Discover the values & code of conduct of PTA IT Consulting

1. Preamble

Since its foundation in 1969, PTA IT Consulting has established a Code of Conduct as part of its corporate and organizational development, which will continue to provide all employees at all locations, workplaces and working environments with a clear understanding of nationally and internationally recognized environmental, labour and social standards.

It is the declared aim of PTA and its shareholders that all activities and services that contribute to the success of the business are based on these values. All employees, managers and stakeholders are obliged to know, live and act in accordance with these fundamental values and guidelines.

These principles and values guide PTA’s actions in its dealings with business partners – in the sense of customers, suppliers, subcontractors and partner companies – as well as other interested parties and all affiliated companies of the PTA Group. Within the scope of its own influence, PTA ensures that these standards are consistently taken into account and implemented in the cooperation. PTA reserves the right to review its business partners’ compliance with the Code of Conduct in order to intervene if necessary or to offer to assist them in meeting the requirements set forth in this Code of Conduct.

Our expectations of ourselves and our business partners are based on international and national standards (see section 2.2)

This Code of Conduct represents the binding basis on which we create a trusting, honest and sustainable collaboration.

2. area of application

PTA and all business partners undertake to conduct their business activities in an ethical, legally compliant and responsible manner at all times.

The business activities of PTA and its business partners are based on the following values:

• Recognition of human rights
  We respect and promote internationally proclaimed human rights and ensure that we are not complicit or complicit in human rights abuses.
• Fair and safe working conditions
  We guarantee appropriate, healthy and safe working conditions, respect freedom of association and the right to collective bargaining, exclude all forms of forced or child labor and consistently oppose discrimination.
• Responsibility in the supply chain
  We ensure that our suppliers and partner companies also comply with fundamental human rights, labor and social standards and deal with risks transparently.
• Ethical business conduct with integrity
  We act with integrity, transparency and responsibility. We reject corruption, bribery, extortion and unfair business practices in all forms.
• Protecting the environment and promoting sustainable practices
  We are committed to a precautionary and resource-conserving approach to environmental issues, continuously reducing environmental pollution, promoting environmental awareness and using innovative, environmentally friendly technologies.
• Social responsibility and a focus on the common good
  We have a responsibility towards society and future generations. Our actions are based on respect, fairness and the protection of the common good.

Business partners undertake to pass on the standards set out in this Code to their own suppliers and subcontractors and to take appropriate measures to ensure compliance with them.

2.1 Scope of application

• All locations, companies and employees of the PTA Group
• All business partners, subcontractors and suppliers
• Applicable worldwide for all business activities

2.2 Central guidelines and frame of reference

The Code of Conduct is based on the following rules and standards:

3. data protection, confidentiality, secrecy

The protection and preservation of the confidentiality of all data and information of our business partners form the basis of a trusting and successful cooperation.

All PTA employees are bound by an express confidentiality agreement to treat as confidential all information that becomes known to them in the course of their work for PTA or for PTA customers. This applies in particular to personal data, internal company information and business and trade secrets.

Confidential information includes, but is not limited to

• all contractual performance results, in particular program and source codes, documentation, data, data extracts and databases, interfaces, samples, drafts, concepts and drawings,
• internal strategies, calculations, plans and other information with economic or technological value.

All employees have undertaken not to make this information accessible, pass it on or use it in any other way, either directly or indirectly, to third parties, i.e. to contractual partners not involved in the project.

In addition to the protection of trade and business secrets, PTA is expressly committed to the comprehensive, GDPR-compliant protection of personal data through appropriate technical and organizational measures. This includes in particular

• the integrity, availability and confidentiality of the data,
• compliance with all relevant data protection regulations,
• protection against unauthorized processing or loss.

In addition, PTA follows the requirements of ISO/IEC 27001 on information security management to ensure a systematic approach to the protection of confidential data and information.

As part of the Supply Chain Duty of Care Act (LkSG), it is ensured that appropriate protection of confidential information and personal data is also observed when working with suppliers and partner companies. Compliance with the relevant obligations is regularly monitored and supported where necessary.

The PTA also complies with the requirements of the BME Code of Conduct, which demands integrity, diligence and confidentiality throughout the entire value chain.

The only exception to these obligations is the disclosure of data that must be made on the basis of mandatory statutory provisions or by order of courts or authorities. In such cases, the other party to the contract must be informed immediately in writing, stating the content, scope and legal basis of the disclosure.

