Code of Conduct

1 Our values and goals

Portal Systems AG is a leading provider of software solutions for the digital transformation of companies. We are proud of our innovative strength, customer focus and quality. We are aware that our success is based on the trust of our customers, business partners, employees, shareholders, and the public. Our commitment to ethical, legal, and social standards is the foundation of this trust. This Code of Conduct formulates the fundamental values and principles that guide our actions and express our responsibility towards all stakeholders. It applies to all employees of Portal Systems AG and its subsidiaries.

2 Our rules of behaviour

We expect all employees to always behave lawfully, honestly, respectfully and with integrity. This means in particular:

2.1 We abide by the laws

We comply with all applicable laws, regulations, and guidelines in the countries in which we operate. We respect human rights and cultural diversity. Additionally, we reject all forms of corruption, bribery, money laundering, terrorist financing, radicalism, tax evasion and other illegal or unethical practices. And we co-operate with the relevant authorities and provide all necessary information truthfully and completely.

2.2 We protect our reputation

We are aware that our behaviour affects the reputation of Portal Systems AG. Our behaviour is professional, competent, and trustworthy. We communicate openly, transparently, and consistently with our stakeholders. We protect the intellectual property, brand image and reputation of Portal Systems AG. This means that we avoid any action or statement that could damage the reputation of Portal Systems AG.

2.3 We respect each other, are honest and have integrity

Our colleagues, customers, business partners and all other people with whom we are in contact are treated with respect, courtesy, and fairness. We maintain an open, constructive, and trusting working relationship. When dealing with our stakeholders, we act honestly and with integrity. We honour our commitments and obligations. We avoid conflicts of interest and inform our superiors immediately if such conflicts arise. Any information entrusted to us will be treated confidentially and used only for the intended purpose.

2.4 We provide management, accountability and oversight

We take responsibility for our tasks, decisions, and actions. Furthermore, we commit ourselves to continuous improvement and personal advancement. This includes supporting our employees in their professional and personal development. We recognise good performance and give constructive feedback. As managers, we serve as role models for our employees. We communicate the values and principles of our corporate mission statement and ensure compliance with them. Our aim is to create a positive, motivating and performance-enhancing working environment. This means that we also pay close attention to the health, safety and work-life balance of our employees.

3 Responsible business practices

Portal Systems AG attaches great importance to fair, transparent, and sustainable business relationships with its customers, suppliers, service providers and other business partners.

It complies with the applicable laws and regulations of the countries in which it operates and expects the same from its business partners.

Portal Systems AG undertakes to observe and promote competition and antitrust law. It rejects any agreements or behaviour that hinder or distort free and fair competition. It rejects any agreements or behaviour that hinder or distort free and fair competition.

Portal Systems AG prohibits any form of corruption, bribery, or undue influence on business partners or third parties. It offers no inappropriate advantages, grants no inappropriate advantages, demands no inappropriate advantages, and accepts no inappropriate advantages.

Portal Systems AG ensures that the awarding of contracts to business partners is based on objective and comprehensible criteria. It avoids conflicts of interest or the appearance of conflicts of interest.

Portal Systems AG supports charitable or social causes through donations or sponsorship, provided these are in line with its values and objectives. It ensures that these donations or sponsorships are transparent, appropriate, and legally permissible.

4 Independence and loyalty

Portal Systems AG expects its employees to fulfil their professional duties and make decisions independently of personal interests or relationships. It avoids situations in which a conflict of interest could arise or be suspected.

Portal Systems AG prohibits its employees from entering into or being in competition with business partners or competitors. It requires its employees not to take advantage of any business opportunities arising from their work for Portal Systems AG.

Portal Systems AG authorises its employees to hold secondary employment or political offices, provided that these are compatible with their professional duties and the reputation of Portal Systems AG. It requires its employees to report any such outside employment or political office and to obtain prior written approval.

5 Dealing with equipment and information

Portal Systems AG provides its employees with various equipment such as computers, telephones, vehicles, tools, machines, office supplies, etc. This equipment is used exclusively for the fulfilment of official duties and may not be misused for private purposes. Employees must use and maintain equipment carefully and responsibly to avoid damage, waste and pollution.

Portal Systems AG is committed to the correctness, completeness and transparency of its records and reports, both internal and external. To ensure compliance with legal and internal regulations, employees are required to record and document all relevant data and facts in a truthful and understandable manner. False, misleading, or incomplete information and manipulation must be avoided.

Portal Systems AG protects the confidentiality of all information that it receives or generates in the course of its business activities and only passes this on to authorised persons or bodies. Employees must not disclose any confidential information to which they become privy during the course of their work, and must not use such information for their own benefit or for the benefit of any third party. This includes, for example, business secrets, company and business data, customer and supplier data, employee data, contracts, strategies, plans, etc. Employees must take all reasonable measures to prevent unauthorised access, disclosure, copying or destruction of confidential information.

6 Data protection, data security and IT security

6.1 Protection of privacy and personal data

Portal Systems AG is committed to protecting and respecting the personal data of its employees, customers, suppliers, and other business partners. It complies with applicable data protection laws and regulations and ensures that data is collected, processed and used only for necessary and legitimate purposes. Additionally, it ensures that the data is only accessible to those persons who need it to fulfil their tasks and that it is adequately secured.

