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 Preamble
The present Compliance Policy, issued in accordance with article 12 of the “Emittenten-Compliance-Verordnung” (Compliance Decree for Issuers) applies to all employees of UNTERNEHMENS INVEST AG (UIAG), as well as to all members of the management of those companies, which are to be considered as associated companies to UIAG pursuant to § 228 Para. 3 Austrian Commercial Code (UIAG and its group companies and subsidiaries), and to other specified individuals, who have been contracted to work on behalf of UIAG (external third parties). For this reason, UIAG is obliged, according to the provisions of the Stock Exchange Act, to inform its employees and other persons acting for itself and its subsidiaries on the legal prohibition of misuse of inside information; furthermore, to issue policies for the dissemination of information within the company, to monitor compliance with these policies, and to undertake measures to prevent insider offences, which hereby takes place.
The procedures and organizational measures contained in this policy are binding to an unlimited extent on all persons acting on behalf of UNTERNEHMENS INVEST AG (including the Board of Management and Supervisory Board), as a supplemental contractual agreement within the context of the existing contractual and relationships and these persons must strictly adhere to the regulations contained in this Compliance Policy. By signing the declaration of undertaking of this Compliance Policy, the validity of this procedure shall be regarded as expressly agreed with respect to all persons acting on behalf of UNTERNEHMENS INVEST AG.
All external third parties, acting for and within the confidentiality area have to sign a confidentiality declaration and submit it to the compliance officer for documentation.
Companies of UIAG-Group that are listed or obliged (according to the provisions of the Stock Exchange Act) to issue a Compliance Policy, do have their own - applicable for the respective company - Compliance Policy and assign a compliance officer in accordance with article 12 ECV. Those companies are included into the Compliance Policy of UIAG to the extent that Information provided by UIAG as a holding, might include data of the respective company that may be considered insider information in accordance with item 3 of this Compliance Policy and are subject to the explanations that follow.  Article 82 para. 5 BörseG (Stock Exchange Act) requires all issuers to undertake the following measures for impeding insider dealings:
1: Informing employees and other persons acting for the company regarding the prohibition of disclosing inside information;
2: Issuing internal policies for the dissemination of information within the company and monitoring compliance with them;
3: Undertaking suitable organisational measures to prevent misuse or dissemination of inside information.
The “Emittenten-Compliance-Verordnung” (Compliance Decree for Issuers) shall substantiate the regulations of the Stock Exchange Act, and prevent the misuse or transmission of insider information.
These policies aim in particular at protecting the bodies and employees of listed companies, since they were adopted to avoid that these bodies and employees must bear the not inconsiderable consequences in connection with the misuse of inside information, arising from the fact that they are unaware of the legal framework or implement it wrongly.   3.1 Elements of the criminal offence of insider trading
Article 48 b para. 1 Stock Exchange Act declares trading with financial instruments while taking advantage of confidential information, the recommendation to buy or sell based on the same and the dissemination of information without an obligation to do so a criminal offence. As an extension to this, Article 48 r Stock Exchange Act provides for banks, insurance companies and pension funds and Article 82 para. 5 Stock Exchange Act for issuers that all operational measures are undertaken to prevent taking advantage of confidential information for securities trading.
Anyone who, as an insider, takes advantage of inside information, with the intent to gain a pecuniary benefit for himself/herself or a third party, by  | buying, selling, offering a third party for purchase or sale, recommending (Section 1) financial instruments affected by this, or
| | making this information accessible to a third party, without being obliged to do so (Section 2)
| | may be punished by a court of law, with imprisonment of up to three years, however, if a pecuniary benefit is gained by the activity, which exceeds EUR 50,000, by imprisonment on one to ten years (Article 48a para. 1 Stock Exchange Act). |
Anyone who, without being an insider, utilizes inside information received or otherwise obtained in a manner described in the previous paragraph to gain a pecuniary benefit for himself/herself or a third party, may be punished by a court of law with imprisonment of up to one year or with a fine of up to 360 daily rates, however, if a pecuniary benefit is gained by the activity, which exceeds EUR 50,000, by imprisonment of six months to five years (Article 48a para. 2 Stock Exchange Act).
Anyone else, as an insider or without being an insider, who utilises gained information, knowing or grossly negligently not knowing that it involves inside information – however without the intent of gaining a pecuniary benefit for himself/herself or a third party – is punishable by a court of law with up to six months’ imprisonment or a fine of up to 360 daily rates.
