour agreements and commitments and play the role assigned to us. We move in a common direction and actively make a difference through engagement and awareness of solutions. We treat our own and external resources with care as part of our active support and care.
Values such as respect, sharing of experience and responsibility provide the framework and support for our collaboration. The behaviour of colleagues and managers is more likely and predictable. Everyone can and should contribute to fostering joint collaboration.

3.3 Supporting CHANGE
With a stronger network, respectful and responsible interaction with each other and with the resources of the company and ourselves as individuals, day-to-day issues, projects, as well as conflicts and decisions, can be dealt with more effectively.
We are improving our operations thanks to a sense of belonging to the whole, a greater ease of sharing and the diversity of our most talented employees, who are fearless and dare to develop and test new ideas.

3.4 Avoiding conflicts of interest
In our company, business decisions are made in the best interests of the company.
We avoid situations where our personal or financial interests may conflict with the company.
If, nevertheless, conflict situations arise, they must be resolved in accordance with the law and applicable company guidelines.

3.5 Management of company assets
We treat and use company assets properly and carefully and protect them from loss, theft and misuse. We use tangible and intangible company assets only for company purposes and not for personal use, unless expressly permitted.
Our employees, together with their supervisors, are responsible for ensuring that the type and scope of business travel is always commensurate with the purpose of the trip. We always plan trips with time and costs in mind and follow the company's travel guidelines.

4 Commercial operations

4.1 Preventing corruption
Our company stands for technological competence, innovative strength, customer orientation and motivated, responsible employees. This is the basis for our high reputation and our sustained economic success in the competition.
Corruption is a threat to these guarantees of success and is not tolerated. Bribes" and other unfair influences on business decisions as a means of obtaining an order are not tolerated. We would rather walk away from a transaction or assignment than break the law.
All employees of our company are called upon to actively participate in the effective prevention of corruption in their area of responsibility.

4.2 Gifts, invitations and other benefits
The acceptance or granting of gifts and benefits (gifts, entertainment and other advantages) with a direct factual or temporal link to a business decision should be avoided.
Even the appearance of unfair influence on business decisions must be avoided.
In order to achieve the highest possible level of security in this respect, our company has "anti-corruption guidelines" which, among other things, regulate the possibility of accepting and granting business benefits and gifts (e.g. invitations, hospitality, invitations to events, etc.). We expect our employees and business partners to comply with the requirements set out in these guidelines.

4.3 Donations and sponsorships
We consider ourselves an active member of society and therefore get involved in various ways. We make donations and other forms of social engagement without any expectations.
Donations may not be made to political parties, foundations or institutions affiliated with political parties.
Sponsoring activities are only possible after prior legal review, taking into account relevant findings and considerations and in accordance with the company's internal guidelines.

4.4 Relations with public authorities and offices
In our dealings with the authorities, we always act honestly, transparently and in accordance with applicable law.
In case of enquiries from authorities or other departments that go beyond routine matters, we always inform the responsible manager and, if necessary, the legal department, in order to coordinate further action.

4.5 Fair competition and antitrust law
We are committed to fair competition and compliance with relevant legislation.
Antitrust violations threaten our success and will not be tolerated.
The management and employees of our company do not enter into agreements with competitors, suppliers or other companies that may have an illegal competitive impact.
In case of doubt, the legal department should be involved in the decision.

4.6 Prevention of money laundering
We comply with legal obligations to prevent money laundering and do not engage in money laundering activities. All employees are encouraged to check, verify unusual financial transactions through the Legal Department. in case of doubt, in particular to check cash transactions that may raise suspicions of money laundering.

4.7 Protection of intellectual property
With respect to the protection of intellectual property, we comply with applicable law. Intellectual property is protected by law (e.g. copyright, trademarks or patents) or as a trade secret.
This is what we are sticking to. However, the legal situation often depends on the specifics of the case. That is why, in cases of doubt, we involve the legal department in the assessment.

4.8 Financial integrity
Our company's business transactions and business records must be correct and orderly. We record and document all business transactions, assets and liabilities in accordance with legal requirements.
Documents relating to financial accounting may not contain intentionally false or misleading entries. Any form of balance sheet manipulation is prohibited.

5 Confidentiality and communication

5.1 Confidentiality
Our company's trade secrets are protected and treated with strict confidentiality.
Trade secrets include all documents that are not suitable or intended for external dissemination, such as contracts, draft contracts, planning data, financial data, personnel information, intellectual property and any other business information (confidential information).
We share confidential information internally only with those employees who are connected with the company.
For digital and confidential information, special protection mechanisms should be used.
When sending e-mails, we ensure that confidential texts and attachments are only sent to authorised persons.
We do not share confidential or sensitive company information on social media.
Disclosure of confidential information to third parties is only considered if it is in the interests of the company and does not violate legal or contractual provisions. Before disclosing such confidential information to third parties, the conclusion of a confidentiality agreement must be checked in each case. In case of doubt, advice should be sought from the legal department.

5.2 Communication with the public
We respect the right to freedom of expression and the protection of personal rights and privacy.
Every employee must be aware that he or she can also be seen as part of and representative of our company in the private sphere. Therefore, all employees are called upon to uphold the company's reputation and standing through their conduct and public appearances.

5.3 Marketing and advertising statements / reports
We always provide truthful information in marketing and advertising about our services. False statements and misleading information can damage both our customers and our reputation. We place great value on open and truthful reporting and communication of the company's business transactions to investors, employees, customers, business partners, the public and government agencies.

5.4 Data protection
When we collect, store, process or transfer personal data (e.g. name, address, telephone number, date of birth, etc.) of employees, customers or other third parties, we act with the utmost care and ensure compliance with applicable laws and regulations. In case of doubt, please consult the company's data protection officer.

5.5 Transparency of information
We ensure the fast and efficient exchange of information within the company. Information is communicated correctly and completely to other authorised persons. Company-relevant knowledge is not unfairly concealed, falsified or selectively communicated.

6. Application and contact persons
We actively promote communication of the principles underlying this Code of Conduct.
We encourage our employees to address their concerns and issues openly. Therefore, employees who raise concerns about company procedures in good faith are not disadvantaged.
Our managers have a special role as role models and are the first point of contact for questions regarding their understanding of the regulations. As part of their management responsibilities, they prevent unacceptable behaviour or take appropriate measures to prevent violations in their area of responsibility.
Employees and business partners may contact the external lawyer and ombudsman at the address below if they have any questions about this Code of Conduct or if they have any indication of a violation of the law or guidelines.
All information will be treated as confidential by the lawyer and the ombudsman.
You can contact him at the following contact details:
Compliance Officer, Legal Services

7. Decision-making aids
If you are unsure whether a decision on a case is in line with company policy, the following questions may help you:

• Is my decision legal and in accordance with company regulations?
• Can I make a decision in the best interest of the company, free from competing personal interests?
• Can I reconcile this decision with my conscience?
• Can I easily reveal this decision to the outside world?
• Will this decision also be subject to third party review?
• Does my decision preserve the good reputation of the company?

If you can answer "Yes" to all questions, your decision is probably justified. If you are in doubt, please contact the contact persons listed.
Status: 05/2020