Transmedia code of conduct

Preface
In the more than 25 years of existing, the reputation of our company has grown constantly. Our customer’s, supplier’s and business partner’s trust is based on a long-term reliable partnership. From that quarter it is our responsibility to take care of that our products and services are being created in a surrounding in harmony with international standards. This is why we have summarized our expectations to suppliers and service providers regarding work conditions, health and safety, as well as environment and business ethics in our code of conduct. This code is based on the principles of the “UN Global Compact”, the standards laid down in the conventions of the ILO (International Labour Organization) and the electronics industry code of conduct (EICC). In this code of conduct, transmedia’s principles and demands to our customers and suppliers are defined.

1. Objective
• Precondition for a successful business based on our values, is the observing of all voluntarily, regulatory and legal required measures.
• This code of conduct summarizes the basic rules for ethical and legal conduct among each other, as well as among business partners, local authorities and further third parties.

2. Purview
• The purview of this code of conduct is the entire company transmedia GmbH.
• The code of conduct is binding for all employees of the company.

3. Conduct within the context of business activities

3.1 Observing of laws and regulations
• All business activities and processes must be done and arranged in a way that they are in common with all applicable laws and official orders, as well as voluntarily agreed duties and further regulations.
• Each employee is obliged to keep these regulations. All orders leading to a violation of the here described fundamental rules in practising business, are forbidden.
• A violation of legal provisions can lead to incalculable financial damages of the company and a decrease of its reputation. Both claim for compensations against the management, the responsible leaderships and directly involved employees can result from this. In addition can be irregular behavior or criminal acting, which may lead to institute preliminary proceedings of the departments in charge.

3.2 Fair competition
• To avoid risks it is necessary in case of doubt to ask for legal advice, before taking measures that may lead to a violation of the applicable laws or other regulations.
• The distribution of our products as well as the procurement of material and services is bound to national and international regulations, f.e. the competition law.
• Keeping the competition rules by all market participants ensures the equality of opportunity on the market and is therefore indispensable. Even the exchange of information between the competitors is regulated. We expect or competitors, customers and suppliers to keep the competition rules.

3.3 Offering and granting advantages
• Presents, favours, entertaining or other preferences by our employees to third parties, aiming for contracts or unfair advantages for transmedia and other persons, are not allowed.
• Courtesy presents within the scale of common business practices, must be handled by the binding national laws at the time. In case of doubt it is necessary to ask for permission by the superior.
• No employee is allowed to abuse his position or function within the company to gain, demand or accept personal advantages.
• Accepting presents of low value by opportunity is allowed.
• Exceeding presents and granting advantages for oneself must be denied in principle. In that case, employees are obliged to inform the superior in charge about the offered present or conveniences.
• Granting and accepting courtesy presents or entertaining is to arrange in a way that neither the donor nor the recipient have to conceal the situation. Furthermore it mustn’t give the impression that somebody is forced into an obliged relationship of dependence.

3.4 External trade, export and terrorism control
• All national, multinational and further terms of foreign trade must be kept. This contains customs regulations as well as trade- and production controlling. Each employee is obliged to keep the regulations.
• The fixing of transfer-prices complies with the international recognized principles, means complying with the dealing at arm’s-length rule.


4. Conduct opposite the company

4.1 Usage of the company’s tangible assets and resources
• Using the company’s resources for private purposes is not allowed in principle and each case requires permission. This is also in principle valid for usage of telephones, computers (f.e. installing external software), internet and sending emails. To this, regulations and existing agreements must be kept.

4.2 Correct reporting
• Notes and reports (f.e. accounting documents, business reports, audit reports, etc.) that have been made internal or have been given outside must be correct and truthful. Data capturings and further notes must always be complete, correct, on time and system-compatible.

4.3 Public communication
• Official statements, especially towards press and media will only be executed by explicitly authorized personnel.
• For comments of employees in public is the right to freedom of opinion principally valid. Our employees take care that their public appearance will not damage the company’s reputation. When expressing opinions in private, a reference to own position or job within the company should not to happen.



4.4 Second job
• Pursuance of a second job by an employee is only granted after approval by the personnel department in charge.
• Usually the approval will be granted when the second job does not bother the company’s interests.

4.5 Data protection
• Personal data may only be gathered, processed or used, as far as this is necessary for laid down, transparent and legal purposes.
• Regarding the data quality and technical protection, a high standard must be ensured.
• For the persons affected, the use of their data must be transparent and their rights on information and correction, as well as contradiction, blocking and deleting, have to be kept.
• The national law regulations have to be observed.

4.6 Discretion
• Any non-public accessible information is bound to be maintained confidentially and must not be divulged to third neither during nor after termination of employment. This is not valid if a prior written approval by an authorized representative of transmedia is available or the disclosure is based on a legal obligation (f.e. a testimony in legal proceedings). In that case the superior in charge is to inform about the disclosure in prior.
• The direct or indirect use of confidential business information during and after termination of employment for personal advantage, advantage of third or the company’s disadvantage is prohibited.
• Each employee is obliged to contribute in protecting confidential data against access by third according the current guidelines.

4.7 Protection of rights of third
• Each employee has to respect valid protection rights of third, the use without prior approval is not to happen. No employee is allowed to obtain or use secrets of third without authorization.


5 Social principles

5.1 Human rights
• Transmedia GmbH respects and supports the observing of the international recognized human rights

5.2 Anti-discrimination
• When doing business, each employee has to respect the rights, as well as the national, cultural and ethnical characteristics of each person contacted.
• Business decisions shall be oriented by the cause and interests of the company.
• Equality of opportunity and equal treating, regardless of ethnic origin, colour, sex, religion, nationality, sexual orientation, social class or political view, as far as based on democratic principles and tolerance opposite dissidents, will be guaranteed.
• Employees are chosen, employed and furthered only based on their skills and qualification, as long as national right does not stipulate any different criteria.
• These basics are also valid even if individual countries tolerate behaviour and business practice that stand in opposite to this code of conduct.

5.3 Free choice of employment
• The transmedia GmbH rejects any knowing use of forced labour and bonded labour, including debt slavery or involuntary prison labour.

5.4 Child labour
• Child labour is prohibited. The minimum age for the authorization for working in common with the federal regulation at the time is being observed. Their safety and health must not be damaged. Their dignity is being respected.


6. Observation of the code of conduct

6.1 Contact
• In charge for the receipt of hints regarding potential violations against this code of conduct as well as contact for questions in combination with the basic rules of this code are the management of transmedia GmbH and the QM commissioners.
• The contact persons are authorized and obliged to follow relevant hints with the necessary care.
• Every receipted hint will be maintained on a confidential basis.
• The contact persons will initiate necessary steps.
• No disadvantages for the employee will appear by calling the contact person.

6.2 Responsibility of executives
• All executives have to take care that their employees are being informed about the content of this code of conduct.
• Executives are requested to serve as an example by their own behaviour in accordance with this code. Within their sphere of responsibility, executives must have an eye on their employees to keep these regulations and avoid deviations.

6.3 Duty of disclosure
• When having knowledge of violation against this code of conduct, each employee has to inform his/her superior.

6.4 Violations and sanctions
• Violations against this code of conduct can lead to consequences for the employment relationship and its continuation, as well as damage claims.



RoHS

REACH directive

WEEE

The Packaging Regulation

Battery Law

EUP Regulation

Code of Conduct