Preamble
Our conduct towards our employees, customers, suppliers, shareholders, and the public is guided by high ethical and legal principles.
Every single employee of Dusar Frigo GmbH contributes to the company's reputation with internal and external business partners through their actions, personal conduct, and behavior.
Reliability, honesty, and fairness in daily operations and in the company's strategic direction are fundamental prerequisites for our interactions with one another, with our business partners, and with the public.
Sustainable growth and success are only possible through fair dealings with all our business partners and with each other. For this reason, we do not tolerate any unfair or illegal means of achieving our goals.
The following compliance policy therefore contains binding rules for every employee of Dusar Frigo GmbH.
We are obligated to act in accordance with this policy.
Dusar Frigo GmbH
Christoph Gritzner
This document was created electronically and does not require a signature.

Fundamental Code of Conduct
Lawful Conduct
We act in accordance with the laws and regulations of the respective business environment in which we operate. For the employees of Dusar Frigo GmbH, compliance with law is of paramount importance.
Violations of the law must be avoided under all circumstances.
In addition to the law, every employee must also comply with all applicable internal regulations of Dusar Frigo GmbH. In the event of a breach of their employment obligations, every employee must expect disciplinary action from Dusar Frigo GmbH, in addition to any potential criminal sanctions.
Respect, Honesty, and Integrity
We are reliable partners both internally and with external business partners and individuals.
We honor our commitments and only make promises we can keep. We act honestly, are transparent, and stand by our responsibilities.
We respect the privacy, personal rights, and dignity of every individual. We value collaboration with women, men, and people of diverse backgrounds, nationalities, cultures, religions, and skin colors. We do not tolerate exclusion or discrimination based on sexual orientation or any other reason. We do not tolerate sexual or other personal insults or harassment.

Basic Principles of Cooperation at Dusar Frigo GmbH
Leadership, Responsibility, and Supervision
Supervisors must earn the recognition of their employees through exemplary personal conduct and performance. They must act openly and honestly and demonstrate social competence. In their dealings with employees, they set achievable goals, demonstrate trust, and prioritize as much autonomy and personal responsibility as possible.
The leadership principles issued by Dusar Frigo GmbH must be observed by every employee in a leadership position. Supervisors fulfill their supervisory duties and organize work in such a way that all requirements can be met. They ensure that compliance guidelines are followed in their respective areas and that legal requirements and regulations are strictly observed.
Financial Responsibility
Proper accounting and financial reporting are standard practice in all companies within the Dusar Frigo GmbH group.
Only through the timely recording of all business transactions, in compliance with tax and commercial law regulations, can it be ensured that the company's financial position is accurately represented at all times and that all obligations can be met.
All processes are organized to ensure that all entries are recorded correctly and on time.
Employment Contract
Remuneration and Working Hours
All work performed at Dusar Frigo GmbH is governed by an employment contract and is, of course, voluntary. Every employee may leave Dusar Frigo GmbH at any time, provided the statutory and/or contractually agreed notice period is observed. The minimum wage and its regulations apply. Remuneration is paid monthly.
Before commencing employment, every employee receives comprehensive and easily understandable information about the contents of the employment contract and the composition of their remuneration. Each employee receives a detailed monthly payslip.
Overtime is worked, accrued, or compensated based on applicable legal regulations. Working hours comply with legal regulations and are described in the employment contract.
Occupational Safety
Due to our responsibility to our employees, colleagues, and external partners, we ensure the highest possible level of occupational safety and ergonomics in our workplaces. These principles are observed in the technical planning of workplaces and facilities, as well as in processes and personal conduct in daily work.
The work environment and workplaces must meet the requirements of health-oriented design and the necessary safety regulations.
However, every employee is also jointly responsible for occupational safety in their area. All regulations concerning occupational safety must be strictly applied and adhered to.
Child Labor and Youth Protection
Dusar Frigo GmbH categorically rejects child labor and any exploitation of children and young people.