Inside information is defined as information of a precise nature which has not been made public, relating directly or indirectly, to one or more issuers of financial instruments or to one or more financial instruments and which, if it were made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of related derivative financial instruments, as an informed investor would probably make use of it, partly basing his investment decisions on it.
Financial instruments, within the meaning of the legal regulations, are specifically shares, provisional certificates, participation certificates, financial futures contracts, money market instruments and debenture, all other instruments, to the extent that they are admitted for trading on the regulated market (Sect. 48a para. 1 L 3 BörseG).
3.2 Definitions
a) Definition of “insider”
The term, “insider” as specifieed in Article 48b Stock Exchange Act is interpreted broadly. Accordingly, all persons acting for UNTERNEHMENS INVEST AG, including the members of the Board of Management and the members of the Supervisory Board of UNTERNEHMENS INVEST AG, as well as its lawyers, auditors, tax advisors, employees of the PR agency and printing company, etc., as well as major shareholders and their representatives are deemed as insiders.
Regardless of its equity interest, a major shareholder is regarded as every shareholder, who obtains information earlier and more extensively than the regular small investor, due to his/her number and type of shares (e.g. right to nominate candidates to the Supervisory Board). In this case, insiders are the respective bodies and employees or advisors of the major shareholder, as the Penal Code applies to natural persons.
Finally, anyone who has gained information by committing punishable acts is also an insider. If it involves a legal entity, those natural persons are regarded as insiders, who are involved in the decision to carry out the transaction on behalf of the legal entity.
a) Definition of “insider information”
Insider information is defined as precise information, which is not publicly known, which directly or indirectly relates to one or several issuers of financial instruments, or one or several financial instruments and which, if it were publicly known, would be suitable for significantly influencing the price of these financial instruments or the price of derivatives related to them, because a knowledgeable investor would probably utilise it as part of the basis of his/her investment decisions (“price relevance”).
Insider information must
| relate to knowledge of specific information (in contrast to opinions and rumours);
| | relate to an issuer or a financial instrument within the meaning of Article 48a para. 1 lit. 3 (Stock Exchange Act), i.e. securities within the meaning of the Directive 93/22/EEC, shares in organisations for joint investments in securities, money market instruments, financial futures contracts, including equivalent cash-settled instruments, forward rate agreements, interest rate and foreign exchange swaps, as well as swaps on shares or equity swaps, call and put options on all previously mentioned instruments, including equivalent cash-settled instruments; these particularly include currency and interest rate options; commodity derivatives, all other instruments that are admitted for trading on a regulated market in a Member State or for which an application has been submitted for admission to trade on such a market;
| | only be known to a limited group of persons and not yet be accessible to the investors (“confidentiality”) and
| | be suitable for significantly influencing the price, if it were publicly known (“price relevance"). |
(i) Definition of “Precise Information”
Information is deemed precise if it comprises a number of already available facts and events or such facts and events which can be expected to happen in all likelihood in the future and which, in addition, is specified enough for a conclusion to be drawn on the potential effects of said facts or events on the prices of financial instruments or .on the price of related derivative financial instruments.
The pure linking of generally known data and the drawing of conclusions from this does not fall under this. Therefore, the investment recommendations by banks, which are based on financial analyses, which, in turn, are based on generally known facts, are not regarded as inside information.
(ii) Definition of “confidential fact”
A fact is confidential, as long as it is not accessible to interested parties in stock exchange trading as information that is known to the interested public. Generally, this will be the case, when only a limited number of persons, e.g. the Board of Management and a few selected employees/the auditor or the lawyer of the issuer, have knowledge of this fact.
(iii) Definition of “price relevant”
Any information is price relevant, which appears suitable for significantly influencing the price of a security.
With options and financial futures contract, under certain circumstances, minor price movements in the underlying security can be significant, while with trading in shares and bonds, significant influencing of the price can only be assumed with extraordinary price changes, measured on the historical volatility of the price. The law is indeterminate in this respect. Internationally, there are also no respective fixed boundaries.
In case of doubt, it is therefore advisable to regard inside information as being suitable, which can significantly influence the price and corresponding measures are to be undertaken. According to the explanations on BörsenG, information is price relevant, if a knowledgeable investor would use it as part of the basis for his/her investment decision. With this, it is assumed that a knowledgeable investor will also utilise information as the basis for his/her investment decision, with price-influencing potential that lies below the significance threshold. Therefore, as a precaution, any transaction should be refrained from, if someone possesses information that is not publicly known.
