Code of Conduct


Acting in a responsible, ethical and lawful manner is firmly anchored in our corporate philosophy and thus in our entrepreneurial activities. It forms an essential basis for our long-term corporate success. Compliance with the law is a matter of principle for us, as is the recognition of our responsibility for the common good of society. Both are at the center of our activities.

Our following principles of conduct are guidelines for dealing with each other in the CAPCELLENCE Group, with our customers, business partners and the general public.

Every employee, manager, director, advisory board member and shareholder bears responsibility for the public image of the CAPCELLENCE Group and must always take care to behave and communicate accordingly. Violations may have serious consequences for the company, its employees and business partners.

Accordingly, the following principles are binding for all employees, managers, directors, advisory board members and shareholders.

Dr. Spyros Chaveles


1. Compliance with the law is our highest priority

Compliance with the law has the highest priority for all actions, measures, contracts and other processes.
Special importance is given to the protection of human rights and fundamental rights in the workplace
We respect human dignity, we consider good ethics and decency to be self-evident and more important than maximizing profits
Collective effort to ensure that all employees comply with laws, regulations and our Code of conduct
→ Compliance with the law is our highest priority.


2. We respect labor and employee rights and also ensure that our business partners at home and abroad comply with them.

Protection of the basic rights of work
Rejection of any kind of forced, compulsory and child labor
Freedom of association and collective bargaining for our employees
No discrimination of minorities or any other type in employment and career development
Remuneration and benefits at least in line with legal minimum standards, ideally well above them
Vacations granted at least in accordance with legal requirements
Fair pay and compliance with legal requirements in connection with own employees and work contracts
Fair treatment and fair payment for temporary workers, as well as the opportunity to take over their jobs
We respect labor rights and ensure that our business partners comply with them

3. Our cooperation is characterized by trust, openness, tolerance and respect.

Promotion of the CAPCELLENCE culture, which is characterized by trust, openness and transparency, tolerance, respect and appreciation.
Equal treatment of all employees and the dignity of the individual are above all else
The protection of personal rights of each individual is important to us
No tolerance of bullying, hostile, discriminatory statements or harassing behavior
Every employee of our company, our customers, suppliers and service providers is treated with respect and appreciation regardless of: Task or position within the company, gender or sexual orientation, religion or ideology, skin color, ancestry or origin
→ Our cooperation is characterized by trust, openness, tolerance and respect


4. We ensure safe and fair working conditions, which should be improved continuously.

Responsibility for the safety and health of employees
Ensuring occupational safety and health protection in the workplace
Continuous promotion of employees' health, performance and job satisfaction
Balancing work, family and private life
Employees comply with occupational health and safety regulations
We ensure safe and fair working conditions, which should be improved continuously


5. Integrity: We not only do what is legally permissible, but also do what is right.

For long lasting success, entrepreneurial action must follow ethical principles
Achieve success with integrity
Guidelines for ""conduct with integrity"" beyond the legally prescribed requirements
Ensure exemplary, binding, consistent and credible action
Create a basis of trust and gain people' s confidence
Embed integrity in the personal value system of employees
Reinforce the entire work environment
Moral compass and guidance for daily actions
→ We do what is not only legally permitted, but also right

6. Executives have a special responsibility towards their employees

Responsible action requires responsible managers
Managers set a good example and ensure that rules are clear and understandable and are known and followed in their respective areas.
Promotion of a positive working atmosphere
Listen to the concerns of employees
Regular and fair appraisal of employees
Equal pay
Protection of fundamental rights in the workplace
Promotion of an open dialogue between managers and employees
Promotion of employees' professional development
Executives have a special responsibility towards their employees.

7. Interaction with business partners and third parties - We are only successful in the long term if we work together and with our business partners.

Commitment to fierce but fair competition
Representation of our own interests, but fair and honest dealings with customers, suppliers and business partners
Fight and prohibition of any corruption or taking and granting of advantages
Convincing through products and services and surpassing competitors in a fair manner
No personal advantages may be accepted, offered or granted in connection with business activities
Careful separation of personal and corporate interests
Non-permission of secondary activities that interfere with the fulfillment of official duties
→ Together and with our business partners, we are successful.


8. We bear responsibility for the common good and the environment.

Recognition of responsibility for the common good
Highest standards of quality and safety of products and services
Development and offer of safe products and services aimed at increasing road safety
Prevention and training with regard to safety and environmental protection
Careful review of all safety information and observations
Responsibility for environmental protection and careful use of resources
Human labor, natural resources such as energy, raw materials or materials
Assets of the company
Continuous improvement of production and the provision of services in order to keep impacts on people and the environment to a minimum
→ We bear responsibility for the common good and the environment.


