Compliance.

Act with integrity. Operate responsibly-minded.

We move fairly in competition and attach a great deal of importance to integrity and responsible corporate leadership that conforms with the rules and laws at all times. We expect all employees to satisfy the legal requirements at all times. Our manages have a role model function. They are responsible for ensuring compliance with our own values and rules and for action that is consistent with the legal provisions.

Our compliance system is aimed at establishing transparency in our actions, at integrating compliance in our business processes and serves to ensure strict compliance with all legal standards, guidelines, directives and regulations. It is continuously developed further by us. In our SPITZKE code of conduct we have obligated us all to common guiding principles. In this way, each individual employee makes their own contribution to a collective corporate culture and a common appreciation of values.

Organisation

The development of the compliance policy, dealing with compliance cases, clarification and disciplinary action in case of breaches is the responsibility of the central compliance team at the Group’s head office. The compliance organisation is headed by the Chief Compliance Officer (CCO)  Waldemar Münich, who at the same time is the CEO/​CFO of SPITZKE SE.

Ombudsmann

An external, independent lawyer is available as a contact for reporting suspected cases of non-compliance and is subject to statutory duty to maintain confidentiality. He accepts information, advises the informant and anonymously forwards the information concerning the suspicious facts – if the informant consents – to the responsible bodies within the company.

Contact:
Klaus-Hinrik Woddow
Rechtsanwalt und Notar
Kanzlei Heers & Woddow
Kurfürstendamm 220
10719 Berlin
Phone.: +49 30 8892000
Fax: +49 30 8816882
E-Mail: info@heers-woddow.de
www.heers-woddow.de

Note

Anyone who would like to report suspected misconduct within the SPITZKE Group can turn with confidence – anonymously if they wish – to compliance@spitzke.com

It is also possible to contact the ombudsman directly. The lawyer is subject to a duty to maintain confidentiality.

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