All employees agree to

All employees agree to

• comply with all applicable laws, regulations, and internal instructions
• strictly observe labor law provisions, accident prevention regulations, environmental requirements, and data protection laws
• protect and promote the good reputation of ZH Group and its clients
• conduct themselves respectfully, honestly, and responsibly at all times
• refrain from discrimination of any kind—in particular based on origin, gender, religion, ideology, disability, age, or sexual identity
• not to secure any improper advantages for themselves or others
• strictly separate private interests from business decisions
• not to solicit gifts, benefits, or advantages from clients or business partners
• to report violations of these compliance rules immediately

Prohibition of Bribery and Corruption

It is impermissible and strictly prohibited to

• offer, promise, or grant benefits to public officials or government representatives in order to influence official decisions
• provide business partners, colleagues, or third parties with unlawful personal benefits
• demand or accept unlawful benefits oneself
• tolerate, encourage, or actively support the unlawful conduct of others
• have third parties carry out improper actions

Avoiding the Appearance of Corruption

Courtesies, gifts, and invitations may be part of social customs. At ZH Group, they are generally permitted only if they are appropriate and transparent. To avoid any impression of improper conduct, the following guidelines apply:

• Gifts or invitations must be declined if they are clearly linked to a quid pro quo
• Gifts may not be accepted if they violate laws or internal policies
• Tips are permitted provided they are within customary limits and do not create expectations
• Employees may not demand gifts or benefits
• Invitations to leisure activities or events in a business context are only permissible if they are moderate, do not harm the company’s image, and do not impair fair competition

Avoiding conflicts of interest

Personal relationships and business decisions must be consistently kept separate. To ensure objective and fair cooperation, the following rules apply:

• Related parties must not be given preferential treatment in the awarding of contracts or orders
• Business relationships with companies in which family members or related parties are employed must be coordinated with management
• Secondary employment with competitors is strictly prohibited
• Secondary employment with business partners requires prior approval

Responsibility in Collaboration

ZH Group expects all employees, service providers, and business partners to

• comply with all applicable laws and legal requirements
• consistently refrain from corruption and unfair business practices
• comply with statutory minimum wage regulations
• actively support occupational health and safety measures
• comply with regulations regarding occupational safety, environmental protection, and data protection
• the protection of human rights
• the strict rejection of child labor
• compliance with legal regulations in international business transactions
• compliance with competition and antitrust laws
• the avoidance of price-fixing or market-sharing agreements

Possible Consequences of Violations – Employees

Violations of this policy may result in the following measures, among others:

• A formal warning under employment law
• Termination with or without notice
• Claims for damages by third parties
• Claims for damages by ZH Group
• Fines criminal consequences, including imprisonment

Possible consequences of violations – Company

For ZH Group, violations may have the following consequences, among others:

• Claims for damages by third parties
• Lengthy and costly legal proceedings
• Administrative fines
• Lasting damage to reputation
• Loss of revenue and decline in profits
• Job cuts

Contact persons for questions or reports

If you have questions, concerns, or become aware of potential compliance violations, please contact:

Employees: your respective supervisor
Customers: the responsible property, service, or division manager
Suppliers: the responsible purchasing department