Along with the Group Strategy and Corporate Governance Principles, our Code of Conduct sets out rules for how our employees are to conduct themselves with integrity. The Code of Conduct is accepted by our employees as part of their employment contract and hence has binding effect. It makes clear that active and passive bribery are not tolerated and further makes specific reference to the prohibition of money laundering and illicit financing. There are also specific rules of conduct, for example in the form of instructions for the avoidance and disclosure of conflicts of interest, for the granting and acceptance of benefits, gifts and invitations, for the arrangement of donations and sponsorships as well as with respect to sideline activities and involvement in other companies and business transactions. The Code of Conduct is thus intended to help our employees cope with challenges in their daily work. We consider integrity in dealings with our stakeholders to be the foundation of a successful enterprise. Both in our strategic planning and in day-to-day business, we therefore aspire to live up to the highest ethical and legal standards when it comes to the demeanour, actions and behaviour of every one of us.

As a listed company, we also emphasise to our employees the necessity of observing rules on insider trading and we specify blocking periods during which shares may not be traded.

Since mid-2012 our Code of Conduct for Suppliers has also been in effect at the Hannover location. Among other things, this requires compliance with environmental and social standards and it forms an integral component of contracts when it comes to, for example, tendering and awarding infrastructure services as well as various construction works. Existing supplier relationships in the areas of Facility Management and IT are also progressively checked for fulfilment of the Code of Conduct as part of an ongoing process. In 2017 the Code of Conduct for Suppliers was revised against the backdrop of the new legal requirements associated with the UK Modern Slavery Act; the updated version was approved by the Executive Board on 29 June 2017 and published on our website. Furthermore, we have explicitly committed to respecting and observing human rights concerns, such as equal treatment and anti-discrimination, and we also require this from our suppliers.

As a complementary tool, an application-supported procedure has also been developed for self-reporting by suppliers and service providers that similarly includes criteria from the Code of Conduct. In the context of an assessment carried out in 2014 all IT suppliers were contacted and evaluated on the basis of a checklist. This evaluation was stored in the supplier management system and will be factored into the selection of suppliers when placing future contracts; furthermore, these criteria are also used for the regular evaluation of suppliers. Contracts with critically assessed suppliers are not renewed; an early-warning system ensures that an adequate lead time is available to select and as necessary familiarise an alternative vendor. As a next step, we plan to extend this approach to our international offices in the United Kingdom and Ireland, followed progressively by our locations around the world.