Accordingly, insider information includes, for example, notifications regarding: | Buy orders, sell orders and exchange orders (public buy, sale offerings (secondary offerings) and exchange offerings for listed shares, takeover or settlement offerings), which relate to UNTERNEHMENS INVEST AG,
| | corporate law measures (issues, corporate actions, such as capital increases, reductions, adjustment, changes of legal form, mergers with other companies, acquisition of other companies, changes to dividend policy, amount of proposed dividends, bankruptcy, settlement, corporate reorganisation proceedings, significant changes to the shareholder structure),
| | the business activity and the asset, financial and profit situation of UNTERNEHMENS INVEST AG / UNTERNEHMENS INVEST AG (these include, e.g. extraordinary change to the Board of Management, extraordinary investments, development of new products and services, significant new inventions or development results, concession and/or granting of licences and patents, share or company acquisitions and sales, extraordinary changes to the number of personnel, interruptions in the business activity, court and arbitration board proceedings outside of the ordinary course of business, official investigations, threats of legal action, developments of proceedings, important financial data, such as profit, sales, cashflow, committing to extraordinary liabilities, serious changes to the cost and price situation, change in profit forecasts, change in company results). |
In contrast, information that is already publicly known, regardless of the suitability of this information to influence the price of the traded securities, can be used. Information is regarded as being publicly known, when knowledge by the interested public (see details below) is established.
c) Regarding Dissemination of Insider information
As already described, it emerges from Article 48b para. 1 Stock Exchange Act, that in addition to trading in securities and the issuing of selling or buying recommendations to third parties, the dissemination of information is also prohibited, to the extent that these activities take place with utilisation of inside information.
Utilisation of inside information through the buying or selling of financial instruments is only given, when it involves securities, which are listed for official trading or are traded in regulated unofficial trading, regardless of whether the transaction is on the stock exchange or off-market.
A recommendation to buy or sell securities is advice or the recommendation to sell, which is given to a third party with the intent of gaining a pecuniary benefit for this third party (e.g. a Member of the Board of Management does not buy shares himself, but rather, recommends the purchase to a relative).
Pursuant to Article 48a Stock Exchange Act, the dissemination of inside information without an operational necessity to do so is prohibited.
Therefore, the compulsory (exceeding the confidentiality area) dissemination of order information pursuant to item 4 is unobjectionable.
Disseminating information to specific authorised third parties of UNTERNEHMENTS INVEST AG (e.g. to consultants, chartered accountant or lawyers and authorised PR agencies) is also unobjectionable, to the extent that the authorised third parties have been informed about the insider penal code by UNTERNEHMENS INVEST AG and compliance with these procedural instructions have been verifiably agreed within the scope of authorising these third parties.
d) Sanctions in the case of insider trading
In addition to the above imprisonment and fines for deliberate (Article 48a para. 1 Stock Exchange Act)/conscious (Article 48a para. 3 Stock Exchange Act) violations against the insider penal code, a person acting on behalf of UNTERNEHMENS INVEST AG must bear in mind that he/she can be held personally responsible for violations of the insider penal code under tort. Furthermore, violations of the insider penal code can have labour law consequences, which can extend as far as dismissal.
3.3 Information Regarding the Prohibition of Unauthorised Dissemination of Inside information
On the basis of appointment by the Board of Management, the person responsible for compliance at UNTERNEHMENS INVEST AG (hereafter referred to as “Compliance Officer”) must ensure that the members of the boards and persons acting on behalf of UNTERNEHMENS INVEST AG, who can gain inside information on the basis of their activity, have been informed about the prohibition to disseminate inside information, in writing and verifiably. This takes place by means of the respective person signing this Compliance Policy.  4.1 Confidentiality Area
UIAG is the holding company for its group companies or subsidiaries and thus solely manages its shareholdings.
Confidentiality areas are either permanent or temporary (project-related) corporate areas, where persons have regular or occasion-related access to insider information.
In addition to the Members of the Board of Management, the Members of the Supervisory Board, and employees that are assigned either organizationally or functionally to a confidentiality area of the group, also persons acting on behalf of the company (tax advisors and auditors, lawyers, printing company, advertising companies) are included in the permanent confidentiality area of the company.
