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Group Policy

Cross-functional

Title Code of Conduct

Subtitle Policy about the appropriate behavior in business practices

Validity August 2013

This release invalidates any previous editions of the “Code of Conduct” and the “CoCoDO”

Scope of application All employees of the DORMA group worldwide

Contact Person Isabell Bäcker

Chief Compliance Officer

DORMA Holding GmbH + Co. KGaA

Ennepetal / Germany

Telephone: +49 2333 793-6533

Email: isabell.baecker@dorma.com

Responsibility Group Compliance

Approval Karl-Rudolf Mankel,

Michael Flacke,

Thomas P. Wagner,

Oliver Schubert

No. of Document POL-GRP-001-CoC-EN

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Contents Page

LETTER FROM THE HOLDING BOARD .............................................................................. 4

GENERAL INFORMATION ................................................................................................... 6 1. Objective ....................................................................................................................... 6 2. Scope of application ...................................................................................................... 6 3. Validity........................................................................................................................... 6 4. Communication.............................................................................................................. 6 5. Contacts for help ........................................................................................................... 7

POLICIES.............................................................................................................................. 8

1. Corporate Responsibility................................................................................................ 8 1.1 Compliance with the law and internal regulations................................................... 8 1.2 Human Rights ........................................................................................................ 8 1.3 Employment rights ................................................................................................. 9 1.4 Safety at work and health......................................................................................10 1.5 Environment..........................................................................................................10 1.6 Governmental and regulatory authorities ..............................................................11 1.7 Quality and product safety ....................................................................................11

2. Conduct in the workplace..............................................................................................12 2.1 Responsibility of each DORMA employee.............................................................12 2.2 Trust, respect and tolerance .................................................................................12 2.3 Openness and transparency .................................................................................12 2.4 Use of company property ......................................................................................13 2.5 Conflicts of interest ...............................................................................................13 2.6 Secondary employment or interest in business partners .......................................14 2.7 Data protection and privacy ..................................................................................14 2.8 Documentation of business transactions...............................................................15

3. Dealings with business partners, public authorities and competitors.............................16 3.1 Protection against corruption and bribery..............................................................16 3.2 Gifts and invitations...............................................................................................16 3.3 Donations and Sponsoring....................................................................................17 3.4 Fair competition and anti-trust...............................................................................17

4. Electronic media, systems and publicity........................................................................19 4.1 Intellectual property of third parties .......................................................................19 4.2 Security of information technology and communication devices............................19 4.3 Public relations and confidentiality ........................................................................20

MISCONDUCT AND SANCTIONS.......................................................................................21

GLOSSARY .........................................................................................................................22

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LETTER FROM THE HOLDING BOARD

DORMA is the trusted global partner for premium access solutions & services enabling better buildings.

Dear Colleagues, DORMA as a family-owned business has been established for more than 100 years. The success of our company is based upon our strong corporate culture. We have always felt committed to trustful relationships with our customers, suppliers and employees. Within our DORMA 2020 strategy we formulated this commitment in our four values

� Integrity we do what we say.

� Responsibility we take ownership.

We build mutual trust, fairness and respect in

all our activities and relationships with all stake-

holders. We operate fully within established

company guidelines and we adhere to and re-

spect the equality of our people and cultures,

ethics, morals and legal standards within the

markets that we serve.

We involve, develop and empower our people to

take proactive initiative. We accept accountabil-

ity through every step in process to ensure posi-

tive results. We encourage a culture of open and

transparent communication throughout our or-

ganization. We are committed to meeting our

social and environmental responsibilities.

� Innovation we encourage creative ideas.

� Performance we strive to outperform.

We encourage creative thinking to deliver posi-

tive business development. We take initiative to

question the status quo and to manage the as-

sociated challenges to have a positive long-

term benefit for the company.

We are a high-performance company focusing

on our core business. We empower our employ-

ees to work as a collaborative team in acting in

an entrepreneurial manner that drives measur-

able, positive long-term results that creates

value for generations to come. Through a culture

that embraces dynamic growth, continuous im-

provement and a sense of urgency, we deliver

quality, efficiency and transparency in all our

processes throughout our organization.

We strongly believe that our mission “DORMA is the trusted global partner for premium ac-cess solutions & services enabling better buildings” can only be achieved by respecting our values.

