Compliance

The following guiding company principles describe the desired ethically correct behavior in all business situations in accordance with applicable law and relevant internal guidelines. All LEVACO employees bear responsibility for compliance with the guiding company principles.

LEVACO undertakes to provide its employees with the necessary information, to train and support them appropriately and thus to enable them to comply with these guidelines.

Definition: Bribery is a form of corruption and can be committed against decision-makers in authorities or private companies. Bribery is aimed at inducing an illegal (official) action (e.g. the issue of approval to which no right exists).

Position LEVACO: LEVACO rejects all types of bribery! Bribery undermines the reputation and corporate integrity of LEVACO Chemicals GmbH. It constitutes a criminal offense and could lead to damages proceedings against the LEVACO staff or the corresponding company.

Payments of LEVACO to official representatives: Monetary or material assets may not be given – either directly or indirectly via third parties – to persons occupying a public office or with political influence! The same applies to institutions in which it is known that these persons have a strong interest. The only exceptions are situations in harmony with the applicable laws. This prohibition applies to the same extent to the use of private funds or physical resources and to any participation in direct or indirect payments made, for example, but not only, by advisers, consultants, suppliers or other third parties.

Definition: Acquisition of an advantage, especially from official representatives, through the inducement of a legal (official) action (e.g. acceleration of an approval process). The granting of the advantage must not lead to an advantage for the person granting the advantage that is in conflict with the applicable laws.

Position LEVACO: The granting of an advantage to a person occupying a public office is possible only in a few exceptional cases and within narrow boundaries: the advantage is not prohibited within the framework of the applicable national laws; it is moderate and in line with the usual local conventions; it is recorded correctly and the payment took place in the country in which the services are rendered.

Evaluation of national laws: Some national laws strictly prohibit the issue and acceptance of advantages to or by persons occupying public offices.

On the other hand, in some regions of the world, it is the custom to reciprocate and to reward certain services with a tip. While the payment of bribes is prohibited, such payments may be permitted under the condition that they take place on a modest and moderate scale.

Principles: LEVACO Chemicals GmbH pursues long-term, partnership-based relationships with its business partners. Therefore, the principles of quality, performance, moderateness and usual competitive prices apply to all business processes of LEVACO Chemicals GmbH in which third parties are involved. Neither LEVACO Chemicals GmbH nor a representative may offer or grant business partners or their representatives any form of illegal price reductions or other impermissible payments, gifts or conveniences directly or indirectly or request such from them.

Dealings with customers and suppliers: The following special principles apply to our customers and suppliers:

• The granting of gifts is permitted exclusively within the framework of the applicable laws and business conventions. They must not bring the recipient into an invidious situation in that he or she, for example, violates compliance guidelines of his or her own company. Here, this question could always be helpful: "How would the supervisor of the recipient or a competitor react if he/she/they gained knowledge of the payment?" Of course, promotional gifts of DS are not affected by this regulation.
• Entertainment of customers or suppliers is to take place in accordance with the usual business conventions and only if it is not in conflict with the regulations detailed here. The place, the type of entertainment and the amount spent must be reasonable and moderate and must be documented in accordance with the LEVACO specifications for expense accounts.

Employees may not request gifts, invitations or other personal advantages of any type from third parties who are currently or potentially associated with LEVACO Chemicals GmbH.

Gifts: Employees may accept gifts if they have not requested them and the following requirements are complied with:

• The unrequested gifts are granted within the framework of the usual rules of politeness and are part of the common business practices.
• The value of the gift raises no expectations with respect to any obligation on the recipient’s part.
• Entertainment: Employees may accept entertainment invitations under compliance with the following requirements:
• The entertainment invitations take place irregularly and within the framework of the usual business processes.
• The expenses are moderate in amount and the event takes place in an environment that is sensible and appropriate with a view to the LEVACO employees and the business cause.

Avoid situations that could lead to a conflict between your personal interests and the interests of LEVACO Chemicals GmbH!

A particular conflict of interest exists if a LEVACO employee takes advantage of his or her position to acquire a personal advantage or if the private interests of the employee contradict those of LEVACO Chemicals GmbH and lead to conflicts of loyalty.

If a conflict of interests should emerge between the private interests and the interests of LEVACO Chemicals GmbH, the employee concerned must inform his or her supervisor immediately so that a suitable solution can be found.

LEVACO Chemicals GmbH’s own as well as external company and business secrets (especially including recipes, formulas, etc., i.e. all circumstances that are not publicly accessible) may not be passed on to third parties or made public. Likewise, LEVACO’s own or external industrial property rights (especially including patents and trademarks) are to be respected.

For the topic of data protection, the corresponding LEVACO Chemicals GmbH guideline and the work contract agreements are referred to.

When advisers, consultants, experts or other persons offer their services to LEVACO Chemicals GmbH, the following principles are generally to be followed:

• Any agreement must be within the framework of the applicable laws.
• In all agreements, the corresponding roles and areas of responsibility and especially the fee basis must be clearly established.
• The amount of the fee must be in line with the usual fees for such activities.
• Payments to persons outside the company must take place in the country in which the agreed services are rendered unless this is not possible for important reasons.
• Agreements (orders, contracts, etc.) are to be signed by at least two persons with the right of representation for LEVACO Chemicals GmbH (4-eyes principle).
• All agreements must be reviewed at regular intervals to ensure that they are still up-to-date and appropriate for the activities.

LEVACO Chemicals GmbH is committed to fair competition; illegal deals and agreements of any type are not tolerated.

LEVACO Chemicals GmbH respects all national and international customs laws as well as foreign trade, anti-terror and embargo provisions.

LEVACO Chemicals GmbH is conscious of its responsibility to protect the environment as well as the health and safety of people and operates under these premises.

LEVACO is committed to the production of Halal products in writing. The necessary measures and requirements have been defined and HALAL CONTROL (as an external certification body) guarantees implementation and maintenance.

HAS requirements in the production process:

• The release process of new raw materials must ensure that all materials used in certified products have been tested and approved by HALAL CONTROL.
• Make sure that all materials mentioned in the product formulation/product formulation have been approved by HALAL CONTROL.
• The purchasing process must ensure that every purchased material used for certified products has been approved by HALAL CONTROL.
• Products contain finished products and intermediate.
• The name of the product must not be an allusion to an inappropriate Islamic practice or Haram product.
• The sensory profile of the flavor must not imitate any Haram material.
• Halal products must be labeled as such to distinguish them from non-Halal products.
• The company must have written procedures describing critical activities.

Products that do not meet HAS criteria should not be sold to customers/consumers who request Halal products. Products that do not meet the criteria and have already been sold must be recalled. Records must be created and maintained for the handling of non-Halal compliant products and productions. LEVACO has a written procedure to ensure the traceability of certified products.

As part of the internal audit, all aspects/criteria of the HAS and their implementation are audited. Appropriate corrective action must be corrected within a deadline. It also ensures that the appropriate root cause analysis is performed to prevent a recurrence. After conducting the internal audit, the audit report will be submitted to HALAL CONTROL.

The Jewish dietary laws (Kashrut) are traditional religious laws, the Halacha, for the preparation and enjoyment of food and drink; they are based on the food offerings of the Torah. Under these rules, foods are classified as those that are allowed for consumption ("kosher") and foods that are not permitted for consumption ("non-kosher" or "treife").

The following aspects are fundamental for the Kashrut:

• The distinction between allowed and not allowed animals.
• The ban on blood consumption.
• The division into "meaty", "milky" and "neutral" foods.
• Special rules for the manufacturing process

In the production process, all ingredients of the products are analyzed. If the products do not contain kosher ingredients, comparable alternatives are used. The next step to Kosher certification is to visit our Kosher controller. This examines the plant and the required equipment. If all steps in the production process comply with the kosher regulations, LEVACO receives a certificate. In case the required equipment was previously used with non-kosher products, the equipment must be kosher sterilized. To ensure a consistently good kosher quality of the products, the company will visit regularly.

The LEVACO staff are the foundation of the company’s success. Appreciation is expressed in fair, respectful and trusting dealings with each other. Discrimination or harassment is not tolerated.

LEVACO Chemicals GmbH documents all business processes adequately within the framework of an internal control system and ensures the complete and correct recording of accounting-related information using appropriate checks.

Should you be unsure whether your behavior corresponds to the corporate integrity of LEVACO Chemicals GmbH, the following questions may offer orientation:

• Can I tell my supervisor, my colleagues, my family or my friends about my actions with a good conscience?
• Would it be acceptable for LEVACO Chemicals GmbH or me if my decision is made public?
• Is my decision one that corresponds to LEVACO Chemicals GmbH?
• Is my decision morally and legally irreprehensible?

If these questions can be answered with a “Yes”, you are on the safe side! If you are unsure, speak to your supervisor.

LEVACO Chemicals GmbH offers its staff use of the necessary sources of information, as well as advice, to avoid legal and regulatory infringements.

Each supervisor must organize his or her area in such a way that compliance with the rules of this code of conduct, the company-internal rules as well as the legal provisions is ensured.

All employees are obligated to communicate violations of the code of conduct to their supervisor without delay.

These guidelines apply to all LEVACO Chemicals GmbH employees and enter into force with immediate effect.