Reports of violations of the standards described in this section can be submitted confidentially or anonymously at any time via the central reporting channels (see section 9) or directly to the responsible contact person. PTA guarantees comprehensive protection for whistleblowers.

External person responsible for data protection, to be reached at:

E-Mail: datenschutz@pta.de

4. IT security

All persons who have access to the information systems, data or applications of our company or our customers and business partners in the course of their work are obliged to comply with the applicable IT security regulations within the European Union. In particular, this includes the EU Directive on measures for a high common level of cybersecurity (NIS2).

The responsible handling of information and systems is of central importance. Sensitive data may only be passed on if there is a proven legitimate interest, and communication must take place via secure channels. Access to systems must be protected by strong passwords and, where provided, multi-factor authentication. Work devices must always be locked when left unattended and regularly updated with security updates. The use of unauthorized software is prohibited.

All employees and business partners are obliged to be alert to phishing attempts, malware and other security risks. Suspicious activities or incidents must be reported immediately to the relevant departments. The use of secure networks and the protection of mobile devices through encryption are also mandatory.

The data center of the sister company DATIS used by PTA has been ISO 27001 certified since 2011.

All work instructions and important documents of PTA’s ISMS (Information Security Management System) can be viewed in the internal template management system.

Compliance with these principles is essential for the protection of our digital infrastructure, our customers and our company as a whole. Violations of IT security or data protection guidelines can have disciplinary or legal consequences. Every contribution to information security counts – regardless of function or role.

Reports of violations of the standards described in this section can be submitted confidentially or anonymously at any time via the central reporting channels (see section 9) or directly to the responsible contact persons. PTA guarantees comprehensive protection for whistleblowers.

Internally appointed persons on the topic, to be reached at:

E-Mail: PTA-Support@pta.de

Tel: +49 (0) 62141960-0

5 Human rights, the world of work and employees

The PTA is committed to recognizing, respecting and actively promoting the inalienable rights and freedoms set out in the United Nations Universal Declaration of Human Rights (UDHR) in their entirety. This commitment forms the basis of our actions – both internally and externally.

We expect our business partners to respect, protect and promote these fundamental rights as well.

Human rights and equal treatment
PTA and all business partners respect the dignity, freedom and equality of all people. Discrimination, exclusion, harassment or violence based on race, color, gender, sexual orientation or identity, language, religion, political or other opinion, age, national or social origin, wealth, birth or other status will not be tolerated. Everyone is entitled to equal rights and fair treatment.

Occupational health and safety
PTA and all business partners ensure that the safety, health and well-being of all employees are protected and promoted at all times. Workplaces, machinery, work processes and equipment must not pose a risk to physical or mental health.

The following principles apply:

• Compliance with all applicable national laws and international standards on occupational health and safety, including the provisions of the ILO and, where applicable, ISO 45001.
• Establishing and maintaining safe, ergonomic and healthy workplaces.
• Provision of suitable personal protective equipment, regular instruction and training on occupational health and safety.
• Prevention of work-related illnesses and promotion of physical and mental health.
• Effective fire protection, emergency plans, adequate ventilation, lighting, sanitary facilities and non-smoker protection.

Managers bear particular responsibility for compliance with these principles and the continuous improvement of occupational health and safety measures.

Professional development and training

PTA attaches particular importance to promoting the individual development opportunities of all employees. We support lifelong learning and invest in professional and personal development. This includes in particular

• Measures for systematic training and further education,
• Targeted promotion of professional development,
• fair opportunities for career development regardless of gender, origin or other characteristics,
• transparent processes for agreeing targets and assessing performance.

Managers are obliged to actively support their employees in developing their skills and to create suitable framework conditions for this.

Prohibition of child labor, forced labor and modern slavery
Child labor, forced labor, bonded labor, human trafficking or any form of modern slavery are prohibited without exception. PTA and all business partners undertake to strictly adhere to these principles. Violations will result in immediate termination of the cooperation.

Remuneration, working hours and social security
We guarantee fair, legally compliant working conditions and remuneration that provide employees with a decent living. This includes in particular

• Payment of remuneration at least on the basis of the applicable statutory or contractual minimum wage provisions,
• fair payment for overtime,
• Compliance with rest periods, breaks and vacation,
• social security in accordance with national regulations.