The Board of Management and the Compliance Officer must inform the persons belonging to the confidentiality area, in a suitable manner and verifiably, that they are active in an area, in which inside information also typically occurs.
Temporary (project-related) confidentiality areas have to be established if it is expected that insider information originates from a certain (one-time) project. The manager of the project is responsible to establish the temporary confidentiality area. The project manager is also responsible for the notification of the one-time activity and its relevant information (objective, scope, timeframe, internal and external team members).
All external third parties, acting for and in a temporary confidentiality area, are obliged to sign a confidentiality declaration and submit it to the compliance officer for documentation.
4.2 Delimitation of the Confidentiality Area
The dissemination of insider information within the confidentiality area is admissible for all persons acting on behalf of UNTERNEHMENS INVEST AG, within the scope of obligatory information.
Each member of the responsibility area must immediately notify the Compliance Officer of all inside information that has become known for the first time within the company and is identified as such.
As soon as insider information is disseminated outside of the confidentiality are, the Compliance Officer must be immediately informed.
The dissemination of insider information to persons outside of the company is only admissible if (1) this is necessary for company purposes, (2) the dissemination is limited to the absolutely necessary extent and (3), the person outside of the company – to the extent that he/she is not already obliged to maintain confidentiality – is obliged, within the scope of an agreement to keep inside information secret and exclusively use it for the designated purpose.
If it is questionable in a situation, whether insider information exists at all, or whether disseminating it is necessary for internal company reasons, or if the risk of uncontrolled dissemination or uncontrolled exchange of inside information exists, then – as far as possible – the Compliance Officer is to be consulted at an adequate time prior to the planned dissemination of information. The Compliance Officer shall decide independently on the question submitted. He/she can consult with the remaining members of the confidentiality area.
4.3 General Measures for Maintaining Secrecy Regarding Inside information
Documents containing inside information are to be marked with the note, “confidential”. Documents and external data media, particularly DVDs and CD-ROMS, USB-drives and electronic documents (e-mail, digital archives) with inside information, must always be stored, such that they are not accessible to unauthorised persons.
Computer programs and files on IT system, with which insider information is processed and in which insider information is stored, may only be accessible with user IDs and passwords. Persons working on data processing systems with inside information must switch off the data processing system when leaving their workstations, such that access to the programme and the files is no longer possible.
For sensitive projects, dedicated confidentiality areas are to be set up and code names designated.
For the purpose of efficient self-monitoring, all information contained on the website or accessible information should be coordinated with the Board of Management and the Compliance Officer, prior to disclosure.
Article 6 para. 3 ECV (Issuer Compliance Decree): As soon as inside information has been disseminated from a confidentiality area, the Compliance Officer must be immediately informed. The report to the Compliance Officer shall contain the contents of the information, name of the person reporting, the point in time at which the notification is received, as well as the names of those individuals, who already know about the inside information or are intended to gain knowledge of it.
4.4 Monitoring
The Compliance officer will regularly monitor the measures for preventing the non-traceable dissemination of inside information, outside of the confidentiality area defined above. If violations of this policy should be determined, the responsible persons are to be ascertained. Furthermore, the Board of Management Members, who are responsible for initiating steps under labour law, are to be informed. The legal measures and the result of the investigations are to be documented in writing by the Compliance Officer.  5.1 The Compliance Officer
The Compliance Officer of UNTERNEHMENTS INVEST AG is Ms. Andrea Salchenegger.
In her function, the Compliance Officer reports directly and exclusively to the Board of Management of the company and is not subject to instructions by any other persons acting on behalf of the company, in this function. She is responsible for the ongoing fulfilment and thorough monitoring of all tasks assigned to her under this policy, however she is not the responsible officer within the meaning of Sect. 9 VstG (Administrative Offences Act).
The Compliance Officer is obliged to carry out the ongoing monitoring of adherence to this Compliance Policy. For this purpose, she is entitled to carry out random sample checks of compliance with these provisions.
