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These guiding principles form the basis for the corporate culture of the HÖRMANN Group. Adherence to these principles is vital to the company’s success. They are based primarily on the following fundamental values:

• ENTREPRENEURSHIP in the sense of an active responsibility and when taking business opportunities
• CREATIVITY and using a high degree of knowledge, skills and competencies for the benefit of the Hörmann Group’s customers
• INTEGRITY in the sense of the compliance of the Hörmann Group’s employees with these guiding principles

The Hörmann Group’s employees actively apply these values in their day-to-day dealings with each other and in their interactions with business partners and third parties.

I. Scope

These “Guiding Principles of the Hörmann Group” set out the common framework for HÖRMANN Holding GmbH & Co. and its subsidiaries and equity investments (hereinafter also referred to collectively as the “HÖRMANN Group”). The management boards and managing directors of the subsidiaries and equity investments are obliged to ensure that these Guiding Principles are applied as binding within their respective companies. Employees who conduct themselves with personal integrity are essential to the credibility and strong public image of the HÖRMANN Group.

Every employee is obliged to know and comply with the relevant laws and provisions, including these “Guiding Principles”. Any breach may have disciplinary consequences up to and including the termination of the employment relationship.

II. Organisation, management, supervision

The high degree of independence and responsibility enjoyed by the managing directors of the individual Group companies ensure that they are extremely motivated to respond quickly, expertly and successfully to the requirements of the market and customers. The management structure selected to achieve this – comprising responsible managing boards and managing directors monitored by supervisory boards and advisory boards – serves to protect the legitimate interests of the company and its owners while also providing the best possible support for operating business.

III. Integrity: Compliance with laws and internal regulations

Strict compliance with the law and the regulations prescribed by the Hörmann Group for its employees forms the basis for the actions of the HÖRMANN Group’s employees. Fair, correct and legally sound business dealings with customers, suppliers and other parties create the foundations for cooperation in a spirit of mutual trust. More detailed provisions may be set out in additional binding regulations of the HÖRMANN Group.

1. Good business relationships instead of corruption

Good business relationships with customers, suppliers and competitors are a prerequisite for business success. Managing these business relationships must never cross the line of undue influence. The use of corruption in any form to achieve business purposes is prohibited. Corruption primarily takes the form of the bribery or venality of public officials, e.g. civil servants, and the acceptance or granting of advantages in respect of non-public officials. Corruption in its various forms is punishable by law in Germany and almost every country of the world.

Accordingly, no employee of the HÖRMANN Group may offer or provide business partners, their employees or third parties with illegal advantages. No employee of the Hörmann Group may demand or accept illegal advantages. Benefits in the form of gifts, invitations to business hospitality, events, donations and sponsorship that may be suitable to influence the business decisions of partners can already be interpreted as corruption. Even giving the impression of potential influence must be avoided.

2. Cooperation with business partners

With regard to cooperation with certain business partners and the associated risks, the HÖRMANN Group has adopted a standard process for the examination, approval and documentation of these third parties that is tailored to the respective company and that is required to be applied by all HÖRMANN Group companies. HÖRMANN Group companies are obliged to establish corresponding processes that meet these standards. All employees of the Hörmann Group are obliged to conduct this business partner compliance check before commissioning or entering into a contractual relationship with such third parties. The separate “Business Partner Integrity Check” guideline applies.

3. Integrity in competition

In Germany and most countries of the world, freedom of competition is protected by strict competition and anti-trust laws. In particular, agreements and concerted practices between competitors with the aim of preventing or restricting competition are prohibited.

Anti-competitive arrangements in tender processes may be punishable by strict custodial sentences. Furthermore, it is not permitted to abuse a dominant position in the market. Any form of coordination with competitors of the HÖRMANN Group that could be relevant to competition between the HÖRMANN Group and the respective company is prohibited. The protection of competition is monitored by the anti-trust authorities – in Germany, the Federal Cartel Office. This protection is a key regulatory task in any economic system based around a market economy. A supplier or service provider may not be preferred without objective and verifiable justification for doing so. Contracts are awarded on the basis of the business model of the respective HÖRMANN Group company, which sets clear rules within the framework of the applicable legislation.

4. Integrity in foreign trade

The HÖRMANN Group ensures compliance with all provisions concerning the export of goods, services and information in accordance with the applicable statutory export control regulations. The HÖRMANN Group ensures compliance with the statutory prohibition on money laundering that applies in most countries.

5. Prevention of conflicts of interest

In working for the HÖRMANN Group, employees are obliged to safeguard the interests of the HÖRMANN Group, maintain confidentiality with regard to company matters and not enter into competition with HÖRMANN Group companies. In performing their work, employees must not enter into any conflict between the interests of the HÖRMANN Group and their own interests. If the possibility of such a conflict exists, employees are obliged to inform their superior.

6. Protection of business assets and certain information

Employees of the HÖRMANN Group are entrusted with business assets in the course of their work. All employees are responsible for the careful handling and protection of business assets. Confidential company information must be protected as required by law and taking into account statutory or regulatory disclosure obligations. The applicable statutory and company rules on the protection of personal data and on data and information security must be observed.

IV. Corporate responsibility

The HÖRMANN Group is aware of its corporate responsibility to its employees, customers and business partners. This includes a responsibility to society and its underlying principles. The Hörmann Group and its employees respect the personal dignity of every individual and tolerate no discrimination in the company’s activities around the world.

Prejudice on account of ethnic origin, gender or sexual orientation, religion or belief, disability or age is not tolerated by the HÖRMANN Group. Accordingly, we undertake to uphold human rights and international standards on employee protection.

The HÖRMANN Group is aware of the scarcity of resources and acts in line with the principles of sustainability. This includes environmental responsibility and occupational safety and protection measures that ensure employees’ physical and mental well-being.

V. What to do in cases of doubt?

If employees are in doubt as to whether a certain behaviour is consistent with these Guiding Principles or suspect that an irregularity may have occurred, they are requested to report this. They can do this internally by informing their supervisor or the responsible compliance officer. Details of the employees responsible for compliance at the individual HÖRMANN Group companies are displayed on noticeboards and made available by e-mail on the Internet and can also be requested from the management of the respective company.

All employees are expressly requested to make use of one of these channels for reporting irregularities. No employee who submits a notification should fear being placed at an unfair disadvantage as a result, even if the notification ultimately proves to be unjustified.