All regulations for the protection of young employees are observed. Young people under the age of 18 are not employed at night or under hazardous conditions. The deployment of young employees is only possible within the framework of legal regulations and must be planned with particular care.
Human Rights, Working Conditions, and Modern Slavery
Respect for and protection of the personal rights and dignity of every individual are fundamental values ​​guiding our actions. It is a matter of course for us to comply with the rules and laws that uphold human dignity. We support the observance of internationally recognized human rights.
We comply with laws and create fair and humane working conditions. We reject modern-day slavery.
We expect our business partners to think and act in the same way.
Ethical Recruiting
Equal treatment, respect, and protection in the recruiting process are core values ​​of Dusar Frigo GmbH. Therefore, it goes without saying that there is no unequal treatment of applicants. Job descriptions contain no missing or false information, and we do not use social media to collect private information. Furthermore, we refrain from requesting irrelevant information.
Rights of Minorities and Indigenous Peoples
The rights of minorities and indigenous peoples are protected and respected at all times. Should these rights be affected by our business activities, we align our actions with internationally valid principles. Respect for these rights is always beyond question and must be consistently upheld..
Women's Rights
Dusar Frigo GmbH promotes equal opportunities and does not tolerate discrimination. All people are treated equally, regardless of gender. There is no preferential treatment in filling new positions, and no quotas are met. Remuneration is based solely on the duties performed and not on gender. Positions are filled solely based on professional qualifications.
Handling Company Property
All employees of Dusar Frigo GmbH treat the facilities and equipment entrusted to them with care and respect. Unless otherwise stipulated by company policy or individual contract, the equipment and facilities in offices and workshops (e.g., telephones, copiers, computers including software, machines, tools) may only be used for business purposes. Viewing, downloading, or distributing information that glorifies violence, racial hatred, or other criminal offenses is prohibited. The same applies, of course, to sexually explicit content.
Unless otherwise specified, the use of private equipment for business purposes is generally not permitted (e.g., recording with a mobile phone or private camera/video equipment, use of a private laptop).
Exceptions to this must be specifically regulated.

Dealing with Business Partners and Third Parties
Combating Corruption
a) General
We do not tolerate corruption.
Corruption undermines public trust in the integrity and functioning of the economy and individual companies, and also causes significant economic and business damage.
We define corruption as any abuse of an official position or personal power to obtain an advantage for oneself or a third party.
c) Offering and Granting Advantages
We do not tolerate the granting of advantages. Therefore, no employee may offer or grant unauthorized advantages to business partners in connection with business activities, whether in the form of monetary payments or other benefits. Indirect benefits are also prohibited.
Employees who conclude contracts with consultants, intermediaries, agents, or similar third parties must ensure that these parties also do not offer or grant unauthorized advantages. Benefits to business partners or their employees may be granted at a customer event, to the extent agreed upon at that time. Outside of the measures described therein, such benefits are strictly prohibited. Giveaways can be distributed to customers, business partners, and guests as small tokens of appreciation or product samples on special occasions. It is important to ensure that the positive company image remains the primary focus. Invitations to business meals may be extended within the usual business context.
Free Competition
Dusar Frigo GmbH is fully committed to fair competition. Antitrust law is strictly observed. Even the mere appearance of anti-competitive behavior must be avoided. Every employee is obligated to adhere to the rules of fair competition. Any misconduct by others must be reported to management. All agreements between companies that restrict competition are prohibited. Even the mere exchange of information between companies may be prohibited.
Avoiding Conflicts of Interest:
We make business decisions freely and independently and avoid conflicts of interest as follows:
• Should a personal or family interest exist in connection with official duties, this must be reported to the supervisor immediately.
• Suppliers or service providers must not be favored or disadvantaged in the competition for contracts for personal or other extraneous reasons.
• If suppliers or service providers also work within the personal network of the employee making the decision, the decision in favor of that supplier or service provider must be approved by the employee's supervisor. Conflicts of interest should be avoided in principle, or even better, eliminated entirely.
• If there is a foreseeable risk of a conflict of interest in a decision, the employee in question must inform their supervisor without being asked.
Export Controls and Economic Sanctions
We, as Dusar Frigo GmbH, comply with regulations for the import and export of goods and services.
We are aware that customs and other regulations must be observed in cross-border trade. Cross-border trade also includes taking goods on business trips or the temporary transfer of goods abroad.
Business dealings with companies or individuals on sanctions lists are strictly prohibited.
Sustainability in all actions
Environmental protection and resource conservation
We treat topics such as environmental protection and resource conservation with high priority. These topics are high-priority corporate goals. The exemplary behavior and performance of each individual employee are crucial. Everyone contributes to these issues in their respective role.

Corporate Social Responsibility
We see ourselves as a responsible and important employer in our companies and at our locations, and we embrace the associated social and regional responsibility. This is achieved through open communication with the public and active engagement in the respective region. We are an integral part of public life in our regions and a constructive partner for society and its people. We expect our customers, suppliers, and employees to act sustainably and treat people, animals, and the environment with respect.
Quality Management / Integrated Management Systems
Dusar Frigo GmbH places great importance on its quality management system and the quality of its products and services. These obligations are laid down in our documented information and are binding for all our employees.
Data Protection and Intellectual Property Protection
Trade Secrets / Information Security
We handle the data and information entrusted to us with care and confidentiality. We know that the know-how and trade secrets of Dusar Frigo GmbH, as well as those of the companies that cooperate with Dusar Frigo GmbH, are valuable and must be protected. We therefore adhere to our internal regulations for the protection of confidential information and trade secrets and disclose internal information to third parties only to the necessary and permissible extent.
We maintain strict confidentiality regarding internal matters of our company and our partners that have not been publicly disclosed.
We do not disclose information such as details of the company's organization, business, manufacturing, research, and development processes, or figures from internal reporting that we have learned in cooperation with customers, suppliers, service providers, or other business partners, but which are not essential for the specific task at hand.
The obligation to maintain confidentiality continues even after the termination of the employment relationship. Trust is the foundation of any trusting and effective collaboration. This applies equally to relationships with shareholders, employees, customers, business partners, as well as with the public and all government agencies. Therefore, all records and reports, whether prepared internally or disclosed externally, must be accurate and truthful. According to the principles of proper accounting, data collection and other records must always be complete, accurate, timely, and systematically correct.
Intellectual Property
To foster innovation, it is particularly important to protect intellectual property. Entrepreneurs and individuals would not dedicate themselves to research and development if they could not fully benefit from their inventions. Dusar Frigo GmbH respects its own intellectual property and that of others. The intellectual property of Dusar Frigo GmbH and its business partners is a valuable asset that must be protected. Anyone who misuses it for their own benefit must expect the appropriate consequences.
Data Protection and Data Security
We comply with the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG) and ensure that the applicable principles for processing personal data are adhered to at all times.
The protection of personal data and compliance with the data protection regulations applicable to Dusar Frigo GmbH are essential for us. We take all necessary measures to protect the personal data we collect or process. Personal data may only be collected, processed, or used to the extent necessary for specified, explicit, and legitimate purposes.
Reporting of Violations and Protection of Whistleblowers
Contact Person for Violations
Every employee of Dusar Frigo GmbH can report circumstances that suggest a violation of the compliance policy or indicate violations regarding quality management to their disciplinary supervisor, the Head of Human Resources. Concerns or complaints regarding discriminatory behavior can be addressed directly to the Human Resources department by any employee. Every incident will be thoroughly investigated. Appropriate measures will be taken where appropriate. All reports and documents will be treated confidentially.
Protection of Whistleblowers
Misconduct by individual employees must be identified and reported quickly. To this end, it is essential that the whistleblower is protected.