Code of conduct

This Code of Conduct is based on our jointly developed values and applies without exception to all members of company organs, executives, and employees. Hence, this Code of Conduct contains the core principles that govern the actions of E-Lyte. The commitment to respect these principles forms a bond between all our employees. The Code of Conduct constitutes the framework within which we make decisions in the company; it provides the policies that govern our actions and against which our actions as a company are measured. The Code of Conduct is the basis for other company policies, which concretize it further.

This Code of Conduct underpins our conviction that we, as a corporation, can only be successful if we base our actions on the following core values:

 

We create solutions together
We are a team of talented people from a wide variety of fields. Together, we realize our full potential, create values and innovations. We face challenges together as a team.

 

We all bear responsibility
We bear ecological, social and economic responsibility at all levels. We all do our part in our daily work by constantly making our processes and work more environmentally friendly.

 

Appreciation is our key to success
We are transparent and honest. We treat each other respectfully and fairly. We value every individual. Appreciation is the key to our personal and professional development.

 

We create positive change
We are open to new things, courageous and passionate. We reflect on the status quo and never stop to create positive change.

 

The trust of our business partners, shareholders, the authorities, and the public is a special and precious commodity that requires lawful and responsible actions based on integrity. This trust is important for the reputation and success of our corporation.

We know that we are not measured by what we say but by how we act.

Kaiserslautern, Juni 2024 

1. Social responsibility

1.1. Responsibility for the reputation of the Company

Compliance with valid laws and legal regulations is part of our identity. E-Lyte complies with the respective applicable laws at local, national as well as international level.

E-Lyte is aware of its responsibility towards society and undertakes, without exception, all its business activities based on that responsibility. This means, first of all, respect for the laws valid from time to time.

In addition, E-Lyte has drawn up policies and rules that concretize the standards governing our cooperation with business partners and authorities. E-Lyte expects and endeavors to ensure that these rules and principles are also adhered to by our business partners that include, for example, suppliers, customers, service providers, distributors, advisors, agents as well as other third parties.

To prevent violations of legal obligations and internal company rules, E-Lyte has created a company-wide compliance organization that is available to all employees, managers and external parties as a point of contact. The compliance organization is coordinated by appointed compliance coordinators who report directly to the management board and have drawn up appropriate procedural rules for handling whistleblower reports.

In addition, employees, managers and external parties can contact the federal government’s external reporting office (by post, telephone, email or via a contact form) if necessary.

 

1.2. Responsibility for basic social rights

E-Lyte supports the compliance with international conventions for the protection of people’s civic, political, economic, and social rights as well as for the protection of the environment. This includes, among other things, the General Declaration of Human Rights of the United Nations, the Manifesto of the International Labor Organization (ILO) and the initiative for sustainable and responsible corporate governance (UN Global Compact). As a internationally active company we accept our responsibility and do everything we can, within the framework of our corporate policies, to ensure compliance with internationally recognized standards for human rights and the environment when it comes to our supply chain.

Hence, E-Lyte also expects those involved in its supply chain to act with integrity and respect sustainability, which is why we undertake to only collaborate with suppliers who are aware of these standards and act accordingly.

 

1.2.1. Protection of human rights

E-Lyte forbids all forms of slave labor, human trafficking, illegal child labor, illegal penal labor, and the physical abuse of employees.

Based on the respective statutory provisions, E-Lyte undertakes to abide by the principles of equal opportunities concerning the recruitment and promotion of employees. We furthermore respect the rights of our employees to equal treatment irrespective of ethnic origin and nationality, religion and ideology, gender, and sexual orientation, political or trade union activities, age, illness or disability or other personal characteristics. Discrimination of any kind shall not be tolerated by E-Lyte.

E-Lyte furthermore condemns any kind of bribery and corruption and respects the freedom of association as well as the right to collective bargaining negotiations.

 

1.2.2. Mutual respect

Every E-Lyte employee must be treated fairly and respectfully. Executives encourage employees through open and intensive communication, transparency, and teamwork. Every E-Lyte employee shall be appreciative of as well as respectful and open towards colleagues, undertake to avoid any type of discrimination and foster relationships that are based on fairness. Violence at the workplace, threatening behavior, intimidation, physical attacks, and any form of sexual harassment will be sanctioned.

 

1.3. Sustainability and protection of the environment

Sustainability, the protection of the environment as well as the improvement of living and environmental conditions are important corporate goals for E-Lyte. E-Lyte endeavors to continually optimize its corporate governance, ensuring that it meets the three benchmarks of economic, ecological, and social sustainability. Sustainable growth that guarantees the protection of the environment, a sparing use of its natural resources and respect for the living conditions of subsequent generations is a top priority for E-Lyte.

A summary of our principles governing sustainable management can be found in our comprehensive policies that, as all policies listed in this Code of Conduct, can be downloaded from our company’s home page.

We are very much aware of the scarcity of resources and our responsibility towards future generations, which is why we as a company pay particular attention to these issues. E-Lyte does everything it can to ensure that its products and manufacturing processes meet these requirements across its entire value chain. Every E-Lyte employee is personally responsible for the sustainable use of resources and the consistent reduction of emissions resulting from the company and its products and shall act accordingly at his place of work. The intention is to increase the resource efficiency of the material used and limit the environmental impact of one’s own commercial activity to a minimum. Considering these aspects, we pay particular attention to a responsible use of resources such as energy, water, construction, and raw materials as well as to a reduction of the quantity of waste generated with the aim of continually reducing the emissions of E-Lyte.

 

1.4. Leadership and management responsibility

The respect of law and order is a matter of course to us even if, as a result, certain business relationships do not materialize, or personal goals are not met. When it comes to compliance with statutory rules and internal policies, our executives must set an example. Responsible management and cooperation require decisions that are transparent and plausible.

It is the particular responsibility of our executives to prevent, within their respective field of responsibility, any breaches of laws, this Code of Conduct, and internal policies, which could have been avoided or made much more difficult through open communication and appropriate supervision.

Executives must fulfil their organizational and supervisory duties by, in particular,

• leading by example and explaining to their employees that statutory provisions, this Code of Conduct, and internal policies must be adhered to, and that non-adherence will not be tolerated; and
• by ensuring compliance with statutory rules and internal policies

 

1.5. Party political activities

On principle E-Lyte does not get involved in party political activities. This also applies to the financial support/sponsorship of parties, political organizations, and their representatives as well as activities or events performed in the name of E-Lyte.

Our employees as private individuals and citizens are free to take part in political processes in their spare time.

2. Occupational health & safety and environmental protection

In matters of occupational health & safety and environmental protection, E-Lyte must comply with various national and international rules that we as a company naturally comply with.

Every E-Lyte employee must know of and comply with the applicable laws, regulations and internal policies on occupational health and safety. All employees are called upon, in their own as well as their colleagues’ interest, to be constantly vigilant and aware of the potential risks associated with their work and work environment. Together we endeavor to keep potential dangers and risks to an absolute minimum and reduce any risks that we have become aware of.

Safety at work has the greatest priority for E-Lyte. We ensure safe working conditions that are in line with applicable regulations governing occupational health and safety. We respect these rules of occupational safety and regularly monitor safety standards to make working conditions safe and avoid health risks. Our employees are informed of the relevant rules and receive instructions on how to comply with them.

Our company takes responsibility for the environment, because only sustainable management enables long-term, secure and successful growth. Compliance with the laws and regulations that apply to environmental protection is a task and obligation that all of us take very seriously.

 

3. Cooperation with business partners and third parties

3.1. Fair competition

Competition and anti-trust laws ensure fair and genuine competition. In its business transactions E-Lyte always observes and complies with these laws. Every one of our employees is obliged to adhere to the rules of fair competition and abide by the provisions set out in our anti-trust policy.

Acting in a way that ensures fair competition means, for example, that no E-Lyte employee is allowed to enter into an arrangement with competitors that leads to the fixing or coordination of prices, conditions, capacities, the allocation of customers, markets, personnel and production programs. They must also refrain from exchanging such information with competitors. E-Lyte also acts fairly when dealing with suppliers, customers and distributors and does not unduly restrict their activities in the marketplace, so that the economic freedom of action of all partners is guaranteed.

 

3.2. Anti-corruption

We are not prepared to do business at any price. In a competitive environment, E-Lyte prefers to rely on the quality and value of its products and services and chooses its business partners exclusively based on competitive criteria (such as quality, price, and suitability of service).

Through clear policies, business processes and internal controls we support national and international efforts aimed at ensuring that competition is not undermined by corruption. It is essential to avoid even the appearance of offering inducements to our business partners.

Generally, E-Lyte employees must neither offer nor request, neither accept nor grant, neither promise nor be promised benefits by third parties to generate business opportunities or influence business proceedings in illegal ways.

It is strictly forbidden to offer payments, inducements, or other benefits in kind as well as invitations to officials, civil servants, politicians and other employees and representatives of state-owned or state-controlled enterprises and public institutions.

 

3.3. Expectations vis-à-vis business partners

E-Lyte also expects its business partners to comply with the principles set out in this Code of Conduct. To do business with us, our business partners must – as do we – adhere to the following principles and values and ensure their adherence in their own supply chain:

• Adhering to all applicable laws, regulations, and policies.
• Abstaining from corruption and bribery.
• Observing the human rights of their employees.
• Refraining from the use of forced labor, child labor and slavery.
• Respecting the freedom of coalition.
• Assuming responsibility for the health and safety of their employees.
• Engaging in sustainable production that makes a sparing use of resources.

 

3.4. Distributors, consultants, and agents

To sell its products and services E-Lyte also uses independent distributors, consultants and agents (distribution partners), who also make an important contribution to the sale of products. If distribution partners were to use illegal selling practices, such practices harm the reputation of E-Lyte. Under certain circumstances, illegal practices used by third parties may be attributed to E-Lyte, and result in (co-)liability. Hence, E-Lyte will do whatever is necessary to ensure that its distribution partners comply with the statutory rules. We meet our duty of care among other things by having implemented selection processes for the use of distribution partners.

 

3.5. Foreign trade and export control

National and international laws restrict or ban the importation, exportation or the trading of certain goods, technologies or services, the handling of certain products as well as the associated capital and payment transactions. The restrictions and bans may, among other things, be due to the quality or the intended use of the goods, the country of origin or use or the business partner himself.

All E-Lyte employees are obliged to comply with all applicable rules, among others those that cover foreign trade and export control laws, tax and customs laws, money laundering laws and anti-terror laws. This applies specifically to those E-Lyte employees who manage the importation and exportation of goods, technologies, and services.

 

4. Avoidance of conflicts of interest

4.2. Conflicts of interest

Every E-Lyte employee is obliged to make business decisions exclusively in the best interest of the company, separate private interests from corporate interests and always remain loyal to

E-Lyte. Any type of conflict of interest is to be avoided and, in cases of doubt, must immediately be disclosed to the superior.

The following situations may signify conflicts of interest:

• The private interests of a E-Lyte employee clash with those of E-Lyte.
• The professional judgment or conduct of a E-Lyte employee risks being affected by personal interests (e.g., personal relationship with external parties or contributions made by external parties such as gifts, rebates, etc.) to such an extent that the employee no longer makes business decisions that exclusively benefit E-Lyte or business decisions risk being adversely affected.
• E-Lyte employees acting on behalf of E-Lyte conclude contracts with persons that they are close to (e.g., family members and friends) or with companies where they or persons close to them have a (direct or indirect) shareholding. The common practice of acquiring minor shareholdings in listed companies is exempt.
• At E-Lyte, employee also works for a business partner or a competitor of E-Lyte.

 

4.2. Noncompetition clause

In addition to their work for E-Lyte, E-Lyte employees are not allowed to run or work for a company as employees, consultants or in another capacity, which, in part or in its entirety, is a direct or indirect competitor of E-Lyte. This ban on competition also includes other competing activities.

 

4.3. Shareholdings in other companies

E-Lyte employees have neither direct nor indirect (e.g., via family members) holdings in companies that have a business relationship with E-Lyte. The common practice of acquiring minor shareholdings in listed companies is exempt.

 

5. How to responsibly deal with company property

Every E-Lyte employee is duty-bound to protect the material and immaterial assets of E-Lyte and to responsibly manage company property. Company property includes all installations and facilities as well as intangible values such as know-how and industrial property rights. Any abuse and waste of company resources damages the operational and financial capacity of the company. Only the efficient use of all resources at all levels can secure the long-term success of the company.

 

6. How to responsibly deal with information

6.1. Reporting and external communication

Our reporting is at all times conducted promptly, truthfully, completely and in compliance with the applicable standards and rules. This applies irrespectively of the type of reporting and the

respective group of recipients. Every E-Lyte employee takes the greatest possible care when it comes to reporting. This duty of care and responsibility also includes the documents produced by third parties.

Making negative statements or defamatory comments about the company, business partners, competitors, or colleagues – in particular on social media – goes against our values and is not permitted.

The media as multipliers are particularly important for the presentation of the company to the outside world. Certain contact persons within E-Lyte have been appointed to deal with the media. Any inquiries made by the media or other persons who do not work for the company must be passed on to these contact persons or the managing directors.

 

6.2. Protection of business secrets

Our business secrets are a precious commodity; they ensure that we have a competitive advantage over our competitors. Every E-Lyte employee is obliged to generally protect any information of E-Lyte, its business partners and competitors, refrain from disclosing it to unauthorized persons and only grant access to such information if such disclosure is required for business reasons.

Confidential information covers, in particular, strategic, financial, and technical information, which may include details regarding the organization of the company, prices, markets, customers, suppliers, marketing strategies, business and financial plans, figures compiled for internal reporting, formulations, technologies, etc.

 

6.3. Data protection and safety of information

E-Lyte observes the rights of its employees and third parties concerning their personal data. The company undertakes the necessary measures to ensure that personal data is only processed in compliance with the respective applicable statutory rules and regulations.

When processing personal data E-Lyte shall ensure that this process is transparent for the parties concerned and that the statutory rights concerning the personal data of the parties concerned shall be upheld.

To ensure the safety of data processing E-Lyte has carried out appropriate technical and organizational measures. This guarantees the confidentiality, integrity, availability and verifiability of the systems and services in connection with data processing and, in particular, the prevention of unauthorized use.

7. How to deal with the Code of Conduct

The Code of Conduct is binding for the entire company and for every E-Lyte employee. Every E-Lyte employee has the right to insist that the rules set out in the Code of Conduct be applied to him. Management shall endeavor to ensure that all employees know and adhere to the Code of Conduct.

E-Lyte executives shall actively encourage the implementation of this Code of Conduct in their respective fields of responsibility, ensure compliance and live up to the principles and values set forth herein. They and the respective competent Compliance Coordinators are the first port of call for questions and help the employees act lawfully and in line with our values. The

management calls upon you as an employee of E-Lyte to read this Code of Conduct, gain an understanding of it, align your own behavior to its principles and thereby act with integrity.

The Code of Conduct cannot regulate every detail relating to the standards, procedures, and provisions of our company. If E-Lyte has approved specific policies, instructions, and provisions for certain cases, they complement this Code of Conduct and are binding.

Every E-Lyte employee is called upon to immediately notify his superior, the competent compliance coordinators or the responsible department upon receiving information concerning potential or known breaches of the applicable law, this Code of Conduct, or the internal policies.

The tips and information received will be treated and processed confidentially and with due care. E-Lyte shall inform the whistleblower within seven days and confirm receipt of the notification. If there is a well-founded suspicion that a breach has been committed, the appropriate Compliance Coordinator will contact the competent departments and take the necessary measures to clear up the matter and sanction any breaches established. Within three months after the notification E-Lyte shall inform the whistleblower as to how his report has been managed and what measures have been taken.

Reporting breaches or misconduct will not adversely affect the whistleblower unless he verifiably and knowingly disclosed or reported false information.

 

Download code of conduct