I. Preamble

Prime Work Services and its companies recognize their social responsibility. In particular, all those involved in the procurement process, as intermediaries between the Group and its own companies and the suppliers in the respective procurement markets, bear responsibility towards customers and suppliers, towards the environment and towards Prime Work Services and its companies. Our actions are guided by the values of integrity and fairness.

Our Code of Conduct is a voluntary code designed to reinforce our interest in fair, sustainable, responsible ethical principles of action.

It applies to our management as well as to our employees and is intended to serve as the basis for all business relationships of Prime Work Services and its companies. The ethical guidelines described in this Code of Conduct are based in particular on the principles of the UN Global Compact (as an annex under point V), the ILO conventions, the UN Universal Declaration of Human Rights, the UN conventions on the rights of the child and on the elimination of all forms of discrimination against women, and the OECD guidelines for international companies. The following points II to V constitute minimum standards and are intended to prevent situations that may call into question the integrity of our companies and our employees. Prime Work Services and its companies observe the principles of the Global Compact and work towards their achievement in their management.

II. General principles, law and legislation

Prime Work Services and its companies are committed to fulfilling their social responsibility in all business activities. This means that we undertake to comply with the applicable laws and other relevant regulations of the country in which we operate in all business actions and decisions. Business partners are to be treated fairly. Contracts shall be honored, taking into account changes in the general conditions.

III Corruption/antitrust law/forced labor/child labor

a) Corruption
In dealings with business partners (customers, suppliers) and government institutions, the interests of Prime Work Services and its companies and the private interests of employees on both sides are strictly separated. Actions and (purchasing) decisions are made free of extraneous considerations and personal interests. The applicable criminal law on corruption must be complied with. Among other things, the following must be observed:

Crimes in connection with public officials:
The granting of personal benefits (especially monetary benefits such as payments and loans, including the granting of small gifts over a long period of time) to public officials by Prime Work Services, its companies and its employees to public officials (such as civil servants or employees in public service) with the aim of obtaining benefits for Prime Work Services and its companies, themselves or third parties are not permitted.

Crimes in business transactions:
Monetary personal benefits in return for preferential treatment in business dealings may not be offered, promised, granted or approved. Likewise, personal benefits of value may neither be demanded nor accepted in dealings with business partners. Prime Work Services and its companies impose on their employees that they do not allow themselves to be promised any such advantages. The management and employees of Prime Work Services and its companies may not offer, promise, demand, grant or accept gifts, payments, invitations or services in business dealings which are granted with the intention of influencing a business relationship in an inadmissible manner or where there is a risk of jeopardizing the professional independence of the business partner. This is generally not the case with gifts and invitations that are within the scope of customary hospitality, custom and courtesy. Prime Work Services and its companies may issue a binding policy on the acceptance and granting of gifts, invitations to entertainment and events. This may regulate exceptions with regard to appropriate low-value and symbolic gifts, appropriate business meals and appropriate events of the own companies as well as of business partners (customers, suppliers).

b) Conduct towards competitors (antitrust laws)
Prime Work Services and its companies respect fair competition: we comply with applicable laws that protect and promote competition, in particular applicable antitrust laws and other laws regulating competition. In dealing with competitors, these regulations specifically prohibit collusion and other activities that influence prices or conditions, allocate sales territories or customers or or customers, or improperly impede free and open competition. Furthermore also prohibit agreements between customers and suppliers that are intended to restrict the freedom of customers’ freedom to determine their own prices and other conditions for resale (price and other conditions for resale (price and condition fixing). In view of the fact that the demarcation between prohibited cartels and permissible cooperation can be problematic, Prime Work Services and its companies provide their employees with a reporting system through which the management can be contacted – also anonymously – in case of doubt.

c) Forced Labor and Human Trafficking
Prime Work Services and its companies reject all forms of forced labor and human trafficking.

d) Child labor
Prime Work Services and its companies observes the United Nations regulations on human rights and children’s rights. In particular, we undertake to comply with the Convention concerning the Minimum Age for Admission to Employment (Convention 138 of the International Labor Organization) and the Convention concerning the Prohibition and Immediate Action for the Elimination of the Worst Forms of Child Labor (Convention 182 of the International Labor Organization). If a national regulation concerning child labor provides for stricter standards, these shall be observed as a matter of priority.

IV. Principles of social responsibility

a) Human Rights
Prime Work Services and its companies respect and support the observance of internationally recognized human rights.

b) Discrimination
Prime Work Services and its companies undertake to oppose any form of discrimination within the framework of the respective applicable rights and laws. This refers in particular to discrimination against employees on the basis of gender, race, disability, ethnic or cultural origin, religion or belief, age or sexual orientation.

c) Health protection
Prime Work Services and its companies ensure occupational safety and health protection in the workplace within the framework of national regulations. We support continuous development to improve the working environment.

d) Fair working conditions
Prime Work Services and its companies respect the right to freedom of association and the working hours of its employees within the framework of the applicable rights and laws.

e) Environmental protection
Prime Work Services and its companies are committed to the goal of protecting the environment for present and future generations in a sustainable manner. Laws enacted to protect the environment must be observed. We use resources sparingly and keep the impact on the environment to a minimum. We support environmentally conscious actions by our employees.

f) Business Secrets
Prime Work Services and its companies oblige their employees to respect company / and business secrets. Confidential information as well as confidential documents may not be disclosed to third parties without authorization or made accessible in any other way, unless authorization has been granted or the information is publicly accessible.

g) Suppliers
Prime Work Services and its companies are committed to complying with and adhering to the principles and requirements of the Supply Chain Due Diligence Act and implementing them to the best of their ability in their day-to-day professional activities.

V. United Nations Global Compact

As an annex: The principles of the Global Compact are based on a worldwide consensus derived from

• the Universal Declaration of Human Rights
• the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work
• the Rio Declaration on Environment and Development, and
• the United Nations Convention against Corruption.

The Global Compact requires companies to recognize, support and put into practice within their sphere of influence a set of core values in the areas of human rights, labor standards, environmental protection and anti-corruption:

Human rights
1: Businesses should support the protection of international human rights within their and respect the protection of international human rights within their sphere of influence; and

2: ensure that they are not complicit in human rights abuses.

Labor standards
3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining.

right to collective bargaining, and further to

4: the elimination of all forms of forced and compulsory labor,

5: the elimination of child labor; and

6: the elimination of discrimination in respect of employment and occupation.

Environmental protection

7: Businesses should support a precautionary approach to environmental problems,

8: Take initiatives to create a greater sense of responsibility for the environment; and

9: Promote the development and diffusion of environmentally friendly technologies.

10: Businesses should work against corruption in all its forms, including extortion and bribery.