Code of Conduct of MCD Medical Computers Deutschland GmbH for suppliers and subcontractors

1. Preamble

MCD Medical Computers Deutschland GmbH (hereinafter referred to as "MCD") acts in accordance with all ethical, social and environmental standards and in full compliance with the applicable laws, regulations and guidelines that apply to the Company's products and services.

The basic principles of our thinking and acting are laid down in the MCD Code of Conduct for Suppliers and Subcontractors. Compliance with the standards set out therein is mandatory for MCD and for MCD's suppliers and subcontractors, and forms the basis for business relationships between MCD and suppliers and subcontractors.

Employees who are aware of violations of this Code of Conduct or applicable law are required to report it without incurring any inconvenience.

2. Compliance and Integrity

MCD expects Suppliers and Subcontractors to comply with all applicable laws and regulations relating to corruption, bribery or other prohibited business practices, as well as not to use or tolerate illegitimate acts or conduct.

2.1 Corporate Integrity and Anti-Corruption

The open and honest dealings of all parties involved form the basis for good and lasting business relationships. MCD rejects any form of corruption, bribery, taking advantage, extortion or embezzlement, and does neither give order to do so nor tolerate such acts. In any case, MCD will refuse such offers and, if aware of violations of applicable law, will notify them to the appropriate authorities. Strict adherence to national and international anti-corruption regulations and agreements is binding on MCD, its employees, suppliers and subcontractors.

2.2 Invitations and Gifts

Suppliers and subcontractors may not accept or offer invitations or gifts to gain an advantage in the business. Entertainment or small gifts to MCD employees or others are only permitted if they are of little financial value, in accordance with local business practices, unsolicited and do not expect any consideration.

2.3 Confidentiality and Privacy

Confidential information may only be used for legitimate purposes in the business relationship between MCD and its suppliers or subcontractors. Such information may not be disclosed, published, used, reproduced or disclosed without the prior written consent of MCD.

MCD and its suppliers and subcontractors undertake to record, store or process personal data only in strict accordance with the respectively valid version of the GDPR (General Data Protection Regulation) or other national or international laws, guidelines or regulations concerning the protection of personal data.

3. Compliance with national and international Regulations

Suppliers and subcontractors agree to comply with all applicable national laws, regulations and industry-standard minimum standards. This applies especially to national and international trade and customs laws as well as international agreements.

4. Social Relations and Working Conditions

4.1 Equal Treatment and Prohibition of Discrimination

The equal treatment of all employees in terms of recruitment conditions, compensation, measures for professional and personal development, promotions and dismissals is the basis for the respectful interaction with each other.

MCD strictly adheres to the General Equal Treatment Act (AGG) and does not endorse or tolerate discrimination against employees because of race, ethnic origin, gender, religion or belief, disability, age or sexual identity ,

MCD expects the same without limitation from the suppliers and subcontractors towards their employees as well as MCD and the employees of MCD.

4.2 Respect in dealing with each other

MCD is respectful, fair, just and non-discriminatory to others inside and outside the company. MCD expects the same without restriction from suppliers and subcontractors. In particular, MCD does not tolerate any form of intimidation, blackmail, harassment or abuse.

4.3 Remuneration

Wages and salaries must be determined in accordance with applicable laws or collective agreements and paid on time and in full.

4.4 Working Hours and Overtime

To protect the health and safety of employees, working hours must comply with national laws and industry or industry standards. Overtime may only be provided on a voluntary basis and must be remunerated appropriately.

4.6 Working Conditions, Health and Safety

Within the scope of duty of care, suppliers and subcontractors undertake to comply with statutory regulations from the regulations of the professional associations or corresponding local regulations, in particular with regard to occupational safety, occupational safety and workplace regulations.

4.7 Involuntary Labour

MCD will not accept if suppliers and subcontractors use or benefit from involuntary or forced labour. Personal documents, work documents or allowances may not be withheld to prevent the employee from vacating his job.

4.8 Child Labour

National and international legal regulations regarding child labour are to be observed without restrictions. The minimum age and basis for the employment of children and adolescents is set out in IAO Conventions C138 and C182.

For employment or apprenticeship conditions, the provisions of the Youth Employment Protection Act and/or local regulations must be observed.

5. Environmental Protection

Protecting our environment, and therefore our livelihood, is a top priority at MCD. MCD complies with legal requirements and waste prevention standards and strives to make the products as recyclable as possible by using environmentally friendly technologies. MCD expects our suppliers and subcontractors to prioritize environmentally friendly practices, such as packaging.

6. Scope and Consequences

This Code of Conduct applies to all suppliers and subcontractors and their employees. It is part of the General Conditions of Purchase of MCD Medical Computers Deutschland GmbH and therefore binding.

In case of violations, MCD reserves the right to initiate appropriate measures, in particular to notify local authorities about unlawful acts or to terminate  business relations.

MCD reserves the right to change or extend the Code of Conduct.

Moenchengladbach, August 14th 2018