Code of Conduct: Corruption, Bribery, Competition

This code applies to all kaliber5 employees and to everyone acting on behalf of kaliber5. It implements the commitments kaliber5 has made to its clients.

We expect our business partners, suppliers and subcontractors to comply with these principles as well, to require the same of their own suppliers, and neither to offer nor to request any advantages from kaliber5 or our customers. Reports of violations are received confidentially by the management (section 6).

1. No bribery, no corruptibility

Nobody offers, promises or grants benefits to third parties in order to influence a business decision. Nobody demands or accepts such benefits. This applies equally towards clients, suppliers, authorities and public officials, in Germany and abroad. Payments to speed up lawful official acts (facilitation payments) are prohibited as well.

2. Gifts and invitations

Gifts and invitations are permitted only where they are socially customary, transparent and not capable of influencing a decision. As a guideline, a value of 35 euros per person and occasion applies. Anything beyond that is agreed with the management in advance. Money or monetary benefits (vouchers, discounts, benefits for relatives) are neither given nor accepted.

3. Competition

Offers made by kaliber5 are not based on any agreement with competitors regarding prices, terms or the submission of bids. Information about prices or offers of other providers is neither obtained nor passed on.

4. Conflicts of interest

Anyone who, in connection with a project, has a personal relationship with an employee of a client or supplier that could influence the matter discloses this to the management.

5. Business partners and financial sanctions

Before working with a new supplier or subcontractor, the management checks whether they are listed on an EU financial sanctions list (sanctionsmap.eu). We do not work with listed individuals or companies.

6. Reports and whistleblower protection

Anyone who suspects corruption, bribery or breaches of competition law reports this to the management: Ulf Schmidt-Dumont, ulf.schmidt-dumont@kaliber5.de. Where the suspicion concerns the management itself, or where the whistleblower does not wish to use an internal route, the external reporting office of the German Federal Office of Justice is available: bundesjustizamt.de/hinweisgeberstelle.

Every report is treated confidentially and investigated, and the outcome is communicated to the whistleblower. Nobody suffers any disadvantage from a report made in good faith.

7. Acknowledgement

Every employee confirms once a year that they have read and understood this code.

Last updated: 24 September 2026. This is a translation of the German original; in case of doubt, the German version prevails.