Compliance – Guidelines

„Only a workforce in which everyone is aware of their responsibility to the whole, can make a significant contribution to the company’s success“

Definition and scope
The term compliance stands for compliance with legal requirements, regulatory standards and the fulfillment of further, essential and generally by the company itself set ethical standards and requirements. This mix of governmental laws and regulations, as well as corporate values are the principles, that can be used to regulate which operations in a company are compliant and which are illegal. However a compliance regulation covers not only the company as a legal entity but also every employee and business partner. Accordingly all company divisions are required to keep the following points and to regularly check these also with business partners.

Principles
CAT Clean Air Technology GmbH has developed into one of the leading companies in clean room technology in Germany and supplies Germany and neighboring European countries with its services and products. Similarly services and deliveries were provided to the USA, Canada, Russia, Japan and Switzerland. Due to our market position we see it as our duty to respect and to follow up the general legal system and the ethnic values on which our society is based. There are described in more detail below. Accordingly we reject any kind of human rights violations and also require this from our business partners. In particular all types of discrimination within the company are not accepted. This includes among other discriminations based on origin, religion, gender and also sexual orientation. Each individual case is strongly condemned, not tolerated and leads to consequences under employment law. Detected violations must be reported to the supervisor immediately.

Forced and child labour
Our company is active in a sector, that also purchases goods from third countries. We see ourselves obliged to the abolition of child and forced labour, which is still part of everyday life in many countries. We can only achieve this, if our business partners, explicitly our suppliers pay attention to the origins of their goods and they rule this misconduct out. The relevant suppliers must confirm this and comply with these principles in all cases. Of course we also require our employees to identify with this principle, as any other opinion would not be compatible with the company ideals.

Employment protection
To protect our employees, we provide them with the necessary personal protective equipment, such as work clothing. Ladders, equipment and workplaces are checked at regular intervals. Accordingly all our employees are required to immediately report any potential risks to their superiors and to avoid them as long as they exist. Following this, a risk elimination and troubleshooting is carried out as quickly as possible in order to avoid a renewed danger. Furthermore we are in health and safety support by the responsible professional association.

Corruption, bribery or extortion
In Germany we find a free market economy, that promotes equal opportunities and freedom of competition. Of course we are also dependent on these principles, which are offered to us by the German state / the European Union. Significantly, the implementation and strict adherence to these existing principles are required to acquire customers and to be able to supply them on a long-term basis. Consequently we adhere to the legal framework and do not allow corruption, bribery or extortion, either internal or external. We stand for free competition, wanting to receive it from our potential customers and also to offer it to our suppliers. However the threshold between small gifts and corruption or bribery is often fluid, it is important to be extremely sensitiv and comprehensible in this area. In general each case should be individually illuminated and evaluated.
Various points can be given as general orientations:

• No gift or donation should result in a perceived personal commitment.
• Cash gifts are to be rejected, gifts to officials in any respect are also prohibited.
• Gifts, that we send to our business partners are within a taxable legal framework.
• In case of doubt, a vote can always be made with the supervisor or the managing director.

Competition-suitable maintenance
It is in line with the business policy of CAT Clean Air Technology GmbH and its affiliates to promote fair competition. Participation in an anticompetitive agreement, whether in the interest of CAT Clean Air Technology GmbH, an affiliate or a competitor is strictly prohibited. In this context the parallel participation of the company in a tendering procedure as a single bidder and at the same time as a member of a bidding consortium constitutes an agreement restricting competition if the advertised services are the same. Infringements are punishable by penalties or fines and may result in the nullity of the relevant agreement.

Horizontal competition agreements
It prohibits, in particular, agreements and concerted practices between competitors (‘horizontal’ agreements) which have as their object or effect the prevention or restriction of competition. These include, for example, agreements on prices, offers, customer allotment, conditions of sale, production or sales quotas, or the division of geographic markets. The prohibition includes not only agreements, i.e. express agreements, but also voting as a result of unilateral declarations (e.g. price increase announcements with the intention of obtaining similar reactions from the competition). In case of contacts with competitors care must be taken to ensure, that no information is received or given, which allows conclusions to be drawn as to the present or future market behaviour of the information provider.

Vertical competition agreements
Also many vertical restraints of competition, i.e. agreements and understandings between suppliers and customers or patent holders and licensees are prohibited in Germany, the EU and the USA with minor differences. These include restrictions on the customer’s freedom to set prices or to supply goods with his business partners (geographical, personal or material restrictions), certain most-favoured-nation clauses, exclusivity obligations such as total coverage or exclusive supplies, and non-compete obligations. In many cases the admissibility and thus the effectiveness of the binding depends on its duration and intensity as well as on the market position of the parties involved.

Abuse of a dominant position
A dominant position does not exist due to our market share in the markets in which we operate. Nevertheless the consequences of the abuse of a dominant position should also be pointed out: In principle the abuse of a dominant position in Germany, the EU and the USA – with minor differences in each case – is not permitted. Such abuse may, for example, be the result of different treatment of customers without objective justification (non-discrimination), refusal to supply, selective distribution, enforcement of inappropriate purchase prices and conditions or coupling companies without objective justification for the additional service required. The determination of a dominant position of a company is as dependent on the individual case as the limits of a still permissible behavior. In cases of doubt in the area of ​​competition law, contact should be made with the management at an early stage.

Data protection
All employees are obliged to actively take appropriate security precautions (passwords, approved technologies and licensed software) to ensure the protection of intellectual property and personal data. Each employee is clearly explained at the beginning of the employment relationship and enshrined in the later employment contract, that all internal information is subject to urgent secrecy. Any even partial transfers to third parties are only permitted after approval and release of the management. All violations are the procedure clean Desktop is implemented. It is regulated there, that all visible documents are at least turn around even if only temporarily leaving the workplace and the desktop is switched in a password-protected economy mode. All employees are instructed to clear away all their papers after work. An access control is implemented for both external and internal persons. In the operating rooms of CAT Clean Air Technology GmbH there is a strict ban on photography. Personal data are only collected, processed or used if this is legally permitted or if the person concerned agrees. We are committed to the principles of saving personal data and transparency of data processing. The right of access, correction and, where appropriate, opposition, blocking and deletion of personal data is of course implemented. In case of doubt the data protection coordinator of CAT Clean Air Technology GmbH, Mr. Dirk Hellenbrandt is always available for further questions. The e-mail address: datenschutz@catgmbh.de can be also used. With this claim we ensure a high level of data protection.

Product quality, service quality and planning quality
When placing an order our customers rely on the quality, that we have symbolized on the market for years. It is therefore natural for us to set and maintain high quality standards within the company. An annual audit of our certification according to DIN EN ISO 9001 takes place for the certified company divisions. According to these audits, we meet the requirements for quality management to an increased extent. We also comply with the special customer requirements arising from our activities within the legal framework. In addition we see ourselves permanently tied to an improvement process, as standstill means a step backwards for us. Accordingly we work permanently with our quality management department on product and process optimization as well as on our range of services. The main components of these optimization processes are above all, our employees, who are responsible for complying with our quality criteria. Any violations or problems that could lead to non-compliance are to be reported immediately to the direct supervisor or quality management officer.

Environmental awareness
Our daily aspirations and actions are designed to preserve our environment and minimize its impact on it through ongoing process improvements. In addition to our own claim to be as environmentally friendly as possible, as well as to transport, we also plan on our internal processes, environmentally friendly and energy-savings projects.