In times of intensified competition, a globally active company must work under clearly and consistently defined rules & regulations allowing it to act responsibly and in an exemplary manner in every pending business. These rules and regulations not only distinguish the company culture but also constitute PPMC's national and international reputation.

PREAMBLE

This Code of Conduct is to be understood as the PPMC guideline for executing our daily business as well as our short-, medium- and long-term strategy. Our activities are based on good governance considering socio-economic aspects for our decision-processes. Beside the UN Initiative of Global Compact these guidelines lay the basis for a fair, sustainable, ethical, and responsible management.

1. AREA OF APPLICATION AND LAW-ABIDING PRINCIPLE

This Code of Conduct is valid for the PPMC management as well as for all our employees and applies in addition to the respective laws and regulations of the countries in which PPMC is doing business.

We build our social and business actions on integrity, transparency, honesty, respect, and fairness and strictly prevent any discrimination whatsoever. These principles are valid for our relationship with external partners and clients as well as internally amongst the PPMC employees.

The management strictly supports values such as freedom of opinion, fundamental right to freedom of expression, principle of equal opportunity, and nondiscrimination of all employees.

PPMC's management as well as all our employees is committed to comply with all applicable national and international laws of countries in which PPMC is doing business. This includes all export control laws, bylaws and regulations, even if the business consultancy is not directly involved in international trade.

2. COMPORTMENT WITH OUR PARTNERS AND CLIENTS

Our behavior mirrors the business culture at PPMC. We commit ourselves to orient our social actions towards the rules of fair competition and not to make or support any arrangements that contradict these rules. By this commitment any form of corruption whether connected to individuals, companies, authorities or other institutions is strictly forbidden. Neither acceptance nor offering of gifts, with the exception of those of symbolic value and/or appropriate invitations to events and/or for dinner, lunch or similar being customary in place and only if and when the rules under this Code of Conduct and any applicable law will not be contradicted thereby, are allowed for PPMC's staff.

3. AVOIDANCE OF CONFLICTS OF INTEREST

Conflict of interest is existent if interest of a PPMC employee or of one of his/her close dependents should be at odds with the ones of PPMC. All PPMC employees are not only requested to prevent such conflicts of interest but also to inform the management without undue delay in case such conflict of interest should arise. Equity holding of other companies, whether as active or silent partner or shareholder shall only be allowed in case such involvement is not at odds with PPMC's interests and is not exerting influence on the management of such other company.

4. EXPECTATIONS FROM OUR BUSINESS PARTNERS

We expect from our associates to follow at least the same rules and regulations as outlined in principle in this Code of Conduct which includes in particular but not only to the strict rejection of corruption, the observance of human rights, the compliance with applicable national and international laws and fair behavior on the markets.

5. PROTECTION OF PROPERTY AND CONFIDENTIALITY

If not otherwise regulated in writing property of PPMC shall only be used for business purposes and must be protected against theft, loss, damage and malpractice as if it were property of the employee to whom PPMC has given access to such property for conducting his/her duties and responsibilities. All employees are committed to strict confidentiality vis-a-vis third parties whether related to any PPMC-internal business secrets or related to clients of PPMC or particular projects. This obligation is valid for an indefinite period of time even after termination of the employment.

6. QUALITY OF OUR CONSULTANCY

We are committed to providing excellent consultancy and measure the quality of our services on international standards. This includes continuous improvement by attending respective training and education.

7. BREACH OF RULES

Each employee is obliged to immediately report any breach of this Code of Conduct to the management of PPMC.

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