In particular, the following tasks lie within the responsibility of the Compliance Officer:
a) Advising and supporting the Board of Management of UNTERNEHMENS INVEST AG in matters regarding the Issuer Compliance Decree;
b) Submitting regular reports (e.g. monthly, quarterly or half-yearly reports) to the Board of Management of UNTERNEHMENS INVEST AG in matters regarding the Issuer Compliance Decree;
c) Preparation of an annual activity report on the past fiscal year, in matters regarding the Issuer Compliance Ordinance; this annual report must specifically include: | project-related confidentiality areas;
| | the number of exceptions granted and not granted in respect of the trading prohibition pursuant to Point 5.3;
| | the number of transaction notifications included pursuant to Point 8;
| | violations of internal company instructions issued on the basis of the Issuer Compliance Decree, as well as resulting consequences;
| | training and education measures carried out. |
d) Training and education of the persons acting on behalf of UNTERNEHMENS INVEST AG in the confidentiality area;
e) Instructing the persons acting on behalf of UNTERNEHMENS INVEST AG, regarding the prohibition of misusing inside information.
5.2 Insider List
The Compliance Officer is required to keep and regularly update an Insider List, in which the following details must be included:
a) Creation and updating date of the Insider List;
b) First name and surname of those persons, who are active in the confidentiality area;
b) Date of birth and place of residence of those persons, who are active in the confidentiality area;
d) Legal entities from confidentiality areas, specifying the company/business relationship and, if known, the company registration number;
e) Start and end of these persons’ membership in the respective confidentiality area;
f) Applications from persons acting in the confidentiality area, to which the Compliance Officer grants an exemption from trading prohibition within a lockup period; this includes recording:
(i) Name of the applicant
(ii) Description of the financial instrument
(iii) Extent and reason provided by the employee for the securities transaction
(iv) Details of whether a purchase or sale of financial instruments of UNTERNEHMENS INVEST AG was intended
(v) Decision by the Compliance Officer and the relevant circumstances
All persons acting on behalf of UNTERNEHMENS INVEST AG are hereby expressly informed that the Compliance Officer must keep such an Insider List, containing the details outlined above.
UNTERNEHMENS INVEST AG and the Compliance Officer must grant access to the Insider List, to the financial market supervisory authority, upon request.
5.3 Lockup Periods and Trading Prohibitions
In the case of gaining knowledge of inside information, members of the confidentiality area shall not be permitted to carry out any transactions in financial instruments of UNTERNEHMENS INVEST AG, until disclosure of this information pursuant to item 7.1 of these procedural instructions. In cases of doubt, the Compliance Officer should be consulted.
Within 6 weeks prior to the planned publication of the annual (preliminary) company results and within 3 weeks prior to the planned publication of (preliminary) half-yearly or quarterly figures, persons who were involved in the publication of this financial information or coordination of insider-related financial information, are not permitted to buy or sell shares or securities of UNTERNEHMENS INVEST AG, unless the Compliance Officer grants explicit permission in an individual case. The Compliance Officer must document all applications, which relate to intended securities transactions within lockup periods. The Compliance Officer shall have a right to define additional lockup periods, in consultation with the Board of Management of UNTERNEHMENS INVEST AG.
These regulations relate to any purchase or sale of financial instruments of UNTERNEHMENS INVEST AG, regardless of whether this purchase or sale involves a transaction on the stock exchange or an off-market transaction.
The purchase or sale of shares or securities by members of the confidentiality area is equated to orders regarding financial instruments, which are issued by (1) persons from the confidentiality area on behalf of and/or for the account of a third party, (2) third parties, on behalf of and/or for the account of persons from the confidentiality area and by (3) companies, in which the persons from the confidentiality area hold a controlling share (generally, 50% of the respective company).
Acquisitions of securities issued by UNTERNEHMENS INVEST AG are not included in this prohibition, to the extent that they take place within the context of employee share schemes, which do not exceed the limit of Sect. 3 para. 1 L 15 EstG (Income Tax Act). Employee shareholdings, which exceed this limit, are to be coordinated in the individual case or generally with the Compliance Officer. In an individual case, the Compliance Officer can introduce a notification obligation for such employee transactions.  6.1 Facts pursuant to Article 48d BörseG (Stock Exchange Act)
UNTERNEHMENS INVEST AG must immediately disclose inside information (see item 3.2), which directly relates to it, to the public. The occurrence of a series of circumstances of an event – although not formally ascertained – must be immediately disclosed by the issuers, to the extent that formal ascertainment is anticipated. All significant changes with regard to already-disclosed inside information are to be immediately disclosed after the occurrence of these changes.
