Code of Conduct

Principles

Integrity and credibility

Our code of conduct is based on internationally recognised standards for sustainable and economically sound business practice. As part of our internal risk management and by publishing this code of conduct, the management commits itself — as do employees at every level of the company — to the general principles of action and conduct set out below, in order to ensure compliance across all our activities.

Consistent application is ensured through the assigned responsibility and authority to issue guidelines held by the managing directors and the employed department heads. The requirements set out below therefore serve as a guideline for all employees and are to be observed throughout. By communicating this guideline to our business partners, we work towards implementing this code of conduct in our supply chain as well.

Scope

This code of conduct applies to the entire business of IoT Invent GmbH. We undertake to promote compliance with the content of this code of conduct among our suppliers and along the wider value chain as well, within our respective means and spheres of influence.

Compliance with the law

All applicable laws and regulations, and all other relevant statutory provisions of the legal systems applicable in each case at national and international level, are to be observed.

Conduct towards competitors, business partners and third parties

Competition and antitrust law

We compete fairly and observe the applicable antitrust laws. We avoid conflicts of interest with regard to upholding the prevailing standards of fair business practice and fair advertising, as well as the equal treatment of all subcontractors. Statutory obligations relating to the prevention of money laundering are complied with.

Combating corruption

We reject all forms of corruption and bribery. In the spirit of the guidelines of Transparency International and the OECD, we promote acting with integrity, transparency and responsible management within the company.

Trade sanctions and export control

The company undertakes to comply with the economic sanctions laws and regulations of the United Nations and the European Union, and with national legislation on economic sanctions and embargoes.

Handling of information

Data protection

In addition to the general confidentiality requirements, the company is committed to handling personal data responsibly and confidentially in accordance with the GDPR.

Intellectual property and confidential information

The company’s employees are obliged to respect and acknowledge the agreements governing the treatment of confidential information and intellectual property. The same may be required of suppliers and contractors where necessary.

Products, as well as ideas for and improvements to products developed within the company, remain its property.

We thereby ensure that no contractor makes use of plagiarism and that no conflicts of interest arise. Where employees, suppliers and contractual partners have access to confidential information or intellectual property belonging to our company, they are obliged to protect it and to treat it confidentially.

Financial responsibility and disclosure of information

The business dealings and transactions carried out by our company are documented in accordance with the applicable standards, laws and internal procedures. All accounts and records must accurately reflect the transactions and events concerned and comply with generally accepted accounting principles.

Principles of social and environmental responsibility

Social responsibility

Social responsibility is an indispensable part of value-driven corporate management and a key factor in sustainable business success.

Human rights

Our company respects and supports internationally recognised human rights.

Prohibition of child and forced labour

The prohibitions of child labour are observed in accordance with the conventions of the ILO and the United Nations.

Non-discrimination and equal opportunity

We do not tolerate discrimination against employees on the grounds of skin colour, ethnic origin, gender, age, nationality, social background, disability, sexual orientation, religious affiliation or beliefs. At the same time, we promote equal opportunity for all employees in recruitment, remuneration, access to training and further education, and promotion.

Environmental protection

Sustainable environmental and climate protection and the efficient use of resources are important corporate goals for us. All national environmental protection requirements are to be observed. Our aim is to minimise pollution and the consumption of natural resources and to improve energy efficiency overall. All employees, as well as suppliers and service providers commissioned by us, are required to work in an energy-efficient manner and to avoid unnecessary consumption of resources — at our sites and at our customers’ premises alike.

Consumer interests

Where consumer interests are affected, the company complies with the provisions on consumer protection.

Community involvement

The company contributes to the social and economic development of the country and the region in which it operates.

Whistleblowing and protection against retaliation

If employees are confronted with an ethical problem, they must inform their direct or indirect superior, or the management, accordingly. In doing so, they allow their superior sufficient time to give advice or take appropriate measures on the matter. It is part of the responsibility of our company’s superiors and managers to help employees who find themselves in difficult situations to find a solution. In case of doubt, the human resources department or an external adviser should be consulted. Employees who report a breach of the rules of this code of ethics in good faith and without self-interest need not expect any sanctions.

Compliance with the code of conduct

Our company makes every appropriate and reasonable effort to implement and apply the principles and values described in this code of conduct on an ongoing basis. The company familiarises its employees with the content set out in this code of conduct and explains the resulting obligations. The company communicates the principles of the code of conduct to its business partners.

Ismaning, 1 July 2026

Martin Dobler & Dimitri Rzhavin, Managing Directors