August 2013 Page 5 / 24

Our conviction is that our long-term success is strongly linked to legally and ethically impec-cable behavior. We regard compliance with applicable laws, legal regulations and our inter-nal regulatory framework as a matter of course. Ethical misconduct or legal offenses cause damage to every one of us: shareholders, management and employees. This Code requires that we exercise the highest degree of legal and ethical conduct in all our business practices. It expresses our common understanding of “right and wrong” for our daily decisions and actions. Ultimately, the responsibility for ensuring compliant behavior rests with each of us. We expect personal integrity and appropriate judgment from every DORMA employee in day-to-day business. This requires that each of us is aware of the rules that are relevant in our working field. In this respect, we have developed our DORMA Code of Con-duct, aiming at � empowering our employees in terms of self-responsibility for legally and ethically correct

behavior; � providing protection against legal prosecution and work-law related consequences; � avoiding any loss of reputation for DORMA; � securing our innovative power and creativity; � preventing any loss of working places or threat of existence. We encourage all employees to openly address issues and problems. It is our joint demand to create a working atmosphere which allows honesty and transparency. We know that no set of regulations can cover all situations which we may face. When in doubt about a busi-ness dealing, we should seek advice before acting (see “Contacts for help”). Observed violations against this Code are a serious matter and none of us should hesitate to report it to the management or the appropriate departments (see “Contacts for help”). In the wake of our presence in multiple markets we take over responsibility in different socie-ties and cultures. DORMA feels committed to make a valuable contribution to society. Within the sphere of our influence we will gain the commitment from business partners to comply with the policies in this Code. To ensure that this Code is more than a good concept, it is made available to all DORMA employees, consultants and suppliers. We believe in our DORMA values and are proud to live them through our dealings and so should every DORMA employee, because “You are part of it”. DORMA Holding Board

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GENERAL INFORMATION

1. Objective

Our values are an integral part of our DORMA 2020 strategy. This Code of Conduct gives our employees the orientation about the DORMA’s principles and our values of integrity, re-sponsibility, innovation and performance. The Code aims at supporting every DORMA staff to take appropriate decisions consistent with laws and corporate regulations. 2. Scope of application

Our DORMA Code of Conduct applies to all our DORMA employees, regardless their func-tion or position. The regulations set out in this Code are binding for every DORMA employee. We regard somebody to be a DORMA employee when she or he is working in a company of which the majority of shares is directly or indirectly held by DORMA Holding GmbH + Co. KGaA. We will use our influence on business partners to receive their commitments for the applica-tion of this Code in their companies. 3. Validity

This Code of Conduct comes into force from August 2013 onwards and remains valid indefi-nitely. Any previous versions of Codes of Conduct, especially the CoCoDO, will cease to apply from that date. 4. Communication

Every member of our staff receives this Code of Conduct. Our managers bear special re-sponsibility to increase the consciousness for the contents of this Code among their employ-ees. Every manager must ensure that employees become aware of this Code, understand it and adhere to it. The Code is available as document in different languages, on our homepage “www.DORMA.com” and on the intranet “DORMAWorld”.

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5. Contacts for help

We provide support to our employees whenever they are uncertain about a decision. In case that one or more of the following questions cannot be answered with a clear “yes”, everybody should seek advice. � Does my decision or action comply with applicable law and DORMA regulations? � Is my decision or action viewed as appropriate if objectively evaluated by a neutral third

party? � Is my decision or action taken unbiased from personal interest? � Would I endorse my decision or action if it was my own company? The first source of help can usually be found in the direct working environment, such as the manager or the human resources department. If further advice is required, the following departments are also available for support: Department Telephone number Email contact Group Compliance +49 2333 793 - 6533 compliance@dorma.com Group Legal +49 2333 793 - 3310 legal@dorma.com Data Protection Officer +49 2333 793 - 3310 dataprotection@dorma.com Group Internal Audit +49 2333 793 - 7941 internalaudit@dorma.com Group IT + IT Security +49 2333 793 - 7500 informationsecurity@dorma.com Group Communication +49 2333 793 - 5660 communication@dorma.com We handle your advices and reports with the appropriate confidentiality. No DORMA em-ployee will face disadvantages or discrimination from disclosing misconduct or a suspected violation.

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POLICIES

1. Corporate Responsibility

1.1 Compliance with the law and internal regulations

For us, it is a matter of course to comply with the applicable law and legal regulations on lo-cal, national and international level – wherever we do business.