Freedom of association and collective bargaining
PTA and all business partners respect the right of employees to freedom of association, to form and join trade unions or employee representative bodies and the right to collective bargaining and strike. These rights may not be restricted or responded to with discrimination, intimidation or retaliation. Membership of a trade union is not a reason for unequal treatment and is expressly protected in accordance with ILO Convention No. 87 and No. 98.

Freedom and security of the person
Everyone has the right to life, liberty, personal security and protection from arbitrary detention, torture and cruel, inhuman or degrading treatment or punishment.

Privacy and property
We respect the right to privacy and the protection of property. Unlawful interference with private areas of life, data or property rights will not be tolerated.

Responsibility in the supply chain
In accordance with the German Supply Chain Due Diligence Act (LkSG), PTA undertakes to systematically identify and assess human rights risks and violations along its supply chain and to take appropriate preventive and remedial measures.

PTA has implemented procedures for risk analysis, prevention, remediation and documentation to fulfill its due diligence obligations under the German Supply Chain Due Diligence Act (LkSG). These procedures are regularly reviewed and adapted as necessary.

PTA does not tolerate retaliation against individuals or organizations that promote human rights.

Reports of violations of the standards described in this section can be submitted confidentially or anonymously at any time via the central reporting channels (see section 9) or directly to the responsible contact persons. PTA guarantees comprehensive protection for whistleblowers.

Internally appointed persons on the topic, to be reached at:

E-Mail: hinweise@pta.de / hinweise@pta.ch (the management)

Tel: +49 (0) 62141960-0

6. language, equality and diversity

Language has a significant influence on the way we work together. That is why we would like to express our point of view and our self-image here, without imposing any binding standards.

PTA’s corporate culture is characterized by gender equality, equal opportunities, diversity and non-discrimination. We respect the individuality of every person and promote a working environment in which everyone feels safe and valued, regardless of gender, ethnic origin, religion or ideology, disability, age or sexual identity.

For us, equality of all genders and the recognition of diversity are natural components of modern, responsible corporate governance and at the same time a contribution to securing the future of PTA. We are guided by the principles of the Universal Declaration of Human Rights, the General Equal Treatment Act (AGG), the ILO core labor standards and the UN Global Compact.

We respect and protect the individual freedom and personality of every person. Freedom of opinion, an open culture of discussion and debate and a constructive approach to mistakes are key features of our collaboration. Managers act as role models and promote an environment of mutual respect.

We give all employees the freedom to choose their own language, taking into account our non-discriminatory and gender-neutral corporate culture – both in internal communication and in exchanges with our business partners. At the same time, we recommend that you keep abreast of developments in social change and current communication and writing habits.

This self-image requires mutual tolerance, respect and composure. Since the founding of PTA, collegial and respectful cooperation has been one of the key success factors of our company.

Reports of violations of the standards described in this section can be submitted confidentially or anonymously at any time via the central reporting channels (see section 9) or directly to the responsible contact persons. PTA guarantees comprehensive protection for whistleblowers.

Internally appointed persons on the topic, to be reached at:

E-Mail: hinweise@pta.de / hinweise@pta.ch (the management)

Tel: +49 (0) 62141960-0

The internal complaints office in accordance with Section 13 of the General Equal Treatment Act (AGG) is obliged to investigate every incoming report immediately.

7 Environment and climate change

PTA and all business partners undertake to comply with all applicable laws, regulations and international standards for the protection of the environment as part of their business activities. The aim is to avoid or minimize environmental pollution and to continuously develop measures for environmental and climate protection.

The central principles are:

• the continuous reduction of CO₂ emissions,
• the careful and efficient use of water, energy and raw materials,
• the preservation and improvement of air and soil quality,
• the avoidance, proper handling and safe disposal of waste and hazardous substances,
• the promotion of processes and technologies for resource conservation, waste avoidance and the circular economy.

All products supplied must comply with the relevant European and international regulations, in particular

• EU Directive 2011/65/EU (RoHS) and the German Electrical and Electronic Equipment Ordinance (ElektroStoffV),
• of the REACh Regulation (EC) No. 1907/2006,
• the WEEE Directive 2012/19/EU (Waste of Electrical and Electronic Equipment).

PTA and its business partners ensure that:

• products and packaging are free of prohibited or restricted substances in accordance with the aforementioned regulations,
• in the event of deviating regulations, a complete list of the materials concerned and the respective restrictions is provided,
• suppliers do not source raw materials such as gold, tin, tantalum or tungsten from conflict regions (e.g. the Democratic Republic of Congo or neighboring countries), and all relevant regulations of the Dodd-Frank Act §1502 are complied with.

