A. Preamble

To maintain our independence and to live up to our corporate responsibility, we have established this Code of Conduct. The CITO Code of Conduct is a voluntary commitment by all employees to act correctly and responsibly in their everyday professional lives. We want to be a transparent, responsible and ethically correct partner for our business partners, for which this Code provides us with a corresponding framework for action.

B. Scope of application

The Code of Conduct applies to all companies of the CITO Group in Germany and abroad (CITO for short) as well as to all employees, regardless of function or hierarchy.

To the extent that national law provides for stricter rules in individual cases than those laid down here, national law takes precedence. Managers have a special role model function regarding compliance with the Code of Conduct.

1. Compliance with the law

We are committed to complying with all laws and regulations relevant to us, both national and European Union (EU), as well as conventions of the International Labour Organization (ILO) and the United Nations (UN). If similar facts are regulated, the respective regulation that sets the strictest requirements applies. The following principles must be observed by our employees and must not be circumvented by other agreements.

2. Corruption and bribery

When dealing with customers, suppliers and service providers as well as government institutions, the interests of the CITO Group and the private interests of CITO employees on both sides must be strictly separated. Actions and decisions are always free of irrelevant considerations and personal interests, i.e. personal benefits of monetary value in return for preferential treatment in business transactions may not be accepted.

On the other hand, our employees undertake not to offer or solicit any gifts, payments, services or invitations that could improperly affect a business relationship.

3. Export trade regulations, conflict minerals

CITO does not supply products or services, either directly or indirectly, to countries that are subject to international trade sanctions. For products that may have a so-called "dual-use", we obtain the necessary export licenses.

CITO or our sales partners regularly carry out background checks on actual and potential customers against the applicable sanctions lists (at least UN, EU, USA and the respective exporting country), whereby our sales partners comply with rules at least equivalent to those of these.

Our products do not contain conflict minerals (e.g. tin, tungsten, tantalum, gold).

4. Accounting

The use of funds within CITO is only permissible if the respective transactions are properly accounted for. Payment applications and payments may only be made in the interest of the company. There must be a match with the relevant accounting documents.

5. Competition law

We rely on fair competition with market competitors. We expect our employees and people commissioned by CITO to comply with all applicable domestic EU and foreign antitrust laws. Agreements that influence prices or conditions or other measures that impermissibly hinder free competition are prohibited.

6. Data protection

We are committed to confidential and transparent communication. We are committed to protecting trade and business secrets. Confidential information may not be passed on to third parties without authorization, stored on external data carriers or forwarded to private e‑mail accounts, unless explicit permission has been granted. Confidential information is only to be disclosed externally if this is done based on legal regulations or by court order. Even after the termination of an employment relationship, the obligation of confidentiality continues to exist.

7. Occupational health and safety

We take all necessary measures to avoid accidents and health hazards related to the work of our employees. We are committed to continuously improving the working environment. We expect our employees to take personal responsibility for maintaining their health and support them in maintaining or developing a health-promoting lifestyle. Against this background, the consumption of alcohol, drugs or other intoxicants during working hours is prohibited.

8. Working hours

We are committed to complying with the respective legal regulations as well as the company standards on working hours and public holidays.

9. Remuneration

At CITO, remuneration is based on statutory and operational standards. Employees are informed clearly and regularly about the composition of their remuneration.

10. Workers’ rights

We respect the freedom of organization and assembly of our employees. We assure that employees who engage in this form do not have to reckon with negative consequences.

11. Work of children and young people

CITO is committed to ensuring that the rights of young people are respected. CITO will not tolerate any exploitation of children and young people. Child labour within the meaning of the ILO conventions and the United Nations as well as national regulations is prohibited. The age limit for authorized employment is not less than the compulsory school age and in no case is less than 15 years. Young people must not be exposed to dangerous, unsafe or harmful situations.

12. Forced labor

CITO rejects any form of forced labour. In accordance with ILO conventions, all forms of forced labour and work that violates human rights are prohibited.

13. Employee development

In accordance with our management philosophy, we live the values of willingness to develop, performance orientation and appreciation. We promote the personal development of the individual. To this end, we implement appropriate personnel development and further training programs and enable employees to identify with the company. On the other hand, we expect our employees to be open and willing to take personal responsibility and develop further.

14. Equal opportunities

CITO stands for fair and respectful dealings with each other. Any form of bullying as well as verbal, physical and/or sexual coercion and/or harassment will not be tolerated. In addition, we are committed to combating any discrimination that must be avoided in employment and employment. A distinction according to

  • Ethnic, national and social origin
  • Breed
  • Skin color
  • Gender
  • Age
  • Nationality
  • Religious affiliation
  • Political opinion
  • Physical or mental disability
  • Sexual orientation

or other personal characteristics are prohibited.

15. Environmental protection

We are committed to complying with applicable laws and minimum requirements for climate and environmental protection. Our employees handle resources carefully. For us, environmentally conscious behavior means:

  • Efficient use of resources (energy, water, raw materials, air)
  • Use of environmentally friendly materials
  • No use of illegal materials (e.g. illegally acquired wood)
  • Avoidance of emissions and waste
  • Development of management systems to conserve resources

16. Communication

This Code of Conduct is accessible to all CITO employees and is made available in the respective national languages. It can also be viewed on the Internet under www.cito.de.

C. Complaints procedure

We expect all employees to act responsibly in accordance with this Code of Conduct. In the event of a reasonable suspicion of a violation of the Code of Conduct, the employee is free to contact the management or the elected employee representatives. Employees who report the suspicion of misconduct in good faith do not have to fear any negative consequences. However, the complaints procedure must not be used to deliberately disseminate false information or information. The reporting of any violations is done in anonymity.

D. Sanctions

Depending on the severity of the violation, CITO reserves the right to initiate disciplinary and/or legal measures.

CITO carries out a check against sanction lists before every new customer and supplier investment. This check is intended to prevent inadmissible transactions with new customers and suppliers.

The following countries are subject to special measures (from restricted trade transactions to a trade ban):

  • Venezuela, Yemen, Russia, Belarus, Iran, North Korea, Cuba, Syria, Ukrainian territories under Russian military control – Crimea, Sevastopol, Donbas, Donetsk, Luhansk, Zaprozhya, Kherson

Schwaig, January 2026