Code of Conduct

Code of conduct for business partners

The companies of the Bookwire Group consisting of Bookwire GmbH, Bookscapes Inc., Bookwire Spain S.L.U. and Bookwire Brazil Distribuicao de Livros Digitais Ltda. are committed to high ethical and social standards. Lawful, ecologically sustainable and socially responsible behavior is the fundamental basis of any business relationship. Corporate responsibility, especially with regard to sustainability and climate protection, are issues of crucial importance for a beneficial coexistence in our society. In the spirit of a holistic approach, Bookwire also expects its business partners to comply with these standards. The provisions of this Code of Conduct are intended to illustrate the requirements with regard to the conduct of Bookwire's business partners. This Code of Conduct is based on the most important international standards and regulations for human rights and environmental standards as well as the German Supply Chain Duty of Care Act.

The business partner shall adhere to the principles listed. In addition, it shall communicate the content of these rules of conduct or rules of conduct with at least the same effect to its employees, agents and subcontractors and take all necessary precautions to implement these requirements.

1. Compliance with laws

The applicable law of the respective applicable legal system must be respected. It is strictly prohibited to induce third parties to commit unlawful acts or to participate in such acts.

2. Human rights

Fair treatment
The business partner will not use forced labor. It shall ensure that there is no rough or inhumane treatment in the workplace. This includes, in particular, sexual harassment, physical punishment, mental and physical coercion and verbal abuse of employees. Employees must also not be threatened with such behavior.

Child labor and protection of minors
The business partner does not use child labor and observes all applicable regulations for the protection of minors. The minimum employment age must not be below the age at which compulsory schooling ends. Under no circumstances may employees be younger than 15 years of age (or 14 years of age if this is permitted by national law in accordance with ILO Convention 138).

Health and safety
Workplaces and work facilities must comply with the applicable laws and regulations. Any violation of fundamental human rights in the workplace and in company facilities is prohibited. In addition, fire protection and emergency care requirements in particular must be complied with. Adolescents (young people) in particular should not be exposed to dangerous, unsafe or unhealthy conditions that jeopardize their health and development. Employees should receive regular training on health and safety in the workplace. Adequate cleanliness must also be ensured at workplaces. If the business partner provides employees with accommodation, the same requirements apply to them.

Remuneration and working hours
The business partner shall comply with all relevant laws, regulations and industry standards on remuneration and working hours. Remuneration for regular working hours and overtime must comply with the national statutory minimum wage or the industry minimum standards, whichever is higher. The employees must be granted all legally prescribed benefits. The business partner must ensure that employees receive clear, detailed and regular written information on the composition of their remuneration (e.g. in the form of payslips). Employees shall not work longer than the legally permitted working hours. Sufficient break times must be ensured. Statutory rest days are observed.

Freedom of association
In accordance with local laws, the right of employees to freely form or join trade unions must be safeguarded. The business partner guarantees the right to freedom of association. Employees have the right to assemble in accordance with the relevant laws and to form or join trade unions and employee representative bodies. Employees also have the right to collective bargaining to resolve workplace and wage issues. The assertion of these rights may not be punished with reprisals.

Disciplinary measures
Disciplinary measures must be taken within the framework of national law and internationally recognized human rights. Any inappropriate disciplinary measure must be avoided, in particular the withholding of salary, social benefits or documents (e.g. ID cards) and the prohibition to leave the workplace. The business partner respects the right of its employees to resign.

Prohibition of discrimination
Equal opportunities and equal treatment of employees must be promoted and discrimination in any form must be strictly rejected. In particular, no one may be disadvantaged on the basis of their age, gender, sexual orientation, pregnancy, disability, nationality, ethnic origin, skin color, religion or ideology, political beliefs, social background or marital status. Equal opportunities for women and men are guaranteed in all aspects of education and personal and professional development. The personal dignity, privacy and personal rights of each individual are respected.

3. Ethical business conduct

Prohibition of corruption and bribery
he highest standards of integrity must be applied to all business activities. Bookwire does not tolerate direct or indirect involvement in corruption or bribery and expects the same from its employees and business partners. The offering, granting or promising of benefits to government officials or private sector entities with the aim of influencing official actions or gaining an unfair advantage is strictly prohibited. Only generally customary low-value promotional gifts for business use are permitted. Invitations (to business lunches or similar) are also permitted if they have a business purpose, are within reasonable limits and are not likely to influence business decisions in a dishonest manner.

Avoidance of conflicts of interest
Business decisions must be made in the best interests of the company and uninfluenced by personal interests. Conflicts of interest that could adversely affect business relationships must be avoided. When deciding on a business relationship, only factual and objective criteria such as price, quality and quality management, reliability, product suitability and the existence of a long-term and conflict-free business relationship count. Existing and potential conflicts of interest must be disclosed by a business partner.

Fair competition
Business partners will act in accordance with national and international competition laws and will not engage in price fixing, market or customer allocation, market collusion or bid rigging.

Intellectual property
Business partners will respect intellectual property rights. Technology and know-how must be transferred in such a way that intellectual property rights are protected.

Protection of trade secrets
Business and trade secrets as well as confidential matters must be protected from unauthorized access by unauthorized parties. Confidentiality must be maintained for the duration of the business relationship and beyond. Confidential information is information which it can be assumed is neither publicly known nor intended to be made public.

4. Prevention of money laundering and terrorist financing

The relevant statutory provisions on the prevention of money laundering must be observed. Money laundering and the financing of terrorism must not be promoted either directly or indirectly.

5. Foreign trade and embargoes

The applicable regulations on customs duties and foreign trade must be complied with and embargoes observed.

6. Data protection

The business partner undertakes to protect personal data. When collecting, storing, processing, transmitting and passing on personal data, the business partner must comply with the laws on data protection and information security as well as the official regulations.

7. Environment

Environmental protection
The business partner shall comply with the relevant environmental protection laws and regulations. The business partner's operations comply with the requirements of waste legislation as well as immission and water protection. The business partner shall comply with all regulations relating to hazardous substances. This applies in particular to the storage, handling and disposal of hazardous substances. Employees must be instructed in the handling of hazardous materials and substances.

Dealing with waste
Compliance with local regulations and laws regarding the generation, storage, disposal and recycling of waste, waste gases and waste water must be ensured by the business partners. Activities that may have a negative impact on human health or on the environment and climate must be appropriately managed, measured and controlled. The generation of waste, waste water and emissions should be minimized as far as possible.

Resources and environmental impact
Environmental pollution must be avoided or at least reduced as far as this is possible by proportionate means. Environmental and climate protection as well as the promotion of biodiversity is an ongoing task that can only be fulfilled by continuously improving the level of protection through the constant reduction of resource consumption and efforts to reduce waste.

8. Information, control

The business partner will identify risks in the supply chains and take appropriate measures to reduce and avoid them.

Notification of violations and duty to cooperate
If the business partner becomes aware of any indications of a not insignificant breach of these rules of conduct, it must report this immediately. The business partner is obliged to provide written information on violations upon request and shall cooperate in the clarification of a violation. The notification shall be made while safeguarding the legitimate interests of the business partner and taking into account the rights of employees, in particular data protection and the protection of business secrets. This also applies to breaches committed by subcontractors of the business partner. The business partner must establish an appropriate internal reporting system for violations of these standards; employees who submit reports must not be disciplined or disadvantaged as a result.

Compliance with this Code of Conduct can be checked with business partners by means of an audit. For this purpose, Bookwire will coordinate with the business partner on the scope, period and location.

Consequences of violations
In the event of a breach of the obligations contained in these rules of conduct, the business partner may be given a reasonable period of time to remedy the situation or, if this is not possible due to the nature of the breach, a warning may be issued. If the business partner allows the deadline to pass without remedying the situation or if there are repeated breaches, the contractual relationship can be terminated without notice. The same applies to serious breaches. Further rights, in particular a possible claim for damages, remain unaffected by this.

9. No third-party protection

This Code of Conduct exclusively regulates the relationship between Bookwire and its business partners. Third parties are not included in the scope of protection of this Code of Conduct and cannot assert any rights