PTA bases its environmental management on the principles of ISO 14001, even if there is no formal certification. In addition, we are committed to complying with all other relevant local and international environmental standards. This includes in particular

• the identification and assessment of environmental impacts,
• the definition of environmental targets,
• compliance with all binding obligations,
• the continuous improvement of environmental performance.

As part of the continuous improvement process (CIP), PTA is particularly keen to tap into existing energy-saving potential and actively promote energy-saving working methods.

Impacts of climate change
PTA and its business partners are actively responsible for limiting the negative impacts of climate change and preparing for the resulting risks. This includes in particular

• Measures to adapt to changing environmental conditions (e.g. extreme weather events, scarcity of resources),
• minimizing climate-specific operational and supply chain risks,
• the consideration of climate-related requirements in all relevant processes and decisions.

In addition, business partners are expected to implement measures to raise environmental awareness and disseminate environmentally friendly technologies in accordance with Principles 7 to 9 of the UN Global Compact.

Reports of violations of the standards described in this section can be submitted confidentially or anonymously at any time via the central reporting channels (see section 9) or directly to the responsible contact persons. PTA guarantees comprehensive protection for whistleblowers.

Internally appointed persons on the topic, to be reached at:

E-Mail: hinweise@pta.de / hinweise@pta.ch (the management)

Tel: +49 (0) 62141960-0

8. ethical and moral business standards

PTA is committed to conducting all business activities with integrity, fairness, transparency and in accordance with applicable law. This includes, in particular, compliance with all national and international laws and regulations on anti-corruption, money laundering prevention and integrity.

We expect our business partners to:

• comply with all applicable anti-corruption, anti-bribery and anti-money laundering laws,
• refrain from unfair business practices, bribery, extortion, granting or accepting advantages in any form,
• disclose and avoid potential conflicts of interest. Recognized or potential conflicts of interest must be reported to the management without delay.
• base business decisions exclusively on objective criteria such as quality, suitability, price, reliability and sustainability.

PTA has introduced binding company-wide guidelines that regulate the handling of gifts, invitations, donations and other benefits. These guidelines serve to ensure transparency, avoid corruption risks and maintain the trust of our customers, partners and employees.

All PTA employees are obliged to inform themselves about these guidelines, to comply with them and to report any violations immediately.

In addition, PTA complies with the principles of the UN Global Compact, in particular Principle 10, in all its business activities.

Reports of violations of the standards described in this section can be submitted confidentially or anonymously at any time via the central reporting channels (see section 9) or directly to the responsible contact persons. PTA guarantees comprehensive protection for whistleblowers.

Internally appointed persons on the topic, to be reached at:

E-Mail: hinweise@pta.de / hinweise@pta.ch (the management)

Tel: +49 (0) 62141960-0

9. giving advice and consequences

PTA enables all employees, business partners and third parties to report violations of this Code of Conduct, legal requirements or other binding obligations.

Confidentiality and protection of whistleblowers
The identity of whistleblowers is always treated confidentially. Comprehensive protection mechanisms have been put in place to protect whistleblowers from reprisals, discrimination or other negative consequences. No person may be disadvantaged or discriminated against because of a report made in good faith.

The protection of whistleblowers is based on the provisions of the German Whistleblower Protection Act (HinSchG).

Reporting channels
Reports can be submitted via various channels – anonymously or by stating your name. The following reporting channels are available:

• E-mail: hinweise@pta.de / hinweise@pta.ch (this will be forwarded to the respective management)
• Anonymous reports: via our central whistleblower platform
• Legal notices & information for our content
• External reporting office at the Federal Office of Justice: BfJ Whistleblower Office

In addition, topic-specific information (e.g. on discrimination, human rights, environmental risks or corruption) can also be submitted directly to the relevant designated contact persons. These are listed in the relevant sections of this Code of Conduct.

Processing and consequences
All incoming reports are examined with the utmost care, neutrality and respect for the personal rights of all parties involved. If necessary, measures are initiated to clarify and eliminate the grievances and to prevent further violations.

Depending on their severity, violations of the principles enshrined in this Code may result in disciplinary, labor law or contractual consequences, up to and including termination of the collaboration.

> Note: All personal designations are to be understood as gender-neutral in case of doubt. <