CODE OF CONDUCT

CODE OF CONDUCT FOR BUSINESS

ANT Applied New Technologies AG.

Dear employees of the ANT Group!

The ANT group of companies is a leading company in the field of water abrasive suspension (WAS) cutting technology and the related special machine construction.

The success of the ANT group of companies is based on quality, innovation and service, which prevails in fair competition. The ANT group of companies is committed to the basic values of integrity, transparency and responsibility in business transactions and therefore wants to ensure compliance with all applicable legal regulations. The reputation of our company and the trust of our customers and suppliers, and thus also the existence of our company, depend decisively on the conduct of each individual employee.

The principles contained in the behavioral guidelines of this “Code of Conduct” are minimum standards that are binding for every employee, representative and partner of the ANT group of companies. Compliance with laws and internal regulations is a matter of course for us. In this way we contribute to the long-term safeguarding and strengthening of the competitiveness and successful positioning of the ANT group of companies. Compliance violations, i.e. violations of laws or internal regulations, can lead to considerable costs and a threat to the existence of our company.

The Executive Board of the ANT G rou p expects every em ployee to act in accorda nce with the law. This Code of Conduct provides a framework for this, but by its nature cannot cover all laws and regulations and is therefore never complete. lf you have any questions or comments, please contact your supervisor, one of the members of the Management Board or the Compliance Officer.

I. Compliance with the Code of Conduct

This Code of Conduct of the ANT Group of Companies (hereinafter also referred to as the “ANT Group”) contains important behavioral guidelines (see II.) which must be observed by every employee.

Part of the responsibility of each manager of the ANT Group is to ensure that the emÂployees assigned to him or her are aware of the Code of Conduct and comply with the behavioral guidelines contained therein.

lf there is any uncertainty about correct behavior or other questions, the respective supervisor, the Compliance Officer or the Executive Board should be contacted.

Of course, each individual employee of the ANT Group is responsible for his or her own actions. This also applies if the respective superior has given his approval.

The Executive Board and all managers of the ANT Group pay attention to compliance with this Code of Conduct and will pursue violations. Violations of the Code of Conduct will not be tolerated and may lead to consequences for the employment relationship and to claims for damages.

II. Code of Conduct

1. Responsibility and objectives

The ANT Group, as a leading company in the field of Water Abrasive Suspension (WAS) cutting technology and the related special machine construction, strives to meet the highest requirements for the products it manufactures and the services it provides. Our goal is to ensure the trust and satisfaction of our customers. Compliance with the applicable legal regulations is a matter of course for us.

Every employee of the ANT Group is obliged to comply with existing contracts and to avoid behavior that could be interpreted as disregarding legal regulations.
The reputation of our company is essentially shaped by the appearance, actions and behavior of each individual employee.
By acting in a responsible, sustainable and environmentally conscious manner, each employee must protect the reputation of the ANT Group and safeguard the company’s public image from damage.

2. Working environment

The ANT Group treats its employees fairly and openly, with understanding and tolerance.

The ANT Group expects all employees to be objective, friendly and fair in their dealings with colleagues, business partners and third parties
No employee may be harassed, discriminated against or disadvantaged without objective reason because of his or her race, nationality, descent, gender, faith or ideology, political views, age, disability or sexual orientation.
Mutual respect is based on inner conviction and willingness to act. This also means that problems in the workplace are addressed and solutions to problems are sought together.

The ANT Group complies with the applicable work, accident prevention and health regulations and ensures a safe and healthy working environment in order to maintain the health of its employees and to prevent accidents, injuries and work-related illnesses. For the ANT Group, occupational health and safety is the basis of successful business activity.

3. Fair competition

The ANT Group supports fair competition and the free development of all market participants.

Every employee must therefore observe the principles of fair and open competition.
Agreements of any kind with competitors on prices, terms and conditions, market sharing and non-competition are to be refrained from.
The principles of fair and open competition must also be observed vis-á-vis our customers and suppliers and, for example, no specifications of sales prices must be made. This includes not only written agreements, but also informal discussions and informal agreements (“gentlemen’s agreements”) which have the purpose or effect of restricting competition.
The only exception is if individual measures have previously been examined for their compatibility with the applicable antitrust regulations.

4. Prevention of corruption

The ANT Group faces competition with products and services at reasonable prices. The improper influencing or distortion of competition by granting personal advantages is prohibited. The ANT Group prohibits all employees from participating in or tolerating corruption. The ANT Group expects the same from all business partners.

Therefore, the principle applies that employees of the ANT Group may only grant advantages, such as gifts, meal invitations or other benefits, to customers, suppliers and other business partners for themselves or third parties in exceptional cases.
The same applies to the acceptance of such benefits by employees of the ANT Group. No employee may use his or her official position to demand, accept, proeure or be promised advantages for himself or herself or third parties.
Offering and accepting cash gifts are prohibited.
The granting and acceptance of reasonable advantages (e.g. invitations to restaurants or events or gifts) are permissible by way of exception if the gift or acceptance of a gift does not create the appearance of corrupt behavior. The benefit must be within the scope of generally accepted business practices and must not be unreasonable.
Employees are allowed to give gifts worth a total of €35 to a business partner in a year. Gifts up to this value may be claimed as business expenses (Section 4 (5) EStG). At the same time, employees may only accept gifts worth up to €35 per year from a business partner. In addition, promotional items (calendars, pens, tags, etc.) may be distributed up to a value of €10 per person per year.
The acceptance and issuance of invitations to business meals are permissible within reasonable limits.
In any case, care must be taken that the donor and the recipient do not conceal the gifts and that the recipient is not forced into an obligatory dependency.
lf invitations and gifts exceed the limits described above, the approval of a member of the Board of Management must be obtained. Prior approval must also be obtained from the Executive Board for an invitation to a business-related recreaÂtional event (such as sports or cultural events).
Oftering or granting gifts, invitations or other benefits to public officials is generally prohibited.

lf you have any questions, please contact one of the Executive Board members or the Compliance Officer.

5. Avoidance of conflicts of interest

The ANT Group expects its employees to be loyal to the company. All employees are obliged to avoid any activity inside or outside the company which leads or can lead to a conflict of personal interests with the interests of the ANT Group.

In particular, the operation of a company or
Secondary employment for a company that competes with or has a business relationship with the ANT Group, as weil as
A substantial participation in such a company. This does not apply to such shareholdings which demonstrably cannot have any influence on the activities at the ANT Group.
In addition, orders to related persons (e.g. spouses and relatives) are generally not permitted,
Orders to companies in which related persons work, and
Orders to companies in which related persons hold an interest of 5% or more.

All employees are required to report any conflicts of interest or potential conflicts of interest described above to the Executive Board. In exceptional cases, the full Executive Board may approve a transaction after weighing up all interests if there is no reason to fear that the interests of the company will be impaired.

Business matters should never be influenced by personal interests or considerations. No employee may use his or her position or ANT Group property for personal gain or other enrichment. lf an employee sees a possible conflict of interest with regard to his or her professional activities, the facts must be reported immediately to the Executive Board.

6. Property

Every employee is obligated to handle company property responsibly and to protect it. Company equipment or objects may not be used for private purposes or removed from the company’s premises without the express consent of the responsible department.

7. Donations

Donations of up to €1,000 per year may only be made with the prior written approval of a member of the Board of Directors. Donations over € 1,000 per year require the approval of the entire board.

8. Data protection, confidentiality and protection of third-party rights

Every employee who comes into contact with personal data is obliged to comply with the data protection requirements of the General Data Protection Regulation (“GDPR”), in particular to maintain the confidentiality of the data.

Personal data of employees, customers and third parties may not be collected, processed or used without authorization, i.e. without their consent or without legal permission or legal obligation.

Violations of data protection regulations can be punished by fines or imprisonment. At the same time, it is possible that such a violation may give rise to claims for compensation for material or im material damage on the part of those affected. Furthermore, such a violation may at the same time constitute a breach of your employment contractjservice agreement obligations.

Confidential information and business secrets as weil as business documents (including e-mails) are the property of the ANT Group and must be properly preserved and secured. They may only be disclosed to the public by employees expressly authorized to do so and must be protected from unauthorized access by third parties and other employees.

Every employee must respect the effective property rights of third parties (such as patents, copyrights and trademarks). Any unauthorized use must be avoided. No employee may obtain or use secrets of a third party without authorization.

9. Financial integrity

All financial records that the ANT Group prepares, publishes and, in particular, makes available to the competent authorities, shareholders and creditors, must be complete within the meaning of the applicable accounting principles. All financial records must be prepared accurately and in a timely manner by employees, in accordance with their duties and responsibilities, as required by applicable law.

10. Binding nature and reporting obligations

The ANT Group expects its employees to comply with this Code of Conduct. Violations of the Code of Conduct may result in disciplinary action in accordance with applicable labor laws.

Employees must:

Familiarize themselves in detail with the rules and policies related to their own position;
Conduct themselves in accordance with the rules in this Code of Conduct;
Assist employees who report violations of this Code of Conduct;
Cooperate fully with investigations of violations of this Code of Conduct.

In addition, employees shall make suggestions for improvements in the application of this Code of Conduct where its implementation encounters difficulties in practice. Any violations of this Code of Conduct shall be reported to the respective supervisor. lnstead of contacting their supervisor, employees may also contact a member of the Board of Management or the Compliance Officer at any time. Employees who serve as supervisors have a particular responsibility to support this Code of Conduct.

Employees who need assistance or are uncertain about the application or interpretation of this Code of Conduct, its underlying general principles or a specific legal provision should speak to their respective supervisor. lnstead of the supervisor, a member of the Management Board or the Compliance Officer may also be contacted.