All persons acting on behalf of UNTERNEHMENS INVEST AG shall be obliged to immediately report such new information to the Board of Management and the Compliance Officer. Under certain circumstances, the new elements of these disclosure obligations also include information about internal company planning and decision processes, if it already involves “precise information” within the meaning of Article 48a para. 1 L1 Stock Exchange Act.
In the case of multi-level internal company decision processes, the Compliance Officer must decide whether the existence of a decision by a decision-making body already constitutes inside information to be disclosed pursuant to Article 48d Stock Exchange Act, notwithstanding the lack of consent by another decision-making body.
6.2 Inadvertent Disclosure of Price-Relevant Details
If inside information is inadvertently (differently than described in item 7.1) passed on, the Compliance Officer and the Board of Management are to be immediately notified. The party, who has been inadvertently informed, is to be advised of his/her capacity as an insider. Until disclosure pursuant to item 7.1 of these procedural instructions, he/she is to be subjected to a lockup period for disseminating information and carrying out relevant securities transactions and informed about the significance of the insider penal code. This applies to insider information regarding UNTERNEHMENS INVEST AG, as well as for ongoing projects. If a time period of several days should lie between the point in time of disclosure and the inadvertent dissemination of inside information, the Board of Management, in consultation with the Compliance Officer, shall have a right to apply to Wiener Börse AG for suspension of trading for securities issued by UNTERNEHMENS INVEST AG.
UNTERNEHMENS INVEST AG must ensure that lockup periods are imposed and that persons from the confidentiality area are not permitted to place orders for securities of UNTERNEHMENS INVEST AG / UNTERNEHMENS INVEST AG within (1) three weeks prior to disclosure of the quarterly figures and (2) within six weeks prior to disclosure of the annual figures.
In consultation with the Board of Management, the Compliance Officer shall be entitled to define additional lockup periods, which can be restricted to the entire confidentiality area, as well as on individual persons from the confidentiality area.
Exemptions from the trading prohibition during the lockup period can be granted by the Compliance Officer to individual persons in the confidentiality area, in particularly justified cases, related to the personal circumstances of the individual. All applications for intended securities transactions within these lockup periods are to be precisely documented by the Compliance Officer.  7.1 Form and Recipients of the Information
According to Article 48, para 1 of the Stock Exchange Act issuers of financial instruments are obliged to provide insider information that directly affects them to the public promptly and simultaneously. Content and publication, resp. means of publication of ad-hoc disclosures are described in the Veröffentlichungs- und Meldeverordnung (Disclosure and Reporting Regulation) of the Austrian Financial Market Authority (FMA), and in Article 82, para 7ff of the Stock Exchange Act.
7.2 Non- Exclusive Information
Insider-relevant facts may neither be exclusively provided to selected journalists, analysts, shareholders, a bank or similar groups, nor “off the record” to such persons. However, this does not mean that individual discussions with analysts, media, etc. are prohibited. On the contrary, these are permitted, however they must not contain any inside information. In contrast, information known to the public may be explained in detail and extensively in such discussions and dealt with in a significantly more in-depth manner.  Article 48d para. 4 Stock Exchange Act requires that individuals, who are Members of the Management Board at UNTERNEHMENS INVEST AG or carry out management functions, as well as persons in a close relationship with these individuals, must notify and immediately disclose all transactions carried out by them with shares admitted for trading on regulated markets or derivatives, or other financial instruments of the issuer related to these, or with companies affiliated with the issuer (Article 228 para. 3 UGB (Commercial Code).
The notification to the FMA must take place within five business days after the date of conclusion, however it can be deferred, until the total contracted sum of the transactions exceeds the amount of five thousand euros. If this amount should not be reached by the end of the calendar year, the notification can be omitted.
According to the provisions of the Corporate Governance Code, the transaction notifications pursuant to Article 48d para. 4 Stock Exchange Act are to be disclosed on the website of the respective issuer.
The respective persons obliged to carry out notification, must send all such notifications pursuant to Article 48d para. 4 Stock Exchange Act to the Compliance Officer in writing (copy).  Any violation of these procedural instructions can result in consequences under civil, penal and/or stock exchange law. It is furthermore pointed out that violations can be prosecuted with suitable professional measures, which can range from mere instruction or warning, right up to dismissal, in the case of repeated or particularly serious violations.
The provisions of these procedural instructions are to be interpreted, such that the greatest possible conformity exists with the wording and purpose of the insider and compliance provisions of the Stock Exchange Act.
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You can download the full Compliance Policy here as a PDF.
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