Code of Conduct

Foreword by Management

Dear Employees,

In our Code of Conduct, we describe the basic values of the X1F Group, which form the basis for our business activity. To achieve this, we need the support of all X1F Group employees. The basis for our sustainable growth and market existence is acting with integrity and in a value-oriented manner towards our employees, business partners and society.

It’s Always About People.

This is the underlying credo of our actions. Employees should be guided by our core values – TRUST, COURAGE, HONESTY, FAIRNESS – and treat others with openness, tolerance, appreciation and mutual respect.

For the management of the X1F Group as well as for each individual subsidiary, it is therefore important that management and employees act in accordance with the basic values and rules of conduct of the X1F Group and avoid the risk of legal violations. This includes consistent compliance with all applicable regulations. All X1F Group employees are obliged to comply with the requirements described in this document.

Violations of the above rules can potentially cause lasting damage to X1F‘s market reputation and may lead to severe legal consequences for the company and/or the individuals responsible for the violation.

  • Code of Conduct compliance applies equally to all X1F Group employees – regardless of position or corporate entity.
  • Our managers are expected to ensure Code of Conduct compliance in their respective areas of responsibility.
  • All X1F Group employees are requested to report Code of Conduct violations directly to management via compliance@x1f.one. These notifications are treated confidentially by the Compliance Team as a matter of principle.
  • All Group subsidiaries offer corresponding training courses, which may deal with topics such as AGG, corruption prevention, confidentiality, data protection and IT security. X1F Group employees are required to participate in these regular trainings.

All X1F Group employees are bound to comply with this Code of Conduct by virtue of their employment contract within the respective X1F companies.

Hamburg, 19.01.2023

The Management Team

 

1. Principles

Compliance with all applicable laws and regulations is a matter of course for us. In individual countries, business areas or markets, or vis-à-vis business partners, stricter regulations may exist than those described here. In such cases, the stricter local regulations must generally be applied.

We are committed to the ten principles of the United Nations Global Compact and constantly strive to develop further in this respect. The regulations of this Code of Conduct serve above all to prevent and combat corruption as well as provide guidance for the internal and external conduct of our employees.

In addition, the following principles apply to X1F Group employees and all persons who perform functions on behalf of the company worldwide. In case of questions or concerns, our employees can contact their direct manager, executive management, our Compliance Officer (Sebastian Raguse) or the Compliance Department via:
compliance@x1f.one

  1. We conduct our business fairly, honestly and transparently so that third parties can understand our decisions.
  2. We promote a culture of open communication in an atmosphere wherein employees can approach their superiors or top management with critical issues without hesitation and in a spirit of trust.
  3. We do not offer or accept bribes – either directly or in a roundabout way.
  4. We do not accept bribes, even in a roundabout way
  5. We do not accept bribes, even in a roundabout way. – Delete this comment – duplicate of #3
  6. We avoid doing business with individuals or companies that do not mirror our values and could damage our reputation. Managers encourage open discussion, support their employees and address concerns fairly and without prejudice.
  7. We maintain our accounting records accurately and document all important decisions.
  8. We ensure that all company employees and business partners are aware of our principles.
  9. We deal openly with identified cases of corruption.
  10. We will periodically review and, when necessary, update our programs and operations.

 

All X1F Group employees are obliged to maintain confidentiality regarding business and trade secrets of the X1F Group and its customers. The duty of confidentiality does not end with the termination of the employment relationship.

 

2. Future Changes

This policy applies to all employees as amended from time to time and communicated by X1F.

Changes to this policy are effective informally. X1F Group employees will find the currently valid regulations in the X1F Sharepoint (https://x1fgroup.sharepoint.com/). In the event of major changes, central communication will take place as deemed necessarynecessary.

 

3. General Rules of Conduct

3.1 Law and Responsibility

BRIBES AND KICKBACKS ARE FORBIDDEN AND POTENTIALLY PUNISHABLE WORLDWIDE.

X1F Group employees, including management, shall behave in such a way that no personal and/or economic dependencies or obligations arise. Our regulations are fundamentally based on German law, unless this conflicts with mandatory national regulations in other countries.

X1F Group employees shall refrain from any attempts at bribery. If they become aware of a bribery attempt, they shall report this immediately to the Group Compliance Officer.

Practical Help

What is bribery?

“Offering, promising, or giving gifts or other benefits to a public official or a person specially obligated for public service and an employee in the course of business.”

https://wirtschaftslexikon.gabler.de

Forms of Bribery:

1) Bribery in the narrower sense: granting, promising or offering gifts or other advantages

2) Bribery / Acceptance of benefits: granting, promising or demanding gifts or benefits for specific purposes

3.2 Fair Market Behavior

X1F GROUP EMPLOYEES ARE REQUIRED TO COMPLY WITH THE RELEVANT PROVISIONS OF ANTITRUST AND COMPETITION LAW.

Our business success is based on our innovativeness, quality, reliability, integrity and fairness. That is why we always act honorably and in compliance with antitrust law in our dealings with competitors, business partners and end customers.

We refrain from any conduct that has the purpose or effect of hindering, restricting or distorting free and fair competition. This includes, but is not limited to, agreements or contracts at the vertical level (with suppliers or customers) if these intend or have the effect of preventing or restricting free and fair competition contrary to applicable laws.

In their respective areas of responsibility, our employees help to implement and adhere to these requirements. In discussions or other contact with competitors, they avoid topics that are of importance for competition among themselves.

Practical Help

Acts against Restraints of Competition
https://www.gesetze-im-internet.de/gwb/

Laws against Unfair Competition
https://www.gesetze-im- internet.de/uwg_2004/

3.3 Money Laundering Prevention

THE X1F GROUP COMPLIES WITH ITS LEGAL OBLIGATIONS TO PREVENT MONEY LAUNDERING AND DOES NOT PARTICIPATE IN ANY SUCH ACTIVITIES.

X1F Group employees shall comply with all relevant regulations on recording and accounting for transactions and contracts in their area of responsibility. In case of doubt, t hey are requested to call out unusual financial transactions that may give rise to suspicion of money laundering checked by the Compliance Department.

Practical Help

Definition: The aim of money laundering is to conceal illegally acquired income or assets from law enforcement authorities and channel the money into legal financial institutions The concealment takes place, among other things, via letterbox companies, companies in a tax haven or shadow banks

The following indicators may suggest an attempt to launder money:

  1. Lack of transparency (concealment of parties involved and purpose of a transaction).
  2. Customer is located in a country known for money laundering.
  3. Unusually high cash deposits.
  4. Willingness to make purchases with high cash payments.
  5. Lack of knowledge about the business for which the financial transaction is made.
  6. Customer owns an unusually high number of accounts.
  7. Customer tries to disguise their identity.
  8. Third parties are included in the transaction for no apparent reason.
  9. Investment terms and conditions are unimportant, willingness to accept bad conditions.

3.4 Insider Trading Rules

ALL X1F GROUP EMPLOYEES ARE OBLIGED TO COMPLY WITH THE INSIDER TRADING RULES OF THE SECURITIES TRADING ACT, IN PARTICULAR THE PROHIBITION OF INSIDER TRADING

This includes, in particular, employees who are given access to non public information about X1F Group customers.

Such inside information from our customers includes, for example, management plans, new product or manufacturing introductions, corporate transactions, sales and profitability, etc., as well as significant customer contracts or business relationships, financial information or significant customer litigation.

If an X1F Group employee becomes aware of such information that a reasonable investor would consider significant in making an investment decision suc h employee shall not buy or sell shares of such clients or disclose such inside information to other persons until the information becomes public. The use of material non public information may constitute a violation of law.

 

3.5 Communication

WE ENSURE CONSISTENT AND TRANSPARENT COMMUNICATION.

Communications within the X1F Group

We communicate with all of our colleagues in an honest and respectful manner and at all times on an equal footing We follow the general principle of equal treatment in all our actions People are our focus, regardless of origin, hierarchical level mental or physical limitations, gender, age, sexual orientation, religion or ideology. Nevertheless, we show the best possible consideration for one an other ‘s individual life circumstances and treat each other with understanding.

Communications with Business Partners

The trust of our business partners, investors and other stakeholders is the basis for successful long term cooperation. The implementation of communication and marketing measures of the various corporate divisions should therefore be coordinated with the respective marketing/communications team or persons responsible. If cross group communication is to be carried out a brief consultation with the Corporate Communications Team should take place in advance.

Public Communications

X1F Group employees shall not make any official statements to the public (interviews and other press inquiries) without consulting the respective c ommunications m anagers and refer any journalistic inquiries directly to the Corporate Communications T eam or the corresponding marketing communications managers of the respective subsidiary Otherwise, we welcome public appearances by our employees although the form and ( content of these appearances should be coordinated with the respective communications officer.

Expressing Private Opinions

In social media, X1F Group employees take care not to place their respective function or activit ies in a ny context with a private statement.

 

4. Environmental, Social and Governance (ESG)

4.1 General Equal Treatment

WE TREAT EACH OTHER WITH RESPECT AND TRUST AND DO NOT TOLERATE HARASSMENT OR DISCRIMINATION.

X1F and all its employees are obliged to refrain from any discrimination on the grounds of race, ethnic ity religion ideology, disability, age gender or sexual identity.

Discrimination within the meaning of the above is deemed to exist if it directly or indirectly leads to t he affected person experiencing less favorable treatment than another person in a comparable situation who does not exhibit the discriminatory characteristic. The benchmark for X1F and the employees of the X1F Group is that those affected can feel disadvan taged as a result of the trait or behavior. Ideally, such behavior should already be avoided. We promote a culture of open communication in this regard, encouraging our employees to disclose critical situations and discuss them with all parties involved. We respect the opinions of others their privacy and personal rights. We are committed to treating everyone with respect and dignity regardless of their origin or circumstances.

Discrimination is also deemed to exist if a ny third party is put at a disadvantage on the basis of one of the above mentioned characteristics or an aspect relate d to it. Any form of disparagement or incivility even if it is not directed at the persons concerned, must be avoided In particular, sexual harassment of any third party must be avoided. This includes any behavior that is considered potentially undesirable by those affected. In particular, pictures, texts or any other objective representation of sexual content that are made accessible to any third party even if only visually are prohibited X1F and its employees agree that violations of this Code of Conduct will lead to consequences under employment law for the persons discrimina ting against them.

 

4.2 Human Rights

WE RESPECT HUMAN RIGHTS, PERSONAL RIGHTS AND THE DIGNITY OF OUR EMPLOYEES AND ALL THIRD PARTIES.

We are committed to the princ iples of the United Nations Universal Declaration of Human Rights. We expect our business partners internationally to share these values and to commit to their observance.

Our employees observe human rights as a binding guideline. In their business environment, they are attentive to possible human rights violations and work to prevent draw attention to, or remedy them.

 

4.3 Occupational Health and Safety

THE SAFETY AND HEALTH OF OUR EMPLOYEES ARE ASSETS WORTH PROTECTING.

Occupational health and safety are an integral part of our operations and are incorporated into all technical, economic and social planning.

Our employees are required to promote health and safety in their respective work environments and to comply with occupational health and safety regulations. They avoid risky behavior, recognize dangerous situations in time and intervene appropriately We ensure a healthy and hazard free working environment for our employees by complying with all pertinent o ccupational health and safety laws and regulations It is the responsibility of managers in particular to ensure that appropriate procedures and protective measures are in place to guarantee health and safety in the workplace.

 

4.4 Environmental and Climate Protection

WE COMPLY WITH ALL APPLICABLE ENVIRONMENTAL REGULATIONS AND INTERNAL ENVIRONMENTAL GUIDELINES.

We strive for responsible use and procurement of natural resources ( energy, materials and land) in the manufacture and distribution of our products and services. Ecological sustainability is a steadily growing component of our Group mission statement.

All X1F Group employees and its m anaging d irectors are interested in sustainable environmental protection and try to act in a resource saving and ecologically responsible manner. Therefore, we expect our employees, as well as our suppliers and business partners, to act in the same way as X1F:

  • Con stantly strive to optimiz e and apply improved processes in o perational procedures and technologies used.
  • Observe environmental protection with regard to national legal norms and international standards.
  • Minimize environmental impact s and continuously imp rove environmental protection

X1F’s actions are aligned with the following specific rules:

  • Reusing materials where appropriate
  • Conserving water and energy
  • Reducing waste
  • Utilizing recycling opportunities
  • Purchasing environmentally conscious materials
  • Using public transport where appropriate
  • Providing subsidies for environmentally friendly company vehicles

 

4.5 Fair Working Conditions

We comply with applicable statutory regulations to ensure fair working conditions, including those relating to pay, working hours and privacy protection. This also includes ensuring that we pay the legally defined, national minimum wage.

 

5. Conflict of Interest Avoidance

5.1 Family and other Relationships

X1F GROUP EMPLOYEES SHOULD REMAIN OBJECTIVE UNDER ALL CIRCUMSTANCES AND ENSURE THAT THEIR JUDGMENT IS NOT INFLUENCED BY PERSONAL OR FAMILY INTERESTS.

We are pleased when our employees are our brand ambassadors and promote working for the X1F Group among their friends and family. At the same time, we expect all employees not to exploit their position s or influence to create an unfair advantage for a family member or acquaintance.

If related persons (e. relatives, life partners, close associates) are employed by the X1F Group or one of its subsidiaries conflicts of interest of any kind are to be avoided Therefore, employees who have a personal or family connection to one an other should not work together directly or indirectly in a disciplinary relationship either as a manager or subordinate.

All employees must promptly disclose situations in which personal interests may conflict with the interests of the c ompany and take appropriate action with their manager and/or Human Resources to avoid and/or resolve the conflict of interest.

 

5.2 Secondary Activities

ALL EMPLOYMENT ACTIVITIES REQUIRE DISCLOSURE OR APPROVAL IN ACCORDANCE WITH EMPLOYMENT REGULATIONS.

We welcome employee voluntary activities in associations or other institutions, provided that these activities do not run counter to the interests of X1F, they do not impair the employees’ contractual duties and they do not serve criminal purposes.

Seconda ry activities and ( participations with a company not belonging to X1F or another organization, in particular with a competitor, are to be decided on a case by case basis and must not impair the interests of X1F. As a rule, scattered participations are to be regarded as unproblematic.

 

6. Dealing with Business Partners

WE EXPECT OUR BUSINESS PARTNERS TO SUPPORT OUR RULES AND TO BEHAVE ACCORDINGLY.

We identify potential corruption risks in our dealings with business partners. We ask ourselves the following fundamental questions:

  1. Identity: Who are my business partners?
  2. Quality: Can my business partners deliver what they promise?
  3. Creditworthiness: Are my business partners economically reliable?
  4. Integrity: Can I trust that my business partners will behave lawfully?

To answer these questions, we use secured information from reliable (and legal) sources about any business partners, e.g. from public registers and information services.

Practical Help

Risk Evaluation of Business Partners

Company Organization and Structures

Unclear ownership (beneficial ownership), Non-transparent offshore structures, Untraceable company holdings and/or a New company without a clear financial history.

Company Owners: Management, Shareholders and Insiders

Inconsistent resumes / Conflicts of interest. Classification as or relationships with Politically Exposed Persons (PEPs)[1] or State-Owned Companies (SOC)[2]. Relationships with questionable affiliates, including supply chain providers. Functioning as a middleman/woman, excessive dependence on intermediaries

Reputation of the Company and its Management

Under international sanctions and/or on watch lists, Court proceedings / convictions for corruption, Official investigations / investigations by regulatory authorities for corruption, Media reports detailing involvement in corruption / questionable business practices, Connection to questionable organizations (in the sense of parties under observation or banned, Sects and others)

[1]Politicians or persons in the immediate environment of politicians.

[2]Public company.

6.1 Commissioning of Service Providers External Consultants

WE SELECT SERVICE PROVIDERS AND EXTERNAL CONSULTANTS ACCORDING TO CLEAR CRITERIA.

Consultants commissioned by the X1F Group shall comply with local law and internationally applicable laws. The X1F Group will only pay the fee upon presentation of verifiable proof of performance and a proper invoice. We do not allow cash claims.

For some transactions, especially abroad, intermediaries are needed. We usually use intermediaries because of their loc al knowledge and contacts. The intermediaries must not be employees of the X1F Group or its business partners. Intermediary contracts are recorded in writing and must contain a detailed description of the service provided, which must be for legitimate purp oses.

The agreed payments should be in line with market rates and within the usual range. Commissions or agency fees paid should always be commensurate to the service received. All commissions or agency fees are approved in advance by the respective manager.

 

6.2 Contracts

THE X1F GROUP ENTERS INTO TRANSPARENT AND BINDING CONTRACTS WITH BUSINESS PARTNERS WITH CLEAR RULES.

The respective contract with our business partners obligates them to recognize our rules on corruption prevention as binding. In the event of a violation, sa nctions are generally stipulated in the respective contract.

Even when we enter into a joint venture or take a signi ficant stake, we ensure that our Code of Conduct becomes part of the agreement.

 

6.3 Discounts and Kick Back Payments

DISCOUNTS TO BUSINESS PARTNERS OR AGREEMENTS FOR KICK-BACK PAYMENTS WILL COMPLY WITH APPLICABLE LAW.

The following principles must be followed:

  • The granting requires a written agreement, which is part of a contract. The type of discount (direct deduction from the invoice amount, provision of additional services or delivery of additional products) or the process of a kick back payment shall be indicated in the contract.
  • A discount and the type of discount shall be shown separately on an invoice.
  • A discount or kick back payment may only be paid to the invoice recipients concerned, and under no circumstances to third parties.

 

7. Sponsorships and Donations

DONATIONS AND SPONSORSHIPS ARE MADE ONLY TO ORGANIZATIONS AND MUST BE CONSISTENT WITH OUR CORE VALUES.

The X1F Group supports social organizations through sponsorships and donations. They are important measures for expressing our self image of social responsibility.

Sponso rships and donations are voluntary services that we provide without consideration in the form of cash or in kind contributions to promote a tax advantaged purpose. Donations are made exclusively for charitable purposes and are not intended to benefit any political associations or special interest groups, in order to rule out any su pposition of political influence or advantage taking from the outset.

Sponsor ships and donations may be made in accordance with the internal regulation s applicable for this purpose and must be coordinated in advance with the responsible office in the respective subsidiary. Information about the planned action should be sent to compliance@x1f.one in advance of the donation.

As a general rule:

  • Donations or sponsorships made by the X1F Group may not pursue unfair purposes and must be transparent (including documentation of the identity of the recipient, the purpose of use and the occasion).
  • Payments may not be made to private accounts monetary donations may only be made to organizations as a matter of principle
  • Every donation and sponsorship must be compatible with corporate values.


X1F Group employees who consider a sponsorship or donation worthy of support should contact the respective Corporate Communications team and if applicable, the X1F Group Compliance team which manages the internal approval process. The employees themselves shall check in advance whether the sponsorship or donation serves to promote the company’s objectives and does not pursue any unfair purposes, and provide evidence of this. Furthermore, they ensure that the sponsorship or donation is denominationally and politically neutral, otherwise the donation/sponsorship is subject to approval by the respective management of the individual company an d, if necessary, X1F management and/or the compliance team For clarification of such cases, an inquiry can be made via compliance@x1f.one

 

8. Grants

Any grant s must be based on the respectiv e national law. They must be reasonable and must not expect anything in return.

8.1 Contributions to and from Business Partners

AS A MATTER OF PRINCIPLE, CONTRIBUTIONS MUST NEITHER GIVE THE APPEARANCE OF NOR HAVE THE PURPOSE OF INFLUENCING IN AN IMPROPER MANNER.

When dealing with gratuities, for example in the form of gifts or invitations, we take great care to avoid any appearance of dishonesty or impropriety. We do not tolerate gratuities that raise doubts about our integrity or could be interpreted as influencing business decisions.

Mutual invitations to dinners or in expensive events as part of business activities are tolerated. The exchange of gifts that exceed th is scope or are inappropriate are considered unfair. They ca n damage the reputation of our employees and our group of companies. X1F employees are permitted to accept gifts and other benefits from third parties under the conditions specified in the General Policy on Gifts (see section 9).

Decision Support

Grants

Regarding the admissibility of a grant, ask yourself the following questions:

  1. Could I talk to my colleagues about this allowance with professional certainty?
  2. Would I be under any obligation to the giver if I accepted this allowance?
  3. Is the purpose of the contribution entirely altruistic?
  4. Is the monetary value of this contribution appropriate?
  5. Is this allowance made in a professional context?

If you answer no to any of these questions, then you should refrain from accepting or making an offer. If necessary, seek advice from your manager.

8.2 Grants to Public Officials

Public officials are persons who are actual employees or external consultants in the public sector. Corruption involving public officials is a very serious offense for which X1F employees may be held personally liable. There fore, invitations or gifts to public officials carry a very high risk.

As a general rule, gifts to public officials are prohibited and will not be provided by any X1F employee. Conference documents, appropriate accompanying material and low value promotional gifts <25 for Germany) are generally permissible.

Invitations to public officials should also be avoided. In some cases, an invitation to public officials may be desirable and legally permissible for reasons of courtesy or otherwise. These cases must be clarified in advance with the Compliance Officer and require the explicit approval of management.

9. General Guidelines on Gifts

The following rules apply to both offering and accepting gifts.

  • A gift may not consist of money or a loan.
  • Gifts must be clearly recognizable as gifts (company logo, an enclosed greeting card, etc.).
  • A gift must have a minor value and comply with the currently valid maximum value pursuant to Section 4 ( No. 1 of the German Income Tax Act (EStG).
  • Even low value gifts should not be offered more than 1-2 times per year. In individual cases, it may be necessary to offer gifts with a higher value due to cultural circumstances or for reasons of courtesy. In this case, the exception must be clarified in advance with the appropriate manager and Compliance Officer and requires explicit approval.
  • Offering or accepting a gift is not based on a request. A gift is based on a legitimate business relationship or occasion. A gift does not influence any party in the performance of their duties and should not be construed as influencing.
  • The exchange of gifts must not violate any national law or generally accepted ethical standards.

Practical Cases

Gifts

A supplier gives the purchasing department a bottle of wine for the third time in one year, the value of which is appropriate. Not allowed: Gifts may only be made occasionally and may not become a standard practice.

2. At Christmas, a regular supplier sends you a box of chocolates. Allowed: This gift is usually of negligible value (please note maximum value) and selective. It will not affect the business relationship with the supplier.

3. We would like to please a very important customer. We give him a gift card for an online merchant so that he can buy something for himself. Not allowed: Gift cards are generally not allowed because they are considered cash

4. The Managing Director of a company with which X1F has a business relationship is to be presented with a bouquet of flowers on the occasion of his/her 25th anniversary.

Allowed: This is an occasion-related gift and is not done in expectation of gaining influence.

10. General Policy for Business Invitations

BUSINESS INVITATIONS MUST SERVE A PURELY BUSINESS PURPOSE. THE FINANCIAL FRAMEWORK MUST BE KEPT WITHIN LIMITS.

The following rules apply to both offering and accepting invitations.

  • Offering or accepting an invitation to a meal or event may not be done on the basis of a request.
  • A meal or event must be based on a legitimate business relationship or activity (e.g., project celebrations).
  • Invitations from ( business partners are permitted if they serve to establish or maintain business relationships.
  • A meal or event shall not influence either party in the performance of their duties and shall not be construed as influencing either party.
  • The invitation of spouses or friends of business partners is generally not permitted unless it is justified by business reasons (e.g., the spouses are both business partners) If an exception t o this rule is necessary in individual cases, this must be clarified in advance with the Compliance Officer and requires the explicit approval of management.
  • Tickets for events (sports, leisure or entertainment) may only be offered to a business partner: in justified cases and after prior consultation with the Compliance Officer and approval by management.
  • At the same time, the participation of an X1F employee is mandatory for such invitations.
  • Acceptance of a ticket for a gala evening or a sporting event without accompanying the host is only permitted if this does not exceed a value of 50, EURO. If this has a higher value, but there are good reasons for accepting the ticket anyway, this must be agreed upon in advance with the appropriate manager and approved by the com pliance officer(s).
  • Inviting one an other to meals or events must not violate any national law or generally accepted ethical standards.

All exceptions requiring approval must be documented.

Practical Cases

Invitations

1. During a conversation with an important potential customer at a trade fair, the customer tells you that she/he is a tennis fan. Based on this information, you would like to send her/him tickets to attend a match of the German Open together, in order to talk about the conditions under which you could work together. Not allowed: This invitation is made at a STRATEGIC TIME of negotiation and has the purpose of influencing the customer’s decision.

2. After long negotiations we have signed a contract with a customer. To celebrate the business relationship, you would like to invite him/her to a restaurant. Allowed: You may invite this customer if the meal is for a reasonable amount (Michelin restaurant would be inappropriate), as this invitation is in a professional context and after the conclusion of the contract.

10.1. Special Forms of Customer PR Info Events

Customer Public Relations or Information events at which we would like to inform business partners about our products and /or recent developments are permitted, provided that the following conditions are met:

  • Both the location of the event a nd the program are to be selected solely on the basis of business judgment criteria.
  • The supporting program must not take up more time and economic effort than the entrepreneurial part of the event.
  • Travel, accommodation and inciden tal expenses for the participants will not be covered.

11. Data Protection and Trade Secrets

11.1 Handling Information

WE PROTECT CONFIDENTIAL INFORMATION AND PERSONAL DATA FROM UNAUTHORIZED USE, DISCLOSURE AND ABUSE.

The protect ion of personal data is of particular importance to the X1F Group. We only collect, process, use and store personal data in accordance with legal requirements and, where applicable, on be half of our customers. We are committed to the principles of economical storage of personal data and to transparency in data processing. With this commitment, we ensure a uniform and appropriate level of data protection throughout the company. Employees who handle personal data will receive advice and support from the company Data Protection Officer.

The respective subsidiaries of the X1F Group commit their employees to the respective IT security protocols password guide lines and other requirements that are necessary in the respective business environment.

Discussing confidential information in public or unauthorized disclosure of information about our group of companies, individual participating companies or employees as well as our customers to third parties constitutes a breach of confidentiality obligations and is not permitted. This also applies to the disclosure of corresponding information via social media.

Employees who have access to particularly confidential information (e.g., in the areas of finance, human resources, contracts, corpo rate transactions, etc.) are required to maintain strict confidentiality, internally and externally.

12. Organizational Measures

12.1 Multi-Eye Principle

In terms of appropriate preventive measures, it is important to X1F to apply the multiple eye principle (participation or co inspection by several employees or organizational units) in all process steps that require special oversight and to create the greatest possible transparency in all sensitive decision making processes.

The application of the multiple-eyes principle is determined by the respective subsidiaries. Among other things, it can be ensured through regulations on signing (clear representation and s ignature regulations) particularly in the areas of finance, contracting, labor law and purchasing.

12.2 Transparency and Complete Documentation

We ensure transparency about our business processes, decisions and actions through written documentation and regular controls.

We ensure that both internal and external data collection, records and reports are truthfully documented, correct and complete. We expect X1F Group employees to exercise a high degree of care in all processes and to comply with applicable standards, in particular the principles of proper bookkeeping and accounting.

12.3 Control Mechanisms

Appropriate control mechanisms shall be implemented in all areas of work that are susceptible to corruption. These mechanisms include:

  • Intensive regular control of business processes and resubmissions.
  • Regular reviews of existing decision making scopes by the individual companies
  • If necessary, using subcontractor, intermediaries and service provider questionnaires.
  • Accurate and complete document ation of work processes with routine and sufficient reporting requirements.
  • Underwriting reservations (e.g., for approvals above certain value limits).

The individual companies themselves determine the measures suitable for their specific organizations.

13. Dealing with Violations

13.1 Compliance Department and Officers

The X1F Group Compliance Department includes an assigned Compliance Officer and consists of the CISO, Data Protection Officer and HR reporting directly to the Executive Board. The Compliance Team and the Compliance Officer are available to employees, business partners and third parties to advise them on relevant issues arising from this Code of Conduct. The Compliance Officer and the internal specialist units must maintain absolute confidentiality with regard to third parties who are not involved in the procedure. Their tasks include acting as the primary contact person and advisor for employees and management, raising awareness among staff, participating in training and continuing education, observing and evaluating signs of corruption, recommending external audit s if necessary, and controlling (accompanying audit of processes).

Contact: compliance@x1f.one

13.2 Whistleblower System

THE MANAGEMENT OR THE COMPLIANCE TEAM FOLLOWS UP ON ALL RELEVANT INFORMATION, CHECKS IT, REPORTS IT TO LAW ENFORCEMENT AUTHORITIES IF NECESSARY, AND ENACTS INTERNAL CONSEQUENCES.

X1F Group employees should be able to report incidents without fear of retaliation or consequences. Employees who comply with their duty to inform must not suffer any disadvantage as a result We will ensure that such reports are treated confidentially upon request.

On the other hand, it is also important to X1F to protect our employees from unfounded allegations Deliberately false or grossly negligent assertions will be investigated and may result in consequences under labor law.

Information is sent by e mail (compliance@x1f.one) directly to the compliance officer. This office, which is bound to secrecy, examines information about the suspected corruption and, with the consent of the whistleblower, passes the information on to the responsible bodies with in the company or management.

13.3 Sanctions

VIOLATIONS OF THE CODE OF CONDUCT WILL NOT BE TOLERATED AT X1F AND WILL RESULT IN DISCIPLINARY OR EMPLOYMENT ACTION FOR EACH INDIVIDUAL EMPLOYEE.

Employees and persons acting on behalf of X1F and its subsidiaries who attempt to influence business partners or public officials through corrupt behavior or who allow themselves to be influenced in an unfair manner by business partners or public officials will be held accountable in an appropriate manner, irrespective of any possible consequences under criminal law.

14. Internal Contacts

Management COO:
Sven Geilich (sven.geilich@x1f.one)

The Compliance Team consists of the following officers:

Compliance and Data Protection Officer: Sebastian Raguse
CISO: Mario Hackel
Director People & Culture: Sabrina Fulle
Represented by: Tamara Zimmer (Director HR Services)

compliance@x1f.one

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