We regard compliance with applicable local, national and international laws and legal regula-tions as a key factor for success of our business. Our corporate regulations aim to ensure secure business processes and we expect every DORMA employee to comply with our DORMA regulatory framework. In case of doubt, governing law has priority over our DORMA rules, which means that stricter legal regulations must always be observed even when our DORMA rules allow a wider scope. We expect our DORMA managers to acquire a basic knowledge of the applicable law and our corporate regulatory framework in their areas of responsibility.

1.2 Human Rights

We support and respect internationally proclaimed human rights.

We highly respect the personal dignity, privacy and individual rights of our employees, job candidates, customers, suppliers and other stakeholders. It is our declared aim to avoid any kind of discrimination for reasons of age, gender, race or color of skin, nationality, social or ethnic origin, language, sexual orientation, marital status, religion, state of health or disability or any other legally protected status under local law. DORMA will not tolerate mistreatment, harassment or defamation of our employees or busi-ness partners. Within its sphere of influence, DORMA supports and respects the protection of internationally proclaimed human rights and ensures that it is not complicit in human rights abuses. DORMA does not participate in or benefit from any form of forced, compulsory or child labor. With regards to the minimum employment age, we follow the principles of the UN Global Compact and the conventions of the International Labour Organization (ILO).

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1.3 Employment rights

DORMA encourages dialog and strives for an honest communication with all our employees and their representatives.

In terms of freedom of association and the right to collective bargaining, we follow the princi-ples of the UN Global Compact and the conventions of the International Labour Organization (ILO). We abide by applicable national laws regarding fair labor practices, minimum legal pay and other legally guaranteed conditions of employment. When we hire a new employee, we provide a written and understandable working agree-ment. We do not hire employees illegally and ensure that payments for social contribution are paid according to applicable laws. DORMA pays wages and salaries on a regular basis. We do not use deductions from wages as a disciplinary measure. We equally support the development of men and women. We pay women and men equal pay for equal work irrespective of age, race or color of skin, nationality, social or ethnic origin, language, sexual orientation, marital status, religion, state of health or disability. We assure that compensation differences are based on the value of the job performed, the skills, effort and responsibility of the individual or other reasonable factors. The working time of our employees is limited in compliance with governing law; in any case it is limited to a maximum of 60 hours per week. Every DORMA employee is entitled to at least one day off per week. We respect our employees’ legal rights to take time off from work for any legally protected reason such as vacation, maternity protection or parental leave. No DORMA employee may be dismissed for exercising these rights. We grant three working weeks paid holiday for one year service, where no statutory rights exist. We allow a maternity protection period of eight weeks in case governing law rules for a minor protection period. This period increases to ten weeks after five years of employment with DORMA and to fourteen weeks after ten years of employment with DORMA.

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1.4 Safety at work and health

Safety comes first in order to protect our people and assets.

DORMA provides a safe, healthy and secure working environment – for our own employees and employees of business partners working on our sites. We expect our managers to ensure that appropriate health, safety and security practices and procedures are in place in order to comply with applicable laws. We work proactively to remove any workplace hazards. No DORMA employee is allowed to work under influence of drugs or alcohol. Smoking is allowed in smoking areas only. Where protective clothing (e.g. safety shoes, glasses, masks, earplugs, helmets or gloves) is required, we wear such equipment. When operating machines or working in height, we ob-serve safety instructions. We keep driveways and lanes free of obstacles. No open fire or candles are left unattended. We pay increased attention when we maneuver a vehicle inside or outside a production facility.

1.5 Environment

Efficient use of natural resources, energy and land conserves our environment.

DORMA regards the responsible handling of natural resources in the production and distribu-tion of our products and services as part of our corporate responsibility for society. Our corporate program “PACE” strives for the reduced consumption of air, water, energy, materials and space. We encourage every employee to contribute to a sustainable develop-ment and long term savings of resources. DORMA undertakes all measures to avoid any unauthorized release of substances. How-ever, if incidents or plant malfunctions nevertheless occur, it is our goal to initiate the appro-priate emergency response and damage repair measures as promptly and as precisely as possible.

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1.6 Governmental and regulatory authorities

We keep proper, transparent and objectively neutral relations with governmental institutions and public authorities.

