SKE Engineering GmbH – Code of Conduct

Code of Conduct

Preface

Dear Sir or Madam,
esteemed business partners and
valued employees!

SKE operates in a dynamic, Europe-wide market and is constantly growing. As a future-oriented enterprise, we take responsibility for our business activities. We therefore base our actions on the principles of sustainability, integrity, and compliance, and take care to maintain our impeccable reputation. This makes us even more committed to continuous advancement.

This Code of Conduct is the guideline for our corporate governance. It is intended to serve as a guide for all SKE stakeholders to comply with legal, ethical, and moral obligations in a complex working environment.

Together, we will continue to flourish as a reliable business partner and fair competitor. You, our employees, as well as our management and we as the Executive Board, make an important contribution to this every day through prudent, law-abiding conduct.

Your Stefan Eder
CEO

Scope of Application

This Code of Conduct applies to all employees of SKE Holding GmbH and all its subsidiaries (hereinafter jointly referred to as “SKE”). This also includes, in particular, all managers, who play an exemplary role in complying with and implementing our Code of Conduct.

To ensure comprehensive compliance, our Code of Conduct also applies to all our business partners unless they have their own adequate set of rules.

Regardless of the wording chosen, we always address all genders.

Compliance

We always act in accordance with all applicable laws, regulations and directives. Our conduct and our decisions are guided by ethical principles. We also respect the standards and customs of the countries in which we operate. In particular, we also reject “useful violations” of the law.

In the course of our business conduct, we must observe a variety of jurisdictions. Our employees are required to inform themselves to an appropriate extent about the laws, regulations, directives, standards, as well as business and cultural customs that apply in their area of operation. They are obliged to strictly comply with these together with our Code of Conduct and Mission Statement. Training that conveys this content must be completed as promptly as possible. In the event of any ambiguity or doubt, our employees are obliged to clarify this through their direct superiors or our Compliance Officer.

We choose our business partners and business areas carefully. For this purpose, our employees and especially our managers are obliged to analyse risks in advance. Potential corruption, bribery and money laundering risks are to be examined particularly carefully.

“Money laundering” is understood as an operation to conceal the origin of money or other funds obtained through unlawful conduct (e.g. tax evasion, corruption, fraud). SKE fully complies with all applicable anti-money laundering laws. Our employees and business partners are therefore strictly prohibited from accepting money or other funds if they are potentially related to money laundering.

All our employees are aware that violations of legal obligations can have serious consequences, even if these are not yet assessable at the time of the violation. This applies in particular to the violation of criminal law provisions. In addition to high penalties for executive bodies, employees and the company concerned as well as the obligation to compensate for the damage caused, SKE also suffers considerable damage to its reputation in such a case. The loss of the trust of our business partners can result in further economic losses for SKE.

SKE furthermore takes appropriate organisational measures to investigate and respond appropriately to every (suspected) case of legal and regulatory violations in a forward-looking manner. Every employee is free to contact his or her direct superior or (also anonymously) our Compliance Officer in such matters. Every business partner and every other person concerned may contact our Compliance Officer.

Anti-corruption

Our employees and all those who work for SKE are strictly prohibited from offering, promising, or granting any undue advantage to business partners of SKE if even the impression could arise that the business relationship is thereby improperly influenced. This applies equally and in particular in interactions with public authorities, civil servants or other public officials.

Likewise, all our employees and all those who become active on behalf of SKE must refrain from being promised or accepting, directly or indirectly, an undue advantage in connection with their work for SKE. If an employee is offered an undue advantage, this must be reported immediately to our Compliance Officer.

An undue advantage (e.g. invitations, gifts) also occurs if it is directed to persons or legal entities close to the business partner. Thus, donations and sponsoring agreements are only permissible if they do not unduly influence the business activity. Donations (without any value added for SKE) may only be granted for charity or social purposes.

Undue benefits may also be concealed. Payments made to consultants or agents must therefore be proportionate to their documented service. All our employees as well as all those who become active on behalf of SKE are prohibited from offering, contracting, paying, being promised or accepting improper or disproportionate commissions.

No undue advantage is given in the form of local and national gifts of low value (in any case less than € 100.00) if this corresponds to the customs of the respective region and does not violate applicable law. In case of doubt, our employees are obliged to obtain the approval of their direct superior. The latter may consult our Compliance Officer in advance.

