Code of Conduct

Introduction
We are committed to legally compliant corporate management and acknowledge our responsibility to society. Every company in the LINK Group complies with applicable laws and other legal regulations in the countries in which it is active. Compliance with the laws applicable in the respective country is the minimum requirement for our activities. Therefore, the company respects applicable law everywhere and expects the same from its employees. Illegal conduct can cause great financial losses. The mere suspicion of legal infringements can cause severe harm to the company. The consequences of our actions therefore also have to be measured against how they will affect the reputation of the company and its integrity. All actions must be based on a clear understanding of statutory and legal regulations, internal company directives and our shared values. This Code of Conduct describes the framework of how to implement the targets of the company in everyday work. The Code of Conduct is intended to make compliance with legal regulations and internal rules easier. However, it is not a complete collection of the duties owed to all legal systems in which the company is active. Therefore, our employees are obliged to obtain expert advice in case of doubt. Superiors and specialised departments are available to answer questions by the employees. The Code of Conduct may be specified and supplemented by additional rules and regulations.

1. General conduct
In accordance with our mission statement (https://www.linkorthopaedics.com/de/ueber-link/unternehmen/leitbild/) tolerance, respect, objectivity and fairness are required when dealing with each other and with third parties. Employees must separate their private interests from those of the company at all times.

2. Business conduct
The company competes in business fairly and in compliance with the law.

Bribes and corruption
Bribes and corruption are not tolerated by the company. The reputation, acceptance and business activities of the company as a trustworthy market participant must not be endangered by such activities.

Dealing with decision-makers in the health sector
Employees must not offer, provide or authorise any inappropriate advantages for decision-makers in the health sector (HCP). This includes money, merchandise, services or other unjustified advantages. Any cooperation with HCPs has to be conducted in a way that ensures without any doubt that the neutrality and independence of the HCP remains unaffected. The regulations of criminal codes, pharmaceutical advertising laws or laws against unfair competition always have to be obeyed and the following four principles must be complied with regarding any service or consideration provided to decision-makers in the health sector: separation principle (contributions must not be connected with procurement decisions), transparency principle (every contribution, especially payments, must be disclosed in accordance with the applicable laws), documentation principle (all performances must be recorded in writing) and the equivalence principle (performance and consideration must be in an appropriate relationship).

Competition
LINK is committed to fair competition and in particular, does not become involved in any formal or informal agreements with other companies for the purposes of a prohibited prevention, restriction or falsification of competition.

Money laundering
Any infiltration of the proceeds of crime into legal financial and economic circulation with the concealment of their true origins and other money laundering activities domestically or abroad are prohibited.

Export
All national and international customs, export and foreign trade regulations must be complied with.

Financial reporting and documentation obligations
Business transactions must be documented appropriately and truthfully. The complete and correct recording of information relevant to accounting and to tax law must be guaranteed. Legal and official retention regulations must be complied with.

3. Product safety and quality
We meet our product observation obligations thoroughly and in full and keep the users of our products continuously informed. Every LINK product is state-of-the-art and meets all legal and official regulations and our internal company safety and quality guidelines. Every employee is responsible for effectively enforcing these quality assurance requirements and for receiving and remedying complaints comprehensively and in good time.

4. Protection of company assets
The assets of the company must be safeguarded and protected.

Conflicts of interest
Any conflict that occurs during employment between the financial interests of an employee and the financial interests of the company must be avoided as far as possible and otherwise disclosed to the employee’s superior in the same way as any advantages offered to the employee in relation to their employment (e.g. invitations and/or presents from suppliers and service providers). Such advantages may only be accepted with the approval of the employee’s superior.

Business secrets
Business secrets must be treated confidentially. Corresponding digital or analogue data storage media must be labelled as confidential and stored so that they are not accessible to unauthorised persons.

5. Fairness for and protection of employees and applicants
Any unequal treatment for reasons of nationality, ethnic origin, skin colour, age, appearance, sex, disability, sexual identity, religion or political opinions and all other characteristics protected by law must be avoided in all employee or applicant related decisions.
We provide our employees with a safe workplace. All of our employees comply with all occupational safety regulations in their area. Managers must ensure that employees are sufficiently trained in occupational safety.

6. Cooperation with the authorities
Regulatory obligations towards responsible authorities must be followed. The company reaches a good and cooperative relationship with all responsible authorities. Therefore, information must generally be conveyed in full, correctly and punctually.

7. Dealing with the media and government agencies
Enquiries from the media or government agencies may only be answered by employees who have received explicit special authority to do so.

8. Data protection and the use of electronic media
The company is obliged to treat personal data as confidential and to collect, process and store personal data exclusively in accordance with applicable data protection provisions. Insofar as the company provides access to and the use of electronic media for business purposes, such electronic media must not be used for purposes contrary to laws, regulations, instructions, directives or other provisions of the company.

9. Environmental and health protection
The company is committed to environmental protection and the protection of human health.

10. Please note:
Infringements of this Code of Conduct will not be tolerated. They may lead to disciplinary measures up to dismissal and, depending on the type of infringement, can lead to liability action under civil law and criminal prosecution. All employees of LINK must report every possible violation of the Code of Conduct or other violations of the law to their superior or – if they fear a conflict of interest in this case – to their superior’s superior. The company assures that no employee who reports irregularities or suspicious will suffer any loss or any other disadvantage from this.