We maintain political neutrality when dealing with government members, public officials, po-litical parties or candidates. No DORMA asset may be used to promote interests of political parties or candidates. Our ordinary course of business with public authorities (e.g. approvals and licenses, applica-tions, official notifications) is conducted in a transparent and objective manner. We observe the applicable laws when doing business with governmental institutions and public authorities. Although local customs and practices may differ, DORMA employees con-duct highest ethical behavior in all dealings with governments regardless their location. When receiving any kind of governmental or public inquiry relating to DORMA, our employ-ees must contact their senior management and legal department for assistance prior to tak-ing further action if this report is not in contradiction to governing law. This also applies when employees are asked for expert statements or act as witness in civil or criminal proceedings. Employees who duly respond to inquiries of governmental institutions or public authorities need not fear any employment-related reprisals.

1.7 Quality and product safety

DORMA provides innovative products and solutions that convey safety, convenience and comfort.

We provide impeccable products and services at premium quality. We will never intentionally distribute products which malfunction. DORMA products are developed and manufactured under strict observance of our quality assurance measures. Our products have a broad range of different application and functions – in private and public buildings. We feel committed to comply with all applicable laws and regulations regarding safety of products we sell. We monitor our products in the market and follow up on advices relating to product safety. When necessary, we notify the relevant authorities without delay and undertake all measures including product recalls to ensure our customers’ safety.

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2. Conduct in the workplace

2.1 Responsibility of each DORMA employee

Personal integrity is the core qualification we require.

By complying with applicable legal regulations, every employee is acting in the interest of the DORMA group. We expect integrity and responsibility of every DORMA employee for legally compliant, ethi-cal and honest conduct. Each individual must feel responsible and accountable for his or her own decisions and ac-tions. When in doubt, compliance with the law must be given priority. Every employee can rely upon this policy. This applies even when management staff gives instructions to the contrary.

2.2 Trust, respect and tolerance

Every DORMA employee deserves fair treatment, free from any discrimination.

We build mutual trust, fairness and respect into all our activities at work. We value polite-ness, honesty and tolerance. Every person is entitled to fair, respectful and dignified treat-ment. We do not tolerate any kind of discrimination against any employee, candidate, customer, contractor or supplier. In this respect we also reject any form of harassment, bullying or in-timidation.

2.3 Openness and transparency

We encourage our employees to raise concerns freely without fear of retaliation.

We value a culture of open and transparent communication throughout our organization. Our objective is to create a work environment that enables our employees to voice criticism as it helps to minimize workplace hazards, misconduct and ethical or legal violations. We encourage all employees to report misconduct and violations to their management or to whom they feel is the appropriate contact person (see also “Contacts for help”).

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DORMA protects employees who provide reports of violations in good faith. Intimidation or retaliation against such employees is inacceptable. We expect our managers to take employees’ concerns seriously and deal with such situa-tions unbiased and fairly.

2.4 Use of company property

We handle our company property with highest care.

Every employee is responsible for the careful use of the company’s property. This applies to tangible assets such as land and buildings, cars, machines, furniture, computers and mobile devices, office material, tools, cash on hand or in banks and to intangible assets such as li-censes, patents and copyrights. We handle our company property gently and ensure regular maintenance, reducing wear and tear and avoiding waste of energy. DORMA has acquired and developed valuable intellectual property, including patents, trademarks, copyrighted works and trade secrets (e.g. confidential technical or business in-formation). When developing new products and creating inventions, we expect our managers to involve Group Legal at the earliest possible stage in order to secure legal protection for our inventions. DORMA’s legal department must be involved in any transfer or dispute re-lated to intellectual property. Our company assets are used for the authorized purpose only. Any improper, illegal or other unauthorized use is prohibited. Procurement for private purposes in the name and on account of DORMA is prohibited.

2.5 Conflicts of interest

Our decisions are taken for the best of DORMA free of personal interest.

It is essential that we remain free of commitments and relationships when we act on behalf and in the interest of DORMA. We must avoid situations in which personal interests collide with the interests of DORMA. All our decisions in respect to business relationships with third parties are solely taken in consideration of objective criteria for the best of DORMA.

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Family or friendship relations to business partners may not influence the decision. It is impor-tant that even the appearance of a conflict of interest is avoided. The same applies when family or friendship relations to other DORMA employees are concerned. Any employee who believes that he or she may be affected by a conflict of interest must im-mediately disclose all relevant details to his or her supervisor. In case of doubt, the responsibility and settlement of business transactions with friends or relatives are assigned to a colleague or a different department.

2.6 Secondary employment or interest in business partners

We disclose secondary employment or investments in business partners as they could com-pete with DORMA’s interest.

Every DORMA employee works at the best of his power, ability and knowledge. Any kind of secondary employment or consultancy for another company must be disclosed by the em-ployee in writing and approved by the local management. Employees who directly or indirectly have a financial interest or a participating ownership in a DORMA business partner or competitor (except for shares which are traded on a public stock exchange), must notify the local management in writing and on their own initiative. We encourage our employees to participate actively in society in the form of voluntary work for public offices, clubs and foundations or citizen’s groups, provided that such commitment is not in conflict with the legitimate interests of DORMA.

2.7 Data protection and privacy

We respect privacy and protect personal data of ourselves and others.

We regard the personal data of our employees, candidates and business partners as highly confidential. DORMA ensures that personal information is handled with best care and sensi-tivity. DORMA employees are cautious not to disclose personal data of colleagues or business partners when talking in public. When collecting, retaining, using or transmitting data, we comply with data privacy and pro-tection laws. In case of doubt, our data protection officer must be contacted for advice.

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2.8 Documentation of business transactions

We apply high standards of accuracy and accountability in all our business transactions.

DORMA’s reports and statements about business transactions are true, accurate and clearly structured. Every business transaction is recorded in our authorized accounting systems ac-cording to national and international accounting regulations and DORMA corporate rules concerning financial reporting. Secret accounts are illegal and prohibited. Documentation and contracts relating to business transactions are complete and transparent and must always be available for audit. No manipulation or action concealing improper use of company property may be conducted. Any kind of fraud, theft, embezzlement, money laundry or terrorism financing is strictly pro-hibited. Suspected breaches of financial policy, which directly or indirectly affect DORMA’s business, must be reported and investigated. When providing binding offers, concluding agreements or contracts or making official state-ments, our DORMA approval routine of keeping the four-eyes-principles must be observed.

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3. Dealings with business partners, public authorities and competitors

3.1 Protection against corruption and bribery

DORMA does not tolerate any kind of corruption, bribery, kickbacks or other illegal transac-tions with third parties.

DORMA will not condone corruption or unfair business practices by our employees or third parties commissioned by us. We do not offer or accept any inducements, privileges or bene-fits which could influence a person’s ability to make objective and fair business decisions. DORMA does not tolerate the offer, promise or granting of preferential benefits to or from third parties in order to achieve a business dealing. Our funds may not be used to make payments in money, property or services for the purpose of obtaining or retaining business. Our employees are not allowed to ask for or accept anything of value which influences their decision. DORMA rather forgoes a contract if there was any doubt about the reliability of a business partner or if a business dealing could only be acquired by improper practices. DORMA immediately terminates any cooperation with intermediates, commercial agents, sales representatives or consultants if there is any doubt about their proper conduct of busi-ness practices. DORMA purchases goods and services at market prices. We make payments on the basis of proper invoices stating full business partner’s name and address and detailed description of goods delivered or services rendered. Bank transfers are made to the business partner’s bank account in the country of his / her registration. Exceptional check payments are made payable to the business partner only, never to any private person employed with the business partner.

3.2 Gifts and invitations

Gifts and invitations are handled openly and restrictive in value.

Gifts and invitations serve the care of relationships with our business partners. DORMA al-lows the acceptance and offer of gifts and invitations only if no compulsion for a business deal is caused. We handle the acceptance or offer of gifts and invitations with transparency.

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Gifts or invitations as benefit for a business deal are prohibited. They may never be used as vehicle to circumvent the anti-bribery rules of this Code. The offer or acceptance of a gift in cash or cash-equivalent is prohibited. The value and circumstances of a gift or invitation must correspond to the position of the do-nor and the receiver. When become public, the benefits may not damage DORMA’s reputa-tion or embarrass the employee. If an employee is in doubt whether a gift or invitation could appear as improper benefit, he or she must seek advice from Group Compliance.

3.3 Donations and Sponsoring

We use donations and sponsoring for the support of common welfare only, never for im-proper purposes.

DORMA contributes to the goodwill of society by donating or sponsoring to non-profit asso-ciations and organizations. In no case, DORMA will tolerate donations or sponsoring as vehi-cle to circumvent the anti-bribery rules of this Code. Whether or not local laws restrict the use of corporate funds in support of political activities, DORMA refrains from financially supporting governments, political parties, organizations or candidates.

3.4 Fair competition and anti-trust

We generate our success from free market entries and do not tolerate competitive-restrictive behavior.

