State April 2023
Business Conduct Guidelines
Over the years the Starrag Group has built up an excellent reputation based on credibility and reliable performance. Underpinning these attributes are the principles of mutual respect, honesty and integrity, which guide our day-to-day work. These Business Conduct Guidelines of the Starrag Group therefore are crucially important. They set out the fundamental parameters governing our actions not only within the company, but also with respect to our external partners and the public, and provide a framework for the decisions we take on a daily basis.
STARRAG Whistleblower System
Compliance with and adherence to rules, laws and internal regulations is a top priority for the STARRAG Group ("STARRAG"). Any misconduct must be identified at an early stage, dealt with and stopped immediately.
However, STARRAG also relies on the attentiveness of everyone involved. This also includes the will to point out possible violations of rules in case of specific indications. A whistleblower system specially created for this purpose enables the submission of such information at any time in German, English, French or Chinese, in consideration of the principle of confidentiality.
The whistleblower system guarantees the greatest possible protection for whistleblowers, those affected, and the employees involved in clarifying the information. We promise not to take any measures to identify anonymous whistleblowers who do not abuse our whistleblowing system. Discrimination and retaliation against whistleblowers and anyone who helps promote proper conduct at STARRAG will not be tolerated. Those affected are presumed innocent until the violation is proven. Investigations will be conducted with the highest level of confidentiality. Information will be handled in a fair, expeditious and protected process as follows:
Please note that STARRAG's whistleblower system is not intended for everyday issues, but in particular for criminal offenses such as corruption and other material breaches of rules.
In addition to STARRAG's Compliance Officer (in the person of the CFO of the STARRAG Group), an external law firm (Silk Attorneys at Law in Zurich, Switzerland) has been mandated as a neutral intermediary. Via the email address below, a whistleblower can contact the Compliance Officer or an external trusted lawyer directly and point out possible serious breaches of rules. In addition to checking the plausibility and validity of the information, the compliance officer/lawyer of confidence will also assist the whistleblower, if desired, as an advisor on the whistleblowing system. He will then forward all information, to the extent discussed with the whistleblower, to the STARRAG Compliance Committee for further processing. The Compliance Committee is composed of STARRAG's CEO, CFO and Head of HR. Unless one of these persons is affected by the whistleblower. In this case, the Compliance Committee is composed of the Chairman and Secretary of the Board of Directors of STARRAG.
The information will be treated confidential and the whistleblower can decide whether or not to disclose his or her identity to STARRAG. If not, it is advisable to contact the external lawyer of confidence. The latter ensures that tips from whistleblowers who explicitly do not wish to be identified by STARRAG are forwarded anonymously.
In order for a tip to be processed and investigated effectively, it is important that the tip is as specific as possible. It is important to note that the descriptions must also be comprehensible to persons outside the field and, if possible, also answer the questions "Who? What? When? How? and Where?". It is usually helpful if the whistleblower is available to answer further questions.
Whistleblowers are invited to submit their tips via one of the following channels:
- Compliance Officer: email@example.com
- External counsel: firstname.lastname@example.org