9. Each employee must take care of the company's property.

To protect the property and assets of our customers is a priority
Active protection of all data, trade secrets, information and innovations of our customers
To protect the property and assets of CAPCELLENCE is a priority
Active protection of all CAPCELLENCE data, trade secrets, information and innovations
Company property must be respected and protected
Proper, careful and sparing use of work equipment
Use of company property exclusively for company purposes
Removal from the physical working area only with prior consent
→ Each employee must take care of the company's property.


10. Data protection: We actively ensure compliance with rules for the protection of confidential data and avoid the use of insider information.

We responsibly handle our own data, personal data of our employees and data of our business partners. We are constantly in possession of confidential data from business partners, even if it is not explicitly identified as such. Therefore, we always have insider information at our disposal; this information is never used for the benefit of CAPCELLENCE or for personal gain.

Consistent adherence to all data protection regulations
Protection of CAPCELLENCE's confidential information, as well as all data, trade secrets and information of our business partners by all employees
Respect for the privacy and informational self-determination of individuals
Best possible protection of the data of employees, customers and business partners
Commitment regarding confidential, personal data
to only collect personal data within the permitted and necessary scope
to keep it secret
to protect against improper use
No unauthorized use of confidential information of other companies by our employees or by CAPCELLENCE.
No insider trading: No use of confidential information concerning our business partners or other companies for personal purposes or unauthorized purposes within CAPCELLENCE
Reporting to third parties in a true,fair and timely manner
We actively take care to comply with rules for the protection of confidential data and avoid the use of insider information.

11. We assess our risks consistently and with foresight

Active risk management is an essential component of CAPCELLENCE's integrated control system.
The individual elements of risk management together form a system that ensures the identification, analysis, assessment, management, ongoing monitoring and reporting of risks.
We assess our risks consistently and with foresight.


12. We do not only comply with national and international tax laws, but also reject any form of tax abuse and the exploitation of regulatory loopholes

We ensure that all business transactions in our books are reported in accordance with established rules and processes and generally accepted accounting principles. Our accounting, financial reporting and reporting systems are timely, accurate, correct, understandable and truthful. They comply with current legal and regulatory requirements.

We are explicitly committed to fulfilling all tax obligations as a matter of principle.

We practice responsible tax planning - in compliance with the law - which takes account of our public law shareholding and our obligations under stock corporation law. We reject tax planning abuse and avoid legally permissible aggressive tax optimization. When introducing new products, we ensure compliance with tax law requirements. We do not assist customers or our employees in actions aimed at misleading tax authorities.

We always keep our books correctly and completely.

→ We comply with national and international tax laws and reject any form of tax abuse.


13. We will not engage in money laundering or terrorist financing; we are familiar with our business partners and their business.

CAPCELLENCE's goal is to prevent money laundering and terrorist financing in connection with our business activities. We know and manage these risks to avoid being used to funnel criminally acquired money into the legitimate economy and to support terrorist activities. CAPCELLENCE has the necessary tools and measures in place to fight money laundering and terrorist financing.

When conducting transactions, we pay attention to suspicion criteria for money laundering as well as compliance with applicable financial sanctions, embargoes and sanctions policies issued by CAPCELLENCE.

In cases of suspicion, we actively involve the unit responsible in the bank's Compliance division. The bank always reports justified suspicious cases to the relevant law enforcement authorities without delay. We will never communicate suspicious money laundering reports to the outside world.

We actively and appropriately inform ourselves about the purpose and intended development of the business relationship with our customers, and follow clear rules and procedures in doing so. We include information on the underlying transactions behind the exposures in our decisions and analyze them carefully.

We do not allow ourselves to be used for money laundering or terrorist financing.

We are familiar with our business partners and their business.


14. We actively ensure compliance with our Code of conduct

Obligation of employees to comply with the Code of conduct
Monitoring and aligning their own actions with the principles
Mere awareness is not enough
Misconduct must be identified at an early stage in order to avoid possible damage
Any indications of misconduct are followed up fairly and appropriately - but also decisively
If employees have any questions or comments about the Code of conduct, they can contact their managers or the contact person at the company
Dr. Spyros Chaveles
Phone: 040 307 007 06

→ We actively ensure compliance with these rules.