1 Environmental Protection and Procurement
We are all part of the same, limited habitat, and live from the same resources. That is why we are aware of our responsibility for sustainable action. As a company, we have been committed to continuously reducing our environmental impact for years. For this reason, we continually optimize our products and processes in terms of environmental compatibility and research new solutions together with our suppliers and partners.Sustainability is an integral part of our business, which we ensure, among other things, by selecting our suppliers according to ecological and social criteria. We also intend to sensitize our customers to this issue further. This document applies to all PROCOS employees, suppliers as well as business partners and is intended to provide a generally valid basis for long-term mutual business relationships.This policy is reviewed annually by the senior management and further developed as necessary. Objective:Not only do we want to comply with all legal requirements for environmental protection, but we also strive to keep the environmental impact caused by our business activities as low as possible. Individual goals are set for each individual topic area, which are recorded in the form of key figures to track the development of implementation and success.

1.1 Energy
We undertake to choose only appliances with an energy efficiency class of at least A++ when purchasing new electronic equipment. High energy efficiency was also taken into account in the choice of premises. This is intended to keep the overall energy consumption of our offices as low as possible. We have been purchasing electricity from renewable energy sources for years and have set ourselves the goal of increasing this to 100% at both our locations.Our employees are instructed to switch off appliances at the end of business hours and to save heating energy by using the technical control options (weekend and overnight shutdown).Our employees are also encouraged to address suggestions for improvements that lead to direct energy savings directly to senior management.

It is our goal to reduce our energy consumption even further.

1.2 Waste
We try to reduce our waste volume, which is mainly limited to paper, household waste, and occasionally electronic waste, to a minimum. We try to close loops wherever possible. Our employees are instructed to make office filing systems as paperless as possible. This is also promoted by an increasingly better offer of mobile laptop integration into our internal network system.

Our goal, however, is to keep the return rate of old electronic equipment at 100%. In addition, we plan to reduce the volume of paper by 10% per year.
Waste separation systems continue to be implemented at100% of our sites.

1.3 Business Trips and Fuel Consumption
As we cannot do without business trips due to sales activities and other matters, we try to make them at least as environmentally friendly as possible. For this purpose, we prefer to use environmentally friendly alternatives, such as traveling by train. We encourage our employees to use a fuel-saving and consumption-reducing driving style whenever they use vehicles from the company pool. When purchasing the vehicles, we generally took care to choose the most efficient models possible.Objective:100% of the vehicles in our carpool should be equipped with green emission stickers. When purchasing new cars, consumption and CO2 emissions should be directly taken into account when choosing a vehicle.

1.4 Transparency and Open Dialogue
We maintain an open dialogue and exchange of information with employees, customers and public institutions. As an essential element in raising the awareness and motivation of our employees in connection with environmental protection issues, we organize training courses and general information events for our employees and our customers.Objective:Our goal is to train 100% of our employees once a year on the subject of environmental protection in addition to professional training. This includes a brief presentation of our values, their implementation, and impact in practice, as well as related KPIs.

1.5 Sustainable Procurement
As a packaging expert with contract manufacturing, the selection of our suppliers or producers plays a significant role. Here we see an opportunity to make a substantial contribution in the area of sustainability. To ensure this, we have built long-standing relationships with our suppliers, with whom we work in close cooperation to continuously optimize our products as such and especially with regard to sustainability. This resulted, for example, in our “The One Material Bag” – a carrying bag made of pure paper. This allows the use of plastics for the handles of the bags to be reduced. We also use – with a few exceptions – only FSC®-certified raw materials and offer fully compostable packaging and printing free of mineral oil.Due to the trust we have gained over the years, we can also ensure that our suppliers manufacture the products according to our wishes, in the appropriate quality and compliance with high ecological and social standards. We regularly check this by means of queries and audits, which we carry out on-site at the suppliers. Besides our own audits, we require external certifications from our suppliers, both in the environmental and social areas. Based on our assessments and within the framework of the requirements for continuous improvement imposed by the certifications, for example, we gradually renewed machinery in our suppliers’ production facilities, introduced processes for recycling water and/or implemented innovative waste management concepts. This will ensure that we, as PROCOS, also further reduce our environmental impact through our business activities along the supply chain.

100% of our procurement volume should be sustainable in the environmental and social area:
– Supplier Code of Conduct, which we pass on to suppliers via our customers
– Availability of policies on environmental protection and sustainability
– Certificates (e.g., ISO 9001, SO 14001, SA 8000)
– Recognized labels (e.g., FSC, Blauer Engel)

2 Code of Conduct
Our employees are our most important capital. Good working conditions are the key to a successful business. Additionally, compliance with legal requirements is the fundamental prerequisite for long-term stable corporate development.This document applies equally to all PROCOS employees, suppliers, and business partners and is intended to provide a generally valid basis for long-term business relations. This policy is reviewed annually by the senior management and further developed as necessary.

2.1 Labor Policy
2.1.1 Work Environment

PROCOS is committed to a fair and collegial working environment. Attention and respect in our daily dealings with each other are essential. PROCOS will not tolerate any statements or behavior that encourages aggressiveness towards colleagues, business partners, or customers. PROCOS takes a firm stand against harassment and bullying. PROCOS expects its managers at all levels to show a sense of responsibility and awareness of the fact that they have a role model function to fulfill. It is mainly up to them to create a good working environment and collegial cooperation.Any such violations should be reported immediately to the management or direct superiors. Objective:Our goal is to have no violations during the year.

2.1.2 Working Conditions
The international principles of the ILO (International Labour Organisation) must be observed, and a balance between work and private life must be ensured: A regular working week should not exceed 40 hours or 60 hours per week including overtime. It is possible to work from home or remotely. Following the ILO guidelines, overtime is compensated and rewarded fairly and transparently. PROCOS pays wages and salaries in line with regional standards. Apart from legal requirements, the amount depends on the performance of the employees (performance-based pay). Work of equal value is also paid equally. Wages are not paid to third parties but directly to the employees

2.1.3 Human Rights
PROCOS does not employ children under the age of 15 or below the national legal minimum requirements if these are stricter (ILO Convention 138). Furthermore, PROCOS does not use forced laborers or workers comparable to them (ILO Convention No. 29 and 105).

2.1.4 Employee Health and Safety
PROCOS is committed to a health-promoting work environment and to maintaining health and safety at work. Local and national regulations are minimum standards for PROCOS. The aim is to create a working environment in which work and private life can be well balanced.Although our employees are not exposed to any significant health risks from office work per se, we nevertheless attach great importance to making workplaces as ergonomic as possible. This is intended, for example, to prevent repetitive strain injury syndrome and other physical complaints. As a measure and if necessary, our employees receive ergonomic computer mice or screen glasses, for example.

PROCOS would like to keep the number of occupational accidents at 0 per year.

2.1.5 Discrimination
Following our corporate principles and the labor laws – in particular the General Act on Equal Treatment –we do not tolerate discrimination of any kind. This means that PROCOS treats all people equally regardless of their origin, background and nationality, religion and belief, political or trade union activity, gender and sexual orientation, age, disability or illness.

2.1.6 Career Management
Our employees are our assets. To advance the company as well as the employees themselves in their personal development, every employee receives annual feedback on their performance and possible optimization potential. In addition, we offer 100% of our employees the opportunity for internal or external further training. We have set ourselves the goal of introducing a company-wide career management system with career development plans.

2.1.7 Secondary Employment
Secondary employment (including voluntary work) outside the company’s operational tasks requires the written approval of the senior management in all cases. In addition to the time required, the respective applications must also show that the employee can continue to fulfill his or her full obligations under the employment contract despite secondary employment.

2.2 Legal Compliance
An economically sustainable management is only possible if all applicable laws are complied with. Since infringements of such laws can cause financial and reputational damage on an unquantifiable scale, prevention is the highest priority. For this reason, we have not identified individual objectives for this segment, but an overall objective.

2.2.1 Corruption
No PROCOS employee is permitted to accept or offer rewards in the form of cash, material goods, or services from or to business partners, institutions or government bodies to gain advantages for PROCOS, himself or herself or third parties. This does not apply to occasional socially acceptable benefits if they are only for courtesy and have no influence on the official activity.

2.2.2 Personal Benefits
In general, it is prohibited to accept or offer benefits of any kind for personal use in a direct connection with the employment relationship. Voluntary promotional and occasional gifts with a value of up to 10.00 EUR may be accepted. Gifts with a value of 10.00 EUR or more must be rejected and reported immediately to the senior management. Discounts and other benefits offered to employees by business partners or customers in their role as PROCOS employees may only be accepted if they are granted to all PROCOS employees.An obligation to inform the senior management applies to any benefits offered.

2.2.3 Invitations
Invitations from business partners and customers for lunches/dinners or events may only be accepted or offered by PROCOS employees if they are appropriate. Appropriate means that they are made voluntarily and for business reasons. It would be inappropriate to accept invitations frequently or if the invitation is no longer in proportion to the occasion, or if it is made prior to the award of a contract or business transaction.

2.2.4 Antitrust Law
To protect fair competition, no one is allowed to fix prices with the competition or to carry out unjust manipulation of prices in any way.

2.2.5 Data Protection and Confidentiality
PROCOS protects the privacy of its employees, business partners, and customers. For this reason,PROCOS only collects, processes and uses personal data if permitted by applicable laws, other applicable regulations or internal guidelines.Confidential information of the company as well as of business partners and customers must be kept secret and may not be disclosed or otherwise made available to third parties without authorization. This obligation of confidentiality shall also apply after termination of the employment relationship. Personal data must be stored securely, and the necessary measures taken to prevent unauthorized use.

For all these matters, violations can be reported directly to senior management. Our employees, as well as stakeholders, are encouraged to use this communication channel if violations are imminent or identified. It is our goal to keep the number of violations and reports per year permanently at 0 for all the items mentioned.

Equal Treatment in Language
If personal designations in this Policy or this Code of Conduct are only mentioned in the feminine or masculine form, they refer equally to women and men.

Validity of this Policy
All employees are encouraged to report violations of the guidelines set out in this document without delay or, if necessary, to report them through neutral third parties. We are considering establishing an anonymous whistleblower mechanism for the future.If a violation is confirmed, it may be punished by appropriate sanctions. Depending on the severity of the violation, this may extend to a warning and termination of the employment relationship.Employees who report such incidents are guaranteed freedom from sanctions and confidentiality.

Signed by Leander Kritikos,
CEO in Munich, on Friday 29th of November 2019