Code of Conduct

As of January 5, 2026

1. What we are about

Espas GmbH stands for responsible, reliable, and respectful conduct within the team, in the market, and towards society. This code of conduct outlines the guiding principles that inform our daily behavior.

Important: This code is a guideline . It does not replace laws, contracts, or internal policies and does not establish any individual legal claims . The applicable legal requirements and the internal regulations of espas GmbH always take precedence.

2. Law-abiding and correct conduct

We act in accordance with the law and expect the same from everyone who works for espas. This includes, in particular:

• proper documentation and truthful information,
• no deception, manipulation or deliberate misrepresentation, regardless of the goal or time pressure,
• Compliance with internal approvals, responsibilities and processes.

If something isn't clean, it's addressed, not "straightened out".

3. Integrity and fairness in everyday life

We work with decency and a professional attitude:

• Respectful interaction, clear communication, objective criticism,
• no intimidation, belittling or exploitation of dependencies,
• Take responsibility for decisions, mistakes, and their correction.

4. Diversity, equal treatment and personal dignity

At espas, performance and conduct count, not origin or personal characteristics. We do not tolerate discrimination or harassment, especially not on the basis of:
Origin, skin color, gender, religion/worldview, age, disability, sexual identity or other personal characteristics.

5. Safety, health and ability to work

Safety takes precedence over speed. We expect:

• Consistent adherence to safety instructions and PPE requirements,
• Reporting of hazards, near misses and accidents,
• Working safely on machines and equipment in accordance with instructions.

Working under the influence of alcohol or drugs, or with safety-related limitations, is not compatible with our standards.

6. Fair competition and market behavior

We win contracts through quality, reliability, and competence, not through unfair means. Therefore:

• no agreements with competitors regarding prices, terms, quantities, customers, markets or technical features,
• no disclosure or use of third-party trade secrets,
• Protecting our own know-how and confidential information.

7. No corruption, no undue advantages

We make decisions based on objective criteria. The following are inadmissible:

• Offering, promising, or granting advantages to influence decisions,
• accepting benefits that could create the impression of dependency or quid pro quo,
• any form of unfair influence towards public officials or decision-makers.

If a gesture seems "strange", it is usually not okay.

8. Human rights and fair working conditions

We respect fundamental human and labor rights. This includes:

• no forced or child labor,
• respectful treatment, appropriate working conditions,
• Compliance with the applicable rules on working hours and remuneration in the respective legal jurisdiction.

9. Environmental and resource protection

We want to avoid burdens where possible and sensible:

• Compliance with relevant environmental regulations,
• careful handling of materials, energy and consumables,
• Avoiding waste and unnecessary emissions within our means.

10. Data protection, confidentiality and information protection

We protect personal data and confidential information:

• Access only when required for the task,
• careful handling of documents, IT systems and access data,
• No unauthorized disclosure to third parties.

Incident investigations are conducted in compliance with the applicable data protection regulations.

11. Suppliers, service providers and partners

We expect business partners to adhere to comparable basic principles in their collaboration, particularly with regard to:
Compliance with the law, integrity, labor and human rights, occupational safety, and environmental standards. Selection and cooperation are based on objective criteria and without discrimination.

12. Notices, reports and handling of violations

Anyone with information about potential misconduct should report it promptly and objectively. Reports can be made via:

• the respective manager, or
• Alternatively, via the management.

Information will be treated confidentially to the extent legally and organizationally possible. Discrimination based on good faith reports will not be tolerated. Consequences for violations will depend on the severity, circumstances, and applicable regulations.

13. Scope

This code of conduct applies to espas GmbH and is directed at all employees as well as – within the framework of cooperation – at commissioned third parties.