6.2 Data minimisation and data quality

Portal Systems AG only collects, processes, and uses the personal data required to fulfil its business purposes. It avoids the collection and storage of superfluous or irrelevant data. Portal Systems AG deletes or anonymises the data as soon as it is no longer required.

6.3 Transparency and rights of data subjects

Portal Systems AG informs the data subjects about the purpose, type, and scope of data processing as well as their rights to information, correction, deletion, restriction, objection, and data portability. It ensures that the data subjects can exercise their rights at any time and that their concerns are dealt with quickly and appropriately.

6.4 IT security and risk management

Portal Systems AG attaches great importance to the security of its information technology systems and networks. It takes appropriate technical and organisational measures to protect data from unauthorised access, loss, manipulation, theft, destruction, or other threats. In addition, Portal Systems AG adheres to internal guidelines and standards for IT security, updating them on a regular basis. Portal Systems AG sensitises and trains its employees in IT security issues and expects them to comply with the security regulations.

6.5 Reporting and rectification of data breaches

Portal Systems AG takes data protection violations very seriously and investigates them. It immediately reports data breaches that may result in a risk to the rights and freedoms of data subjects to the competent data protection authority and informs the data subjects to the extent required by law or required. Furthermore, it takes appropriate measures to minimise the effects of data protection violations and to avoid their repetition.

7 Responsibility for the environment

Portal Systems AG is aware of its responsibility towards the environment and is committed to minimising the impact of its business activities on natural resources and the climate. We endeavour to comply with or exceed the environmental standards set by applicable laws, regulations, and industry guidelines. To achieve this, we promote a culture of environmental awareness and continuous improvement among our employees, business partners and customers.

We avoid or reduce the consumption of energy, water, and other resources by using efficient and sustainable technologies and processes.

Moreover, we avoid or reduce the emission of greenhouse gases, air pollutants and noise by regularly maintaining and optimising our vehicles and IT systems.

We take environmental aspects into account in the planning, development and procurement of products, services and projects and strive to improve the environmental performance of our supply chain.

We fulfil the requirements of our customers and stakeholders for environmental information and reporting and communicate transparently about our environmental goals, measures, and results.

Our employees are trained and motivated to be environmentally aware and to participate in the environmental initiatives of Portal Systems AG.

In addition, we regularly monitor and evaluate our environmental performance and take corrective and preventive action in the event of deviations or risks.

We expect all employees to adhere to these corporate guidelines and to fulfil their responsibility for the environment. At the same time, we expect our business partners to respect and support our environmental standards. And we expect our customers to recognise and value our environmental performance.

8 How we treat our employees

8.1 Appreciation and promotion

Portal Systems AG is well aware of the fact that its employees are the most important asset of the company. It promotes a culture of appreciation, trust, diversity, equal opportunity, and development. It respects the human rights and dignity of all employees and expects them to behave accordingly.

Portal Systems AG complies with applicable laws, continuously improves working conditions and protects the health and well-being of its employees. It supports freedom of association and the right to collective bargaining.

Portal Systems AG attaches great importance to open and honest communication with its employees and promotes dialogue at all levels. It regularly informs employees about the company’s goals, strategy, results, and challenges. It encourages employees to express their opinions, suggestions and concerns and takes them seriously.

8.2 Health and safety

Portal Systems AG has set itself the goal of creating a safe and healthy working environment for all employees. It complies with legal regulations and internal guidelines on occupational health and safety. In addition, it identifies and minimises risks to the health and safety of employees and takes appropriate preventive measures. And it provides the necessary resources, training, and facilities to ensure occupational safety.

Portal Systems AG expects its employees to comply with the rules of occupational safety and accident prevention regulations and to report unsafe situations or accidents. It promotes awareness and responsibility for occupational safety and health protection among all employees. And it supports employees in restoring their ability to work after an accident at work or occupational illness.

8.3 Complaints and reports

Portal Systems AG attaches great importance to the fair and transparent handling of complaints and information that employees may have in connection with their work or the company’s mission statement. It provides suitable channels and procedures for receiving, reviewing, and processing complaints and reports. And it protects the identity and rights of complainants and whistleblowers and avoids any form of retaliation or discrimination.

Portal Systems AG encourages employees to first discuss their complaints and reports with their superiors or the relevant departments. If this is not possible or not appropriate, employees can contact the Compliance Officers. Portal Systems AG guarantees that every complaint and every report will be treated confidentially, independently, and promptly.

9 Implementation and control

Portal Systems AG is committed to the enforcement and monitoring of compliance with this policy.

The following measures are taken for this purpose:

The Board of Directors and managers are responsible for communicating and implementing the principles and behavioural requirements in their areas of responsibility. They act as role models for employees and are available to answer their questions and concerns.

Employees are obliged to familiarise themselves with the corporate mission statement and to observe it in their daily actions. They are required to seek advice from their line manager, the HR department, or the Compliance Officer if they have any uncertainties or doubts.

Portal Systems AG is convinced that compliance with these corporate principles is not only a legal and ethical obligation, but also an essential factor for the long-term success and reputation of the company.

We expect all employees to be aware of this responsibility and to actively fulfil it.

The Board of Directors of Portal Systems AG