Close relationships can lead to a conscious or unconscious influence on decision-making. All our employees and business partners are therefore obliged to inform SKE about possible conflicts of interest. If a close relationship of any kind exists, this must not lead to preferential treatment or disadvantage. In case of doubt, a decision must be brought to the attention of the direct superior in advance and the reasons for the decision must be documented with particular care.

Fair competition

Ensuring fair competition is a high value for SKE. We therefore rely on honesty and respect when dealing with both our business partners and our competitors. We strictly reject any unfair business practice and our employees are prohibited from engaging in such practices.

In particular, our employees, all those who become active on behalf of SKE as well as our business partners are prohibited from any agreements (arrangements) and concerted practices which have the purpose or effect of preventing, restricting or distorting competition. Therefore, all our employees are also obliged to keep trade secrets, such as in particular calculation bases, strictly confidential. If confidential information from competitors comes to the attention of our employees, it must be reported to our Compliance Officer. If there is any doubt as to whether a violation of this prohibition could occur, our employees are obliged to discuss this in advance with our Compliance Officer.

Misleading information about own or third-party products (e.g. about their availability, usability or quality) is prohibited. Any unobjective or derogatory remarks about competitors are prohibited as well.

Our employees and business partners know that the violation of antitrust, competition and public procurement law provisions can not only result in the highest fines and compensation obligations, but can also seriously damage SKE’s business activities in the long term, for example by excluding it from future public procurement procedures.

Sustainability and social responsibility

Sustainability is a fundamental principle of SKE’s activities. Every business activity must therefore be examined in advance for its economic, social and, above all, ecological impact. All our employees have a duty to comply with all applicable environmental protection regulations and to actively promote environmental protection.

SKE does not tolerate human rights violations or discrimination. At SKE and in business relationships with SKE, any form of human trafficking, modern slavery, wage dumping and child or forced labour is prohibited without exception. Compliance with labour and social law provisions as well as national and international standards is obligatory for all our employees and especially our managers. We also expect this from our business partners.

Each of our employees and business partners is obliged to inform themselves about applicable environmental protection regulations as well as labour and social laws in advance of a business activity. When selecting business partners, our employees must pay particular attention to compliance with human rights, environmental protection regulations, labour and social laws as well as national and international standards (e.g. ILO fundamental principles). Any suspicion of violations of these requirements must be reported immediately by our employees to our Compliance Officer.

It is a self-evident duty for all our employees to treat each other with appreciation and respect. Any form of discrimination, exclusion, verbal, or physical abuse, for whatever reason, is prohibited and will be strictly sanctioned.

We are committed to providing our employees with a good work-life balance. The continuous improvement of work quality and -atmosphere is of great concern to us.

Confidentiality and IT security

Confidentiality is a matter of course for SKE. All information accessible to us, which is to be regarded as our own trade secrets or those entrusted to us, is to be treated confidentially by all our employees. This also applies after leaving the company. The flow of information within SKE is based on the “need to know” principle.

Regardless of whether information is available in hard copy or digital form, it must be carefully stored by our employees. If information is expressly marked as “confidential”, it must be kept inaccessible to others. It is strictly forbidden to pass on confidential information to persons who do not need it in the course of their work for SKE. The disclosure of information to persons or bodies outside SKE requires the consent of the respective superior in every case.

The protection of our IT infrastructure is an important concern for us. All our employees must store their IT equipment carefully and treat it with care. All IT devices are to be provided with password protection with an appropriate level of security. Any loss or possible compromise must be reported immediately to the respective IT department. Our IT security policy must be strictly adhered to.

Data protection

SKE is committed to the comprehensive protection of personal data. Our employees and business partners are obliged to process personal data only in a legally compliant manner and to strictly adhere to all applicable data protection regulations (in particular the GDPR).

All our employees and business partners who process personal data in the course of their work for or with SKE must ensure that the data processing is carried out lawfully. The terms “personal data” and “data processing” are to be understood within the meaning of Article 4 GDPR. The transfer of data to third countries without an adequate level of security must be examined with particular care. If there are any doubts in connection with data processing, our Data Protection Officer must be consulted prior to data processing.

Contact

SKE Engineering GmbH
Compliance Officer
Gewerbeallee 15d
4221 Steyregg
Austria
+43 732 64 10 65
[email protected]

Imprint

Media owner and publisher:
SKE Engineering GmbH
Gewerbeallee 15d, 4221 Steyregg, Austria
www.ske-solar.com
FN: 315430v
Landesgericht Linz
registered office: Steyregg, Austria
UID: ATU64397405

Version: 1.02
As of: February 2023