Code of Conduct

Reliability, credibility and in particular legality are indispensable elements of our business success. This commitment unites all employees of ETS Group across national borders and cultures.

Legality is one of the fundamental values of our company and, for us as management, of paramount importance. We expect all employees to strictly comply with all statutory requirements at all times. Violations of the law are not tolerated in our company, without exception. To underline the importance of this principle, we have formulated our position with regard to legal requirements and ethical issues in our “Code of Business Conduct”. The “Code of Business Conduct” provides our employees with a guide for their behaviour. It outlines the basic standards that we want to keep. If you doubt whether a decision complies with the requirements of the Code of Business Conduct, we ask you to refer to your manager or the Executive Committee for advice. Together, we have got the responsibility for the reputation of the ETS Group. The Code of Business Conduct and the values of ETS Group provide a strong foundation to build the trust that is so important for our business success.


Unconditional compliance with the legal requirements for our company has always been top priority and an integral part of the values of the ETS Group. The legal regulations are controlled through numerous directives and instructions, which are summarised in this Code of Business Conduct to facilitate the employees’ compliance with the rules. The regulations contained in this Code of Business Conduct are applicable to the ETS Group and its employees and should not be based on rights in favour of third parties.

Principles Lawful conduct

We uphold the principle of strict legality of all acts, measures, contracts and other operations of ETS Group. This includes the payment of taxes owed, the obtaining of any necessary regulatory approvals (for example in the area of customs and export control law) and the compliance of third party rights. This principle is not only based on the consideration that, in case of infringements, significant business disadvantages could arise through prosecution, fines or claims for damages; but rather, the affirmation of legal action, regardless of whether it benefits ETS Group or not. Each employee is personally responsible for compliance with the laws in their field of work. It is strictly forbidden to induce third parties to act unlawfully or participate knowingly in such acts. Deviant behaviour leads – regardless of statutory sanctions – to disciplinary consequences. The managers are responsible for ensuring that no violations of legal regulations or this Code of Business Conduct happen in their areas of responsibility, which with proper supervision could have prevented or impeded. They have to make it clear that violations of the law will not be tolerated regardless of the hierarchical position of the employee and will always result in disciplinary consequences. In this context, employees are explicitly drawn to the provisions of this Code of Business Conduct.

Responsibility for the reputation of the ETS Group

All employees need to consider the reputation of the ETS Group whilst carrying out their duties.

Behaviour towards employees

We respect and protect the personal dignity of each individual. We do not tolerate any illegal discrimination or harassment of our employees. We reject child labour, even through our business partners.

Avoiding conflicts of interest, equity investments and sideline activities

Sideline activities are only permitted with the prior consent of the company. Further, staff participation or sideline activity in companies that are in direct competition with the ETS Group, as well as participation or sideline activity with suppliers and customers is only allowed in individual cases after prior written consent by the management. Transactions with companies in which employees are directly related (either married, in partnership, a close family member) may only be made with the prior written consent of the management, provided that the employee can influence the business relationship and thus the possibility of a conflict of interest exists.

Commissioning of business partners for private purposes

Employees may in some circumstances utilise a business partner of the ETS Group for private purposes. In cases which are directly concerned with the allocation or execution of orders and through it the possibility of a conflict of interests exists, the prior written consent of the management must be attained. General goods or services are excluded.

Dealing with information documents

Records and Reports (internal and external) must be accurate and truthful. Generally accepted accounting principles must be adhered to, additionally data and other records must always be complete, accurate and up to date. The making of records, files, etc for confidential company use, is only permitted if they are directly in the interests of the ETS Group.


Confidential information of the company must be kept secret. This obligation shall continue even after termination of employment.

Privacy and Information Security

The protection of privacy in the use of personal data and the security of all business data, taking into account applicable legal requirements in all business processes, is to be guaranteed. Protection against unauthorised access is governed using appropriate systems, corresponding to the latest technical standards.

Insider Information

Insider information is any non-public information that would be considered by an investor as integral to its investment decisions. It is prohibited to purchase or sell securities and shares using insider information or recommend their purchase or sale. Insider information must be kept strictly confidential and must never be disclosed to third parties. This also applies to the disclosure of passwords that allow access to electronically stored inside information. A disclosure of inside information to employees or external consultants is only permitted if it is required for the fulfilment of a task and remains strict confidentiality.

Conduct towards business partners and third parties, Competition and Cartel Law

All employees are obliged to comply with the rules of fair competition in the context of the law. The allocation of particular territorial or customer groups, agreements or exchange of information on prices / price components, supplier relationships and their conditions as well as capacity or supply behaviour are not permitted. The same applies to the exchange of information on market strategies and investment strategies. This applies not only to written contracts but also to verbal agreements, tacit and conscious parallel conduct. Collusion or exchange of information of research and development projects is permitted only in narrowly defined exceptional cases. The market position of the company must not be exploited illegally to enforce, for example, price discrimination, non-delivery of requested products or any refusal to supply.

Supplier and customer relationships

Agreements with customers and suppliers are to be met fully and clearly and documented including subsequent amendments and additions. This also applies to regulations such as the payment of bonuses, advertising or promotional grants. The internal rules for applying counter-checks (“four-eyes principle”), as well as separating the operation and inspection functions, must be strictly observed by all employees. Suppliers are selected solely on their competitiveness based on price, quality, performance and suitability of the products or services offered.

Corruption, gifts and other benefits

Agreements or side agreements to agreements that relate to personal gain or favouring individuals in connection with the recruitment, procurement, delivery, settlement and payment of contracts shall be prohibited. Employees who influence customers or suppliers to take unfair advantage, or seek to influence them to gain an unfair advantage, will face disciplinary action, regardless of the criminal consequences. Attempts by suppliers or customers to unfairly influence the decisions of the employees of ETS Group, must be reported to the management. Individual cases will be responded to appropriately but can include, for example, order suspension or contract termination.

Commissions and fees paid to dealers, representatives or consultants must be appropriate and commensurate to the activities carried out. Services may not be agreed upon which are wholly or partly intended for paying bribes. The acceptance and giving of gifts and other benefits (e.g. attending events without any direct business relevance), including invitations (from and to suppliers or customers) should be done so cautiously. The financial framework should be such that the acceptance by the recipient does not have to be kept secret and should not bring the recipient to feel obliged in any way to the donor. In cases of doubt, written authorisation from the management must be obtained.

Product quality and safety

For our company exceptionally high quality standards are of paramount importance. We aspire to meet the high quality and safety standards of our customers in ever increasingly complex products and systems and make the necessary improvements required thoroughly and effectively. If despite all efforts, defects occur, we act to correct them in accordance with legal stipulations and contractual obligations.

Occupational safety, health, fire and environmental protection

It is the responsibility of all employees to avoid hazards to people and the environment, to keep the effects on the environment low and to conserve resources. Processes, premises and materials must comply with the applicable legal and internal guidelines on occupational safety and health, fire and environmental protection.

Information and Training

The employees are regularly informed about current issues related to this Code of Business Conduct.

Reporting irregularities

All employees have the right to report a possible breach of the rules contained in this Code of Business Conduct. This can be done anonymously. The report will be investigated and where necessary, corrective actions will be taken. Any report can be sent to:


Each department is responsible for compliance with the regulations contained in this Code of Business Conduct and all other internal company rules within their area of responsibility.

Amelinghausen, 25.03.2024

ETS Group

Dr. Uwe Nickel, CEO