Code of Conduct

This Code of Conduct is the moral basis upon which PSI Software AG (PSI) will conduct its business. It is PSI’s policy to comply with all applicable laws and to maintain fair, impartial and ethical relationships with all of its customers, shareholders, employees, partners and competitors. All employees of the PSI Software AG group of companies are expected to behave according to this standard. More specific guidelines for employees are specified in the Company Handbook.

Innovation and Customer Orientation

PSI maintains long-term customer relationships which are distinguished by frank and close cooperation. Through the provision of first-class innovative products and services PSI helps its customers to establish long lasting competitive advantage in their business areas. Through continual research and development PSI, in conjunction with its leading customers, has positioned itself as a technology market leader. PSI’s solutions enable its customers to utilise labour, energy and natural resources in an economical, socially responsible and environmentally friendly manner.

Sustainable Shareholder Value

PSI uses investment capital to increase the company’s value in a sustainable manner. Shareholders are frankly and impartially informed about results and expectations and operating results and risks are regularly scrutinised by an independent certified auditor. Every employee is instructed in writing about the need to adhere to laws regarding insider trading.

Employee Responsibility

The excellent technical and people skills of PSI employees are continuously improved by training and the organisational structure and working environment are designed to encourage performance, creativity and engagement. In all countries in which the company is active the laws governing fair working practices are observed. It is a characteristic of PSI that many managers and employees hold shares in the company and therefore have an interest in the overall success of the enterprise. However all employees are aware of the need to avoid conflicts of interest between company and personal matters. Managers have a responsibility to ensure that their own personal behaviour, and that of their reporting employees, fully complies with applicable laws and this Code of Conduct.

Strategic Partners

The global interests of PSI’s customers are supported by the company’s international presence in addition to support provided by local partners. All partners (with whom PSI seeks to establish true partnership based upon shared success) are required to comply with the company’s standards of quality and performance; to comply with all applicable local laws and fair working practices for employees; to protect natural resources; to conduct fair trade; and to protect intellectual property rights.

Ethical Trading Practices

Employees are strictly forbidden to ask for, accept or offer inappropriate inducements when dealing with public servants or others with whom there is an established or prospective business relationship. Inappropriate means, in this context, that a third party may conclude that a trade has been unfairly influenced, that the standards of hospitality were exceeded or that an existing law has been violated.

Protection of Confidential Information

Confidential data which is entrusted to PSI will be treated as confidential and protected against disclosure to third parties. PSI will defend its own Intellectual Property Rights whilst also respecting the IPRs of other parties. All PSI employees are bound to treat trade secrets and data as confidential. German regulations that forbid insider trading require that partners or customers of PSI who become aware of information such as the placing of a significant order, which is likely to influence share prices, are obliged not to trade in PSI shares until such time as the information has been publicly announced and further to extend this obligation into their confidentiality requirements.

Employees and third parties have the opportunity to report compliance violations to the Compliance Committee. This information is kept confidential.