ETHICS AND
INTEGRITY
Code of Conduct
Providing orientation
Our group-wide ethics and compliance activities ensure that legal regulations and internal company policies are observed. The mandatory application of compliance standards is the basis of responsible corporate governance. To reinforce this approach, the position of Compliance Manager was filled at the end of 2020, reporting directly to the group management. The Compliance Manager’s task is to establish uniform global standards for compliance management and ensure that they are observed.
Our compliance principles are defined in the Code of Conduct of the CHT Group. It describes the conduct we expect from our managers and employees in their day-to-day work. Responsible and lawful behavior with integrity is of utmost importance for our companies’ reputation and the confidence of our business partners and of the wider society. The Code of Conduct is based on internationally accepted standards and applies equally to all companies within the CHT Group. The primary goal of the Code of Conduct is to prevent violations. The group management is responsible for its centrally controlled implementation and communication. The Managers worldwide are responsible for ensuring compliance with the Code of Conduct. Mandatory training courses are an essential instrument for avoiding compliance violations.
In 2021, a worldwide compliance awareness training course was held for the complete leadership team as well as for the sales representatives of the CHT Group. In addition, there is an online-based portfolio with training measures on compliance which are conducted individually or as required.
In addition to the Code of Conduct, our business activities and the conduct of all employees are of course also governed by the applicable laws. If there is any hint or indication of a violation of our code rules, the matters must be investigated by the responsible manager and reported without any delay to the group management in Tübingen. In addition, every employee can address violations or questions on these topics directly to codeofconduct@cht.com by email.

Control Self-Assessment
On a regular basis, the group management conducts a Control Self-Assessment (CSA) with all companies of the group. With our Control Self-Assessments, we pursue the following goals:
- Review, analyze and document business processes
- Review the suitability of existing control systems
- Identify possible risks and necessary improvement measures
- Ensure compliance with overriding guidelines and processes
- Ensure local management is in accordance with national law
- Ensure the implementation of the Code of Conduct
- Review the management in accordance with the principles of the UN Global Compact
The next CSA is planned for 2022.
Our Code of Conduct to read