Compliance rules

Bilster Berg Drive Resort GmbH & Co. KG guidelines for compliance

These guidelines provide the basis for a corporate culture and corporate governance based primarily on responsibility, sustainability, integrity and fairness. These values are intended to guarantee assumption of not only economic but also environmental and social responsibility with regard to customers, employees, contractual partners and contractors and, together with them, to continue supporting the successful development of Bilster Berg Drive Resort GmbH & Co. KG (Bilster Berg KG) to the benefit of its shareholders. These values, along with the ethical and moral requirements they present for our business, form part of the Code of Conduct set out in these guidelines. These constitute binding guidelines for business administration and day-to-day operations and they are based on fair and sustainable employee relations, environmental awareness, environmental protection and anti-corruption measures. They apply not only within Bilster Berg KG, but they also constitute our guidelines in relation to third parties. For this reason, Bilster Berg KG requires all suppliers, contractors, consultants and other contract and business partners to comply with the values in this Code. This also applies to Bilster Berg KG shareholders, insofar as they have any business relations with them directly or indirectly outside of the company relationship.

Core values for socially responsible corporate governance

Bilster Berg KG actively seeks to ensure that the following values and principles in particular are observed and respected in the long term.

Compliance with the law/environmental protection

Bilster Berg KG complies with applicable laws and other regulations. It complies with environmental regulations and standards applicable to its operation and acts in an environmentally conscious manner; in particular, construction permits and operating licenses and their respective conditions are carefully observed and respected.

Integrity and business management

Bilster Berg KG bases its actions on widely accepted ethical values and principles, in particular these include: integrity, honesty, transparency and non-discrimination. We strive for clean business practices and fair competition. Insofar as contracts are concluded in business dealings with shareholders or with companies in which they, or their spouses or relatives from the same lineage, are directly or indirectly involved, any service or equivalent must be provided in reasonable proportion as would be the case with third parties; in other words, they may not be granted one-sided benefits. Exceptions require the written consent of the management and – if this is not already the case – the shareholders’ meeting as well.

Offering and accepting benefits/impermissible payments, benefits

Employees are prohibited from taking advantage of people who have business relationships with Bilster Berg KG. They should reject any offer that might affect objectivity in conducting business, or cause them to act against Bilster Berg KG’s values or interests, or which could otherwise result in violations of this Code. This also includes accepting gifts of minor value; accepting hospitality up to a value of € 150 (maximum € 800 in the financial year) is permissible for employees who have contact with customers. Exceptions require the prior consent of the management.

Any kind of bribery is prohibited, whether it be direct bribery or through the participation of third parties. This also includes any type of behavior that could potentially be construed as bribery. Similarly, offering, promising or granting illegal benefits in order to achieve or influence any preferential treatment with regard to decisions in favor of Bilster Berg KG is prohibited.

Conflict of Interest

Employees – whether it be with or without remuneration or compensation – are not allowed to engage in any activities outside of Bilster Berg KG which may cause conflicts of interest or which contradict, or appear to contradict, the interests of the company. In there is any doubt, written consent must be obtained from the management.

Confidential Information

Any Bilster Berg KG assets, such as information, materials, supplies, intellectual property, systems, software, and other assets that belong to, are leased, or are otherwise owned by the company, may only be used for legitimate business purposes. Confidential information that is known to employees must not be disclosed to third parties, even after the employment relationship has been terminated. Private use of the aforementioned assets are permitted only with the approval of the management.

Implementation and enforcement of the guidelines

Bilster Berg KG employees must be familiar with the current version of the guidelines and comply with them. They are required to familiarize themselves with the guidelines that relate to their duties and their work, and to uphold these standards at all times and to always act in accordance with the Code. They must immediately notify management of any actual or suspected violations of the guidelines.

Bilster Berg, on October 31, 2016

Authorized Managing Directors:

Hans-Jürgen von Glasenapp