CODE OF CONDUCTOUR GUIDE TO RESPONSIBLE BEHAVIOUR

PREFACE

DEAR COLLEAGUES,

We owe our good reputation with customers, business partners and the public, to the exemplary commitment shown, over decades, by all of our employees. The founda-tion of HANSA-HEEMANN‘s success has always been through combining our corporate activities with unquestioned compliance with laws, the assumption of responsibility and respect for our principles.

Our key success factors of commitment, quality, partnership, independence and innovation are the pillars upon which we base our future day to day operations. This Code of Conduct draws together our principles for HANSA-HEEMANN AG and affiliated companies (hereinafter: HANSA-HEEMANN). We embrace our vision of „Refreshment for everyone - every day“ as our mission statement.

This Code of Conduct serves as a guideline for the Executive Board, management and all employees as to the basic rules we must observe in all areas of day-to-day business. It provides us with orientation with which, through responsible action, we

can ensure profitable growth whilst maintaining and protecting the good reputation that HANSA-HEEMANN has with our customers, business partners and the public.

We also pay attention to the conduct of our business partners and expect them to treat the issues described in this Code of Conduct in an equivalent manner.

We ask you to familiarize yourself with the contents of this Code of Conduct and to follow its guidelines in your work. If you have any questions, or are uncertain about anything, you can contact your supervisor at any time or get in touch using one of the channels below.

German Reichert

Chairman of

the Board

Thomas Reise

Technology

Director

Volker Büttel

Sales and Marketing

Director

CONTENT

We work together to ensure

commercial success

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We cultivate respectful and appreciative relationships

PAGE 7

We promote safety in the workplace as

well as professional and personal development

PAGE 9

We handleconfidential

information and company assets conscientiously

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We respondappropriately to infringements of

law or our corporatevalues

PAGE 13

We observe current legislation, regulations

and our own internal guidelines in our day-to-day work

PAGE 5

We manage resources responsibly and are

committed to strengthening the

regional environment

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WE gear our business activities towards contributing to com-mercial success. This is the only way we can permanently expand our leading position in the market.

WE ACT ACCORDING TO ECONOMIC REQUIREMENTS

WE carefully examine investments and projects for oppor-tunities and risks before making decisions and implement them in strict compliance with our internal guidelines. Ensu-ring sustainable profitability is paramount in all decision ma-king, which is why we follow clear and unambiguous targets.

WE are aware of changes in the circumstances of our wor-king environment and react accordingly. We regularly eva-luate our workflows and processes for effectiveness and

efficiency, and constantly undertake improvements in colla-boration with our supervisors. We promote interdisciplinary cooperation.

WