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Oetker Code of Business Conduct
“Code of Conduct”
Author: Group management of the Oetker Group
Bielefeld, February 10, 2011
version status date comment who
1.0 approved Feb 10, 2011 Signature Group management
Table of Contents
Preface .................................................................................................................................. 1
I. Scope of Application ....................................................................................................... 2
II. The basis: strict compliance with the laws ...................................................................... 2
III. Conduct in competition – antitrust law ......................................................................... 3
1. Dealings with Competitors .......................................................................................... 3
2. Dealings with Customers ............................................................................................ 4
3. No abuse of a dominant position in the market ........................................................... 4
4. Registration of corporate acquisitions and company divestitures ................................ 4
5. Early seeking of legal advice in antitrust issues .......................................................... 4
IV. No violations of anti-corruption laws ............................................................................ 5
1. Offering and granting of advantages ........................................................................... 5
2. Demanding or accepting advantages .......................................................................... 5
3. Conduct vis-à-vis office-holders .................................................................................. 6
V. Money laundering ........................................................................................................... 6
VI. Foreign trade provisions ............................................................................................. 7
VII. Protection of research and technical development ...................................................... 7
VIII. Separation of private and corporate interests .............................................................. 7
IX. Use of Company property ........................................................................................... 9
X. Secrecy/Protection of business secrets .......................................................................... 9
XI. Data protection and data security ..............................................................................10
XII. Documentation of business transactions ....................................................................10
XIII. Handling of files and recordings .................................................................................10
XIV. Dealings among Staff Members .................................................................................11
XV. Protection of the environment ....................................................................................11
XIV. Occupational safety ...................................................................................................12
XVII. Conduct vis-à-vis authorities ..................................................................................12
XVIII. Compliance with the Oetker Code of Conduct ........................................................13
1. Compliance organization ...........................................................................................13
2. Questions on the Code of Conduct, contact persons .................................................13
3. Complaints and indications ........................................................................................14
4. Consequences of violations .......................................................................................14
5. Revision of the Oetker Code of Conduct ....................................................................14
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I. Scope of Application
The Oetker Code of Conduct applies to all domestic and foreign companies of the Oetker
Group1 and is implemented by the individual Group companies (hereinafter referred to as the
“Company”). The principles of conduct codified in the Code of Conduct are binding for all
members of the supervisory boards, managing directors, executives and staff members of
the Oetker Group (hereinafter referred to as “Staff Members”2).
In addition to and irrespective of this Code of Conduct, the applicable laws shall certainly
apply to the conduct of all Staff Members. The Code of Conduct serves to make transparent
the fundamental legal requirements with which the Staff Members have to comply in their
activity for each Company of the Oetker Group to the latter and to make them aware hereof.
In addition to the general rules of this Code of Conduct, all rules and instructions that already
exist or will exist in the future in relation to special subdivisions shall continue to apply
without limitation and supplementary to this Code of Conduct. Staff Members must, for
instance, continue to fully comply with existing occupational safety, travel cost or purchasing
policies. If there exist any deviations in any particular case, the more stringent rule shall
apply.
Each Group Company may establish further rules of conduct, for instance, in order to
account for the particularities inherent in their particular field of business or country as long
as they are in line with the basic principles codified herein.
II. The basis: strict compliance with the laws
The Company respects applicable law and expects its Staff Members and business partners
to do likewise. A legal situation that is unfavorable in the point of view of any individual or the
Company may not be ignored. The Company observes applicable law, irrespective of
whether that is domestic, foreign or supranational laws, rules or any other provisions
(hereinafter referred to as “Laws”). All business matters shall be handled in the daily
business with customers, suppliers, Staff Members or government agencies in such a way
that they comply with all applicable Laws (such as labor law, tax law or customs law).
1 The “Oetker Group” refers to Dr. August Oetker KG and its subsidiaries.
2 The term “Staff Members” is hereinafter used for both male and female Staff Members. This applies
mutatis mutandis to other gender-specific designations.
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Any violation of imperative statutory provisions, e.g. of product liability law, antitrust law, data
protection law or environmental law, may lead to unforeseeable financial losses to the
Company and an impairment of its reputation. At the same time, the violation of the law might
result in damage claims against the general management, the responsible executives and
the Staff Members directly involved and finally, the competent authorities may institute
administrative proceedings, administrative offenses proceedings or even criminal
proceedings, depending on the facts.
The Company always acts through human beings. In safeguarding the legal system, the
interest of the Company and the interest of its Staff Members are completely identical.
Therefore, each Staff Member is obligated to comply with the Law applicable in his or her
scope of duties, and each executive must ensure compliance with this duty on the part of
their staff. For this reason, the executives must inform themselves and their staff on the Laws
applicable to their respective scope of duties.
It is strictly prohibited to cause third parties to perform illegal acts or to participate herein.
Executives shall be responsible that in their spheres of responsibility Laws will not be
violated by any conduct which could have been avoided by means of appropriate
supervision. They must make clear that violations of the Law are disapproved of and will
have disciplinary consequences. In this connection, the rules contained in this Code of
Conduct must expressly be brought to the attention of the Staff Members.
III. Conduct in competition – antitrust law
Antitrust Laws, also referred to as Law on competition, protect free competition. Violations of
Antitrust Law might lead to particularly high fines and damage risks both to the Company and
the responsible Staff Members.
1. Dealings with Competitors
Agreements and concerted actions between competitors that are intended to restrict
competition or have the effect of doing so are prohibited. The most important taboos under
Antitrust Law are agreements or concerted positions between competitors relating to: (1)
prices or price elements, (2) the division of markets, territories or customers, (3), boycotts,
(4) the control of the production process, the technical development or of investments, and
(5) those made or held in connection with calls for tenders. Even concerted actions, informal
talks or informal gentlemen’s agreements that are intended to restrict competition or have the
effect of doing so are prohibited. Staff Members must not even give the appearance of being
a part of such conspiracy.
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The mere exchange of commercially sensitive information with competitors is also prohibited,
in particular with reference to current or future prices or price elements, the time or amount of
price increases, discounts demanded by customers, distribution strategies, sales figures, the
state of annual talks, single customers, costs, new products, R&D, etc.
2. Dealings with Customers
Customers must remain free to fix their resale prices. Resale prices may not be agreed or
coordinated with customers, neither directly nor indirectly.
Nonbinding price recommendations are, however, allowed in principle. Price recommenda-
tions may, however, not be enforced through the exertion of pressure or the granting of
incentives.
The freedom of customers to export or import products of any Company of the Group of
Companies may not be restricted in a legally inadmissible manner. Export or import
restrictions may not be enforced through the exertion of pressure or the granting of
incentives.
3. No abuse of a dominant position in the market
If the Company holds a dominant position in any product market, increased antitrust
requirements apply. An abuse of market power may, for instance, exist in case of exclusive
distribution arrangements with customers, fidelity rebates or market share rebates, tie-in
transactions or refusals to supply without factual justification.
4. Registration of corporate acquisitions and company divestitures
As a rule, divestitures of businesses, corporate acquisitions or joint venture projects are
subject to merger control and thus need to be registered with the competent domestic and
foreign competition authorities prior to their execution. Within the scope of these permit
procedures, comprehensive information must be provided to the authorities. It must be
truthful and complete.
5. Obtaining legal advice in antitrust issues early
In all cases of doubt arising in the field of Antitrust Law, the respective executive, the legal
department or the Compliance Officer must be contacted at an early stage. The Company
will provide information on any details by means of separate rules of conduct and information
letters.
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IV. No violations of anti-corruption laws
In most countries, not only the corruption of office-holders and public administration
employees, but also commercial bribery is punishable both for the grantor and the acceptor
of the advantage. On the ground of numerous international anti-corruption conventions, rules
globally apply that are similarly stringent as those applied in Germany. In many countries,
such as Germany or the USA, corruption committed abroad is also punishable under
domestic law.
1. Offering and granting of advantages
In connection with their business activity, Staff Members may neither offer nor grant to
employees of business partners any unjustified personal advantages. Usual and appropriate
occasional gifts, advertising gifts of small value and invitations to business partners, which do
not aim at influencing business decisions in a dishonest manner, are exclusively admissible.
Gifts and invitations must be in accordance with courtesy and usual social practice and may
not be objectively suitable for an inappropriate influencing of business decisions according to
the circumstances of any individual case, the positions and personal circumstances of the
parties involved and the value of the gift. Any appearance of dishonesty or inappropriate
considerations must be strictly avoided.
Gifts or invitations may never be offered as incentives for conclusions of transactions or
additional orders. Even promising personal advantages (“incentives”) is punishable!
No gifts may be granted if a customer prohibits a granting of personal gifts to their staff.
Offering money or vouchers (e.g. gas vouchers or phone cards) is prohibited!
The following applies at all times: If a conduct as set out above is observed with any
competitor, this is no justification for own misconduct. In order to oppose such business
practices, the Staff Members should inform their supervisors and the legal department in
charge.
2. Demanding or accepting advantages
In connection with their official duties, Staff Members may not demand or accept any
unjustified advantages. The prohibition applies unrestrictedly to demanding advantages.
Usual and appropriate occasional gifts, advertising gifts of small value and invitations to
business partners, which do not aim at influencing business decisions in a dishonest manner,
are exclusively admissible.
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The following also applies in this connection: gifts and invitations must be in accordance with
courtesy and usual social practice and may not be objectively suitable for an inappropriate
influencing of business decisions according to the circumstances of any individual case, the
positions and personal circumstances of the parties involved and the value of the gift. Any
appearance of dishonesty or inappropriate considerations must be strictly avoided.
Demanding or accepting money or vouchers (e.g. gas vouchers or phone cards) is
prohibited.
3. Conduct vis-à-vis office-holders
In relation to domestic and foreign public servants, civil servants or government employees,
almost every offering or granting of advantages constitutes a criminal offense. In order to
protect public confidence in the fairness of public service, more stringent measures apply in
this respect.
Not only personal gifts in connection with illegal official acts (“bribery”) are punishable in
particular, but also personal gifts granted for the legal discharge of duty (“conferring a
benefit”). In order to definitely rule out criminal liability, personal gifts to public servants shall
be completely avoided.
The prohibitions of corruption are not restricted to public servants, but also apply to
individuals who, in the broadest sense, are entrusted with sovereign tasks.
The Company provides information on details relating to issues of the anti-corruption Laws
by means of separate rules of conduct and information letters.
V. Money laundering
No Staff Member, either alone or in collaboration with third parties, may take measures that
violate domestic or foreign regulations on money laundering. “Money laundering” means in
particular the introduction – e.g. by conversion or transfer – into the regular economic cycle
of money or other assets originating directly or indirectly from a criminal offense. In cases of
doubt about the permissibility of financial transactions, the Staff Members shall make
inquiries, for instance, if, in connection with a cross-border transaction, payments are to be
made on a third-country account. Accepting cash is prohibited, if it is not a customary
business practice.
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VI. Foreign trade provisions
The Company complies with all foreign trade provisions applicable in the respective countries
where it pursues its business activities, e.g. export control and customs provisions,
provisions pertaining to the suppression of terrorism or to the use of dual-use products.
Foreign trade provisions might prohibit or restrict the export, import or domestic trading of
goods, services or technologies as well as capital and payment transactions. The
prohibitions and restrictions may be due to the nature of the goods, the country of origin
and/or use or the person of the business partner.
VII. Protection of research and technical development
The Company protects its own advance in knowledge and respects the rights of third parties.
The results of our research and our technical development constitute valuable assets. Not
only decisions of significant economic importance are based thereon. The safety and the well
being of our Staff Members, customers and fellow citizens might depend hereon. Our R&D
staff and the technicians are thus obligated to elaborate, document and communicate the
results of their activities in accordance with valid scientific and technical standards.
Inventions, patents and other know-how secure the future and are thus of outstanding value.
Utmost care shall thus be taken over the corresponding legal protection of the inventions. No
Staff Member may pass on new findings or trade secrets in any form to any uninvolved Staff
Members or any third parties. Procedures, formulas and techniques must be treated as
strictly confidential under any circumstances unless they are in the public domain. All
agreements with third parties which deal with the granting of licenses or the transfer of know-
how must have been reviewed by the department in charge prior to their signing. Each Staff
Member must respect protected privileges of third parties and must refrain from their
unapproved use.
The protection of product names as well as any other industrial property rights is of vital
importance in many divisions of the Company. For this reason, a secured legal foundation
must be created for product names and industrial property rights prior to their use by the
Company by means of their registration within the country and abroad.
VIII. Separation of private and corporate interests
The personal interests of the Staff Members and the interests of the Company must be
strictly separated. Staff Members of the Company are obligated to make their business
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decisions in the best interest of the Company and unaffected by personal interests. A conflict
of interests exists if a corporate decision might conflict with any personal interests of an
occupational, financial or private nature. Sidelines for competitors, customers or suppliers or
the awarding of contracts to related parties or companies in which a Staff Member or a party
related to him or her has an interest serve, for instance, as examples for conflicts of interest.
Each Staff Member must separate his or her own personal interests from those of the
Company. Therefore, each personal interest which a Staff Member might have in connection
with the performance of his or her duties needs to be notified to his or her supervisor without
delay. This also applies, if the Staff Member is convinced that he or she might disregard own
interests and acts solely in the interest of the Company as even the mere impression that a
Staff Member might have considered own personal interests in a decision-making process
must absolutely be avoided. In cases of doubt, the supervisor shall delegate the matter to
another Staff Member.
As regards business relationships with third parties, objective criteria are all that counts.
Suppliers are chosen in accordance with appropriate criteria, such as price, quality, reliability,
technological standard, product suitability, existence of a long-standing and trouble-free
business relationship and existence of quality management. The conclusion of a contract
must not be influenced by personal relationships or interests. Business opportunities that are
due to the Company must not be used for own purposes. Personnel decisions must not be
influenced by private interests or relationships either.
No Staff Member may make use of internal knowledge on any projects of the Company –
such as the intended sale of parts of the Company, the acquisition of third-party companies,
the establishment of joint ventures or any other facts relevant to the Company – to his or her
advantage or to the advantage of a third party, either directly or by the involvement of a third
party. No Staff Member may disclose corresponding knowledge to any parties not involved in
the concrete project or to any third parties.
Any outside employment of a Staff Member may neither impair his or her main employment
nor lead the Staff Member into a conflict of interests. This applies in particular to positions
with companies that already do business or compete with the Oetker Group.
Interests of Staff Members or of any parties related to them in companies which do business
or compete with any Company of the Oetker Group must be notified in writing. Following the
notification of interest, the Company may take appropriate measures for a removal of a
possible conflict of interests. A duty to notify does not exist, if, due to the interest, there exists
no possibility to influence the management of the Company, for instance, in case of interests
in listed companies, which amount to less than 5% or in case of mere investments made to a
negligible extent.
Page 9/14
However, the Company welcomes a private involvement in clubs and societies, political
parties or any other social or political institutions as long as the voluntary involvement in such
organizations does not interfere with the performance of the Staff Members’ duties or
conflicts with justified interests of the Company. When expressing their personal opinions in
public, Staff Members must not give the impression that these opinions represent the views
of the Company.
Donations of the Company must exclusively be caused by the executive management und
must be made in compliance with the legal system. Staff Members may not donate any
monies, physical assets or services of the Company to political parties or candidates for or
within public offices.
IX. Use of Company property
Each Staff Member is obligated to use the property of the Company in a careful and
responsible manner und to use corporate property solely for admissible business purposes.
Corporate property must be protected from loss, theft or abuse. Unless for business
purposes, property of the Company may not be removed from the Company premises
without the supervisor’s permission for official purposes. Data stocks, programs or company
papers may not be copied or removed from the Company’s premises without approval.
When using equipment and resources of the Company (inter alia, telephone, computer,
internet and other information technology), the internal guidelines and other rules of the
Company must be observed. Any use for private purposes is only admissible to the extent
this is allowed by the guidelines and rules mentioned.
X. Secrecy/Protection of business secrets
The Staff Members are required to maintain secrecy with respect to all trade and business
secrets, other internal confidential matters of the Company as well as with respect to all
confidential information provided by or on our customers and other business partners. All
information is deemed confidential that is designated as such or with reference to which it is
to be assumed that it is not and shall not be in the public domain, for instance, as it could be
useful for competitors, or whose disclosure could be detrimental to the Company or its
business partners. Confidential information, inter alia, includes data relating to Staff
Members, customers or suppliers, plans for new products, production processes, financial
data, corporate acquisitions or divestitures. The duty to observe secrecy exists both for the
duration of the employment and beyond its termination.
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Confidential information must be protected from any unauthorized inspection by third parties.
Also in intercompany dealings it must be ensured that confidential information may only be
passed on to Staff Members who require such confidential information for the performance of
their duties.
XI. Data protection and data security
All Staff Members are obligated to treat personal data (e.g. name, address, telephone
number, date of birth of Staff Members, customers and others) as strictly confidential and
with utmost care and, in doing so, are obligated to comply with the data protection provisions
both in electronic data traffic and otherwise. Personal data may only be collected, stored,
processed or used in so far as is admissible, i.e. required for specified, explicit and legitimate
purposes. In cases of doubt the corporate Data Protection Officer is to be involved. Personal
data must be protected from unauthorized inspection or access. A high standard must be
guaranteed in the implementation of the technical protection from unauthorized access. The
respective national statutory provisions must be complied with.
XII. Documentation of business transactions
All business transactions must be documented completely and properly in accordance with
applicable statutory provisions, and beyond, in accordance with the provisions applicable at
Oetker. The generally accepted accounting principles must be complied with; accordingly,
data collections and other recordings must always be complete and correct and must be
carried out promptly and in a system-compliant manner. The preservation periods for
documents must be observed.
XIII. Handling of files and recordings
All documents and data carriers belonging to a workplace may not fall into the hands of
unauthorized persons und must be kept under lock and key in principle. Computers must be
protected in accordance with the safety provisions of the Company, for instance, by awarding
passwords and their frequent change. It must be ensured that no third party might access
data stocks even in case of a longer absence from work. Staff Members may solely make
copies of business records or files of the Company for official purposes.
Apart from cases of substitution and from the respective supervisor, there exists no right of
access to information that does not affect the respective Staff Member’s own activity. Each
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deliberate unofficial taking of notice of any communication addressed to third parties is thus
inadmissible.
Each Staff Member must always consider carefully what is to be communicated via
documents and in e-mails. Any correspondence containing improper statements or which
might give the appearance of inappropriate or illegal conduct must be avoided.
All recordings and files must be kept in such a way as to permit delegation to a colleague at
any time. Therefore, files must, inter alia, be complete, orderly and readily understandable.
XIV. Dealings among Staff Members
Each Staff Member must know that his or her conduct is also attributed to the Company and
thus characterizes the Company’s outward and inward reputation. The Company thus
expects each Staff Member to be friendly, objective and fair in his or her dealings with
colleagues.
No person is to be disadvantaged, favored, harassed or ostracized because of race or
ethnicity, gender, religion or ideology, disablement, age, sexual orientation or appearance. A
differential treatment for legally justified reasons remains unaffected.
Sexual harassment is prohibited. Each Staff Member is entitled to protection from acts of
harassment.
First and foremost, the dealings of all Staff Members must be done with confidence.
Communication is the basis of preparing decisions. Each Staff Member must be willing to
contribute the highest possible degree of own expertise as well as expertise of other
departments to a decision-making process. In addition to teamwork skills, one own’s initiative
belongs to successful project work.
XV. Protection of the environment
The Company endeavors to handle environmental resources as sparingly as possible, to
avoid hazards to humans and the environment and to continuously improve all procedures
and processes that serve to further reduce environmental pollution. All Staff Members are
committed to this target.
Each Staff Member is jointly responsible for the protection of humans and the environment in
his or her working environment. All Laws and regulations pertaining to environmental
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protection and plant safety must be strictly observed. Each supervisor is obligated to instruct,
supervise and support his or her staff in taking responsibility.
In dealing with primary or end products that might be harmful to the environment, e.g. their
transport, loading and unloading, storage or chemical conversion, environmental and
occupational safety must be preserved.
Waste disposal must be effected in accordance with statutory provisions. Where third parties
are involved for such purpose, it must be ensured and documented that they comply with the
relevant statutory provisions and other requirements of the Company as well.
In general, no commercial usage of air, water or soil may take place without a permit. The
construction and operation of production facilities as well as their change or expansion also
require a permit in principle. The unauthorized operation, each deliberate or merely accepted
exceeding of the limits set in a permit for the plant operation or the unauthorized discharge of
substances that are detrimental to the environment into the water exposes the responsible
parties to the risk of criminal prosecution. In addition, damage claims of third parties may
lead to a financial burden of the Company. Each unauthorized release of substances must
thus be avoided.
XIV. Work safety
Each Staff Member is obligated in his or her best interest, but also in the best interest of his
or her colleagues and the entire Company to apply all employment protection and work
safety provisions consistently. The existence of and compliance with appropriate procedures
and protective measures for the warranty of safety and health at work must be ensured.
Each supervisor is obligated to instruct, supervise and support his or her staff in taking
responsibility.
XVII. Conduct vis-à-vis authorities
The Company endeavors to cultivate a cooperative relationship with all competent authorities
that shall be characterized by openness.
In this respect, it may not be underestimated that it is the duty of several authorities to punish
violations of applicable Law. Such procedures are effected in accordance with certain rules.
These rules also include the right of the affected parties for legal assistance. The protection
of this right and the use of the “privilege of silence” are not deemed to be an admission of
guilt. Information shall only be provided and files shall only be presented after consultation of
the legal department in charge and/or an external legal adviser.
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In case of hearings, interrogations or searches by investigating agencies, it is up to the Staff
Members of the legal departments in charge to ensure protection of the rights of the affected
persons. All Staff Members who are responsible for the compilation and transmission of
corporate information to any agencies will provide this information completely, openly,
correctly, duly and in a readily understandable form.
XVIII. Compliance with the Oetker Code of Conduct
1. Compliance organization
Dr. August Oetker KG establishes a compliance organization for the Oetker Group which
shall ensure the implementation of this Code of Conduct. Two Compliance Officers are
appointed who shall be in charge of the Oetker Group and responsible for the further
development of the Oetker Code of Conduct and the organizational implementation. One
Compliance Officer will be appointed for each Company managing the divisions of the Oetker
Group and for further individual subsidiaries. In all other subsidiaries, a Staff Member shall
assume the function of Compliance Officer. The corporate audit department of the Group
shall verify the implementation and adherence to the Oetker Code of Conduct in regular
intervals.
2. Questions on the Code of Conduct, contact persons
This Code of Conduct can certainly not cover all conceivable situations. In cases of
uncertainty arising with respect to proper conduct, each Staff Member is expected to seek
advice before he or she takes a measure which might lead to a violation of applicable Law or
of internal guidelines. As a rule, violations of the Law can be avoided by preventive advice.
The respective supervisor, the departments in charge (e.g. the human resources department,
the works manager, the legal department, etc.), the Compliance Officer or the otherwise
designated contact person of the respective subsidiary or the Group Compliance Officers are
available. In general, Staff Members might contact their supervisors in case of any questions
that might arise in connection with the Code of Conduct through ordinary official channels as
the latter knows the sphere of responsibility best. Where questions arise with reference to a
specific field, the respective specialist departments will be able to provide assistance. Legal
questions might be addressed to the legal department in charge.
You may also turn to any of the Group Compliance Officers at any time who are available as
neutral and independent contact persons.
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3. Complaints and indications
If any Staff Member takes notice of a significant violation of any Laws or the rules set out in
this Code of Conduct, he or she has the opportunity to inform his or her supervisor as well as
the corporate audit department or the Compliance Officer or any other designated contact
persons of the respective Company.
In addition, all Staff Members have the opportunity, at any time, to report any indications of
misconduct (e.g. criminal offenses) or dubious or legally doubtful occurrences in their
working environment to the Group Compliance Officers. This also applies in particular to the
reporting of facts that violate this Code of Conduct.
It is warranted that all occurrences reported to the Compliance Officers are inspected and
settled properly (with the help of other specialist departments, where required). Violations of
this Code of Conduct are investigated by the corporate audit department. To the extent
required, action will be taken after a careful inspection of the facts.
If the person giving the information assumes that he or she might incur any personal
disadvantage due to the notification, notifications can also be made confidentially and
anonymously, that is, without giving the name.
The general partners of Dr. August Oetker KG warrant that no detriment or any other
disadvantage arise to Staff Members who make use of the hotline to the best of their
knowledge and in good faith.
4. Consequences of violations
A violation of the Oetker Code of Conduct, any other Oetker guidelines or of applicable Laws
may lead to disciplinary action, a termination of employment and other legal action.
5. Revision of the Oetker Code of Conduct
Legal provisions and rules of conduct might change. A regular revision of the Oetker Code of
Conduct is thus provided. All Staff Members are requested to participate in the further
development of the Code of Conduct.