Code of conduct

1. Introduction and basic principles
The following Code of Conduct is a symbol of the business culture at Friedrich W. Bloch GmbH, and it also encapsulates our perspective on sustainability. In order to reflect these values, we focus our daily business activities on the following principles:

• Trust and responsibility
• Appreciation and reliability
• Initiative and commitment
• Fairness and loyalty
• Integrity

As part of its business activities, Friedrich W. Bloch GmbH seeks to be an honest, reliable, and transparent partner for its employees, customers and suppliers, and for the entire environment. To this end, the following Code of Conduct has been prepared, which addresses all employees of Friedrich W. Bloch GmbH and helps us to conduct our business responsibly. Thus, we expect each and every one of our employees to seek out assistance and advice from their superiors if they have doubts regarding either what their own behavior should be or if they suspect legally dubious processes in their work environment. After all, trust is the most effective means of averting damage due to misconduct at Friedrich W. Bloch GmbH and its business partners or to limit such damage as far as possible.

2. Antitrust and competition laws
As the foundation of efficiency, innovation and economic development, antitrust law seeks to ensure a free and fair competitive environment. For example, antitrust violations are often punishable by high fines and sometimes even imprisonment. Friedrich W. Bloch GmbH has undertaken without any restriction to comply with all competition and antitrust laws in the countries in which we operate. Informal conversations or concerted behavior that can lead to a restriction of competition are prohibited. The conclusion of a prohibited  antitrust or competition law agreement must also be avoided. In discussions with competitors, our employees are not allowed to pass on confidential information about, for example, prices and upcoming price changes or even customer and supplier relationships. They are also not allowed to accept such information from competitors. Our employees are not allowed to participate in conversations with competitors

• in which attempts are made to conclude agreements concerning or to stabilize, fix or control prices, credit terms, discounts, and rebates;
• to share proprietary confidential business information;
• to divide up customers or divisions among competitors;
• to exert pressure on certain customers or suppliers and to boycott them, for example, or
• to restrict or expand the production and sales figures of a product or the quantity or scope of a certain service in consultation with other competitors.

All employees of Friedrich W. Bloch GmbH are obliged to ensure that under no circumstances will they use business strategies that abuse a dominant market position or that generally violate antitrust and competition law regulations.

3. Safety
Our employees are our most valuable assets. Their skills, competences, and dedication have enabled our company to grow and prosper. Understandably, it is of paramount importance for Friedrich W. Bloch GmbH that its employees work in a positive working environment, in which each employee can develop according to his or her own abilities and dedication. Safety has the highest priority at our company, so we take measures to ensure a safe and healthy working environment for our employees and try to minimize any risks as far as possible. However, it is imperative that our employees comply with all safety regulations, regardless of whether they are prescribed by law, promulgated by the authorities, or are company-internal rules of conduct. Following routine procedure must never lead to lower levels of care and caution. It is not only in the interest of all employees to strictly
follow all safety regulations at all times, but it also advances the welfare of colleagues and that of the company as a whole. In order to achieve the highest possible level of
safety for our employees as well as for our business partners, Friedrich W. Bloch GmbH expects its employees to actively participate in the process and raise their awareness of dangers.

4. Environment
Friedrich W. Bloch GmbH is aware of its great responsibility with regard to the protection of the environment, and it does not wish to do anything to evade this commitment. So we meticulously comply with all applicable environmental laws and regulations. Our aim is to protect the environment, to use energy and natural resources sparingly and to avoid polluting the environment. We strive to minimize the impact of our business activities on the environment as much as possible, so we use natural resources very carefully and sparingly in all our business segments. In addition, we want to reduce our raw material, equipment and energy consumption in order to produce as little waste and emissions as possible.  Environmental awareness is not simply a burdensome business obligation that we grudgingly comply with, but a much more important requirement that is essential to
maintaining our profitability and competitiveness.

5. Corruption
Friedrich W. Bloch GmbH complies with all anti-corruption laws and guidelines. It is absolutely forbidden for our employees to directly and indirectly offer, pay for, demand or accept bribes in whatever form. The same applies, of course, to any activity that might even give the appearance of corruption, money laundering or the financing of criminal organizations. Our employees may not make or promise to make payments to organizations or individuals with the expectation of any business gain. All payments that could be unambiguously interpreted as bribery are prohibited. The daily conduct of our employees must be honest and ethical. Likewise, our employees may not demand or accept personal benefits, such as
payments, from suppliers or other third parties in connection with the awarding or processing of an order. In particular, special restraint must be exercised when dealing with public officials. Although it is customary in most countries to occasionally give gifts or invite customers or business partners to events, this should be done with moderation and for an
appropriate purpose so that such behavior cannot be construed as bribery. Any grant and acceptance of benefits and gifts must comply with all legal requirements.

6.  Insider trading laws
The employees of Friedrich W. Bloch GmbH are forbidden to participate in anticompetitive behavior. They may not disclose any detailed information that is not otherwise public information or that relates directly or indirectly to one or more issuers of financial instruments, or that could materially affect the prices of those financial instruments in the event of disclosure. Employees of Friedrich W. Bloch GmbH who have inside information concerning Friedrich W. Bloch GmbH itself or other companies may not acquire any shares or
financial instruments of these companies and may not pass on the inside information to third parties. This requirement will apply until any possible insider information no
longer fulfills the criteria for constituting insider information and is thus no longer relevant or has already been made public.

7. Discrimination and human rights
Every member of the staff at Friedrich W. Bloch GmbH must be treated with courtesy, fairness and respect by all supervisors, employees, and colleagues. No one may be harassed or discriminated against on the basis of race, ethnicity, skin color, nationality, descent, gender, religious belief or worldview, political affiliation, age, physical condition, appearance or sexual orientation. The employees of Friedrich W. Bloch GmbH must respect the personal space of other employees and business partners. Sexual harassment and use of force in any form are prohibited and will entail corresponding workplace penalties and possible criminal prosecution. It goes without saying that Friedrich W. Bloch GmbH does not use, allow or tolerate the use of any child or forced labor. Any form of child or forced labor must be strictly rejected. This requirement applies both to our own employees as well as to all of our
business partners. Working conditions that violate the ILO Convention, the United Nations Convention and national law will not be tolerated. Any form of exploitation of children is condemned by Friedrich W. Bloch GmbH and will not be tolerated.

8. Conflicts of interest
Our employees must not let their business decisions be influenced by private interests or relationships. They must avoid any situations where there might be a conflict between business and professional responsibilities and their private interests. Such conflicts of interest may include relationships with customers, suppliers, other employees, and competitors. Our employees are obliged to act in the best interests of Friedrich W. Bloch GmbH and its business partners and beyond in accordance with this Code of Conduct, and they cannot let their conduct to be influenced by personal interests and private relationships. If there are private interests or relationships that could influence the employee's objective judgment in the course of doing business, they must be disclosed and reported to the employee's superior.

9. Protection of the company’s assets
All of the resources and assets of Friedrich W. Bloch GmbH must be used properly and solely for their intended purpose. Assets include, for example, financial resources, equipment, real property and locations, as well as trade secrets, patents, trademarks, and designs. Our employees are committed to protecting corporate assets from loss, damage, misuse and theft to the best of their knowledge and conscience.

10. Protection of personal data and confidential information
In the course of their employment at Friedrich W. Bloch GmbH, employees may become aware of confidential information related to the business of the company. Our employees may not divulge such information either inside or outside Friedrich W. Bloch GmbH if the counterpart is not explicitly entitled to receive this information. It is in the interests of Friedrich W. Bloch GmbH and each of our employees to protect the data of employees, suppliers, and customers as well as company-specific knowledge. As a result, our employees are obliged to take the utmost care to carry out the task that is entrusted to them to protect personal data.

11. Reporting wrongdoing
All employees of Friedrich W. Bloch GmbH are obliged to ensure that their personal conduct always complies with the present Code of Conduct. Friedrich W. Bloch GmbH will not tolerate any violations of the law or violations of this Code of Conduct by its employees or managers. Such violations usually also constitute a violation of labor law and employment contract obligations, if not also criminal law, and Friedrich W. Bloch GmbH will take all necessary steps to prevent such behavior. If employees violate the provisions of the present Code of Conduct and the law, then they will be subjected to warnings and terminations of their employment contract, and they may also face claims for damages. Friedrich W. Bloch GmbH reserves the right to submit a complaint to the competent investigative authorities if it discovers that its employees have committed any crimes. Behavior contrary to an employee's duties shall not and cannot be justified by reasons of gaining a short-term economic advantage for the company. The foundation of the success of Friedrich W. Bloch GmbH is compliance with all relevant laws, regulations, and company guidelines as well as ethical conduct in all business areas.

Vienna, September 2019