DORMA aims to be the trusted global partner for premium access solutions and services enabling better buildings. In this respects, we support a free market and regard fair competi-tion as best instrument for our growth and corporate success. DORMA complies with applicable anti-trust and competition laws. DORMA will not participate in business practices which inhibit free trade or competition, such as agreements with competitors about price fixings, boycotts of certain suppliers or custom-ers, market allocations or limitations of sales and productions. Our employees disclose no sensible information when meeting with competitors.

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Dealers selling DORMA products on their own behalf and own account are free in their pric-ing strategy. Submissions for tenders and biddings are strictly based upon DORMA’s calculations, free of any illegal agreements with competitors. In no case, DORMA will use meetings of industry associations to illegally agree on competi-tion-restrictive practices with other members. Our employees take special care when asso-ciation meetings discuss topics such as benchmark comparisons, market strategies, product and service details, delivery conditions, norms and standardizations or similar. In case of doubt, our employees discontinue the participation in the meeting and record their protest.

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4. Electronic media, systems and publicity

4.1 Intellectual property of third parties

We respect the intellectual property rights of third parties.

DORMA will not copy, distribute or display intellectual property unless the owner or license holder of such property has directly or indirectly granted permission to do so. DORMA will license one software package per employee-user, except when the license pro-vides otherwise or permits a network version of the software to be used. DORMA will refrain from any action that aims to illegally obtain property rights, protected content or confidential information from third parties.

4.2 Security of information technology and communication devices

We protect our IT equipment against misuse and data loss.

We provide our employees with IT facilities and communication devices to perform their tasks efficiently and allow mobile computing. By doing so, DORMA is exposed to risks such as virus infection of hard- and software, data loss or theft, misuse of data by third parties and similar hazards. We expect our employees to regularly change passwords and keys to avoid unauthorized access to our computer network and communication devices. Passwords are safely kept. The disclosure of passwords to other persons, either within or outside DORMA, is not permit-ted. DORMA does not tolerate the installation of unauthorized software or the upload of unauthor-ized applications onto corporate property. Our employees are cautious not to disclose confidential information to any unauthorized third party, when using computer and media equipment in public. Computer screens and displays of mobile devices must be kept invisible for unauthorized persons. When “surfing” on the internet, we do not access websites with racist, defamatory, porno-graphic, obscene, abusive or other illegal contents.

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4.3 Public relations and confidentiality

We keep sensitive information confidential and seek approval before we communicate with media.

We handle confidential information with care. No information-sensitive material may be dis-closed to unauthorized persons, neither to third parties nor to other DORMA employees. This also applies after the termination of employment. Before confidential information is given to third parties (e.g. consultants, freelancers, due dili-gence lawyers) a non-disclosure agreement must be signed by both sides. During telephone calls in public, information level must be kept to a minimum, avoiding the mentioning of names of persons or companies, projects, product descriptions, figures and any other sensitive information. Media requests for interviews, statements or articles may only be answered after consulta-tion of Group Communication. Any visit of media companies to DORMA sites and facilities must be announced in advance and be permitted by Group Communication. No access to DORMA sites may be allowed when employees of radio or television stations, newspapers or magazines arrive without invi-tation or prior announcement. When we present facts and figures about DORMA in public (e.g. seminars, conferences and trade fairs), slideshows or documents may only disclose contents which are publicly available on our homepage or in official company’s brochures and other information material.

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MISCONDUCT AND SANCTIONS

We strongly believe in our values and bring them to life in our day-to-day business. Our ap-proach to honest and fair business practices is reflected in our behavior, contracts and deal-ings. When misconduct is observed or offences are perceived, every one of us should have the trust and courage to report the issue to the management or to Group Compliance. We handle reports about possible violations with sensitivity and discretion. No employee must fear dis-advantages when disclosing deficits. Any misconduct or offense against this Code causes irritation among colleagues, can lead to fines and penalties for DORMA or to a loss of our good reputation. It threatens the success of our company and departs from our strategy “DORMA 2020”. Consequently, we will not tolerate the breach of policies set out in this Code. Being employed with DORMA means that the policies of this Code are binding. We will not hesitate to take actions against any employee when he or she violates governing law or corporate regulations. Misconduct can lead to severe outcome for every one of us, such as labor-law related consequences up to the loss of employment. Additionally, legal offenses can follow to monetary fines or civil or criminal prosecution in the worst case.

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GLOSSARY

Bribery

Bribery is defined as the act of taking or receiving something with the inten-

tion of influencing the recipient in some way favorable to the party providing

the bribe. Bribery is illegal and can be punishable by jail time or stiff fines if

authorities find out about the bribe.

Bullying

Bullying is the use of force or coercion to abuse or intimidate others.

Business Partner A business partner is a counterpart in a commercial dealing, such as a sup-

plier, a customer, a consultant, an intermediary (agent, broker or reseller), a

licensee or licensor. A business partner can be a company / corporate body

or a single person.

Cash equivalent

Cash equivalents are assets that are readily convertible into cash, such as

checks, coins, gold and other precious metals, etc.

Corruption

Corruption in a legal sense means the misuse of a position of trust in ad-

ministration, justice, commerce and politics or in non-government organiza-

tions and associations in order to achieve a material or immaterial benefit

without legal cause. Corruption occurs actively and passively by granting

and accepting undue advantages.

Embezzlement

Kind of financial fraud: act of dishonestly withholding assets for the purpose

of conversion (theft) of such assets by one or more individuals to whom

such assets have been entrusted, to be held and/or used for other pur-

poses.

Embezzlement sometimes involves falsification of records in order to con-

ceal the activity.

Fraud

Intentional deception made for personal gain or to damage another individ-

ual or organization.

The specific legal definition varies by legal jurisdiction. Fraud is a crime, and

also a civil law violation.

Harassment

Harassment covers a wide range of behaviors of an offensive nature in-

tended to disturb or upset, and it is characteristically repetitive. In the legal

sense, it is intentional behavior which is found threatening or disturbing.

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Human Rights

Human rights are commonly understood as "inalienable fundamental rights

to which a person is inherently entitled simply because she or he is a hu-

man being."

Human rights are thus conceived as universal (applicable everywhere) and

egalitarian (the same for everyone). These rights may exist as natural rights

or as legal rights, in both national and international law.

The Universal Declaration of Human Rights (UDHR) was adopted by the

United Nations General Assembly in 1948. The UDHR urges member na-

tions to promote a number of human, civil, economic and social rights, as-

serting these rights as part of the "foundation of freedom, justice and peace

in the world." The declaration was the first international legal effort to limit

the behavior of states and press upon them duties to their citizens following

the model of the rights-duty duality.

International Labour

Organization / ILO

The International Labour Organization (ILO) is a United Nations agency

dealing with labor issues, particularly international labor standards and de-

cent work for all. Almost all (185 out of 193) UN members are part of the

ILO. For more details please see http://www.ilo.org/.

Intimidation

Intimidation (also called cowing) is intentional behavior that "would cause a

person of ordinary sensibilities" fear of injury or harm.

Kickback

A kickback is an illegal, secret payment made in return for a referral which

resulted in a transaction or contract. A kickback is a form of negotiated brib-

ery in which a commission is paid to the bribe-taker in return for services

rendered.

The most common form of kickback involves a vendor submitting a fraudu-

lent or inflated invoice (often for goods or services which are too expensive,

not needed, of inferior quality), with an employee of the victim company as-

sisting in securing payment. For his or her assistance in securing payment,

the individual receives some sort of payment (cash, goods, services) or a

favor e.g. the hiring of a relative, employment, sponsorship etc.

Maternity protection

period

Maternity protection period is defined as a period of absence for a female

employee immediately before and after giving birth.

Money laundry

Money laundering is the process where cash raised from criminal activities

is made to look legitimate for re-integration into the financial system con-

cealing the source of money obtained by illicit means. The methods by

which money may be laundered are varied and can range in sophistication.

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Personal Data

Personal data is any information that relates to a person and which is suit-

able to directly or indirectly indentify this person, such as name, address,

date of birth, family status, health condition etc.

Terrorism /

terrorist financing

Terrorist financing refers to the processing of funds to sponsor or facilitate

terrorist activity. The terrorist financer will want to disguise the illegal end of

the funds, while trying to maximize the revenues for the organization spon-

sored.

UN Global Compact

The United Nations Global Compact, also known as Compact or UNGC, is

a United Nations initiative to encourage businesses worldwide to adopt sus-

tainable and socially responsible policies, and to report on their implementa-

tion. The Global Compact is a principle-based framework for businesses,

stating ten principles in the areas of human rights, labor, the environment

and anti-corruption. For more details please see

http://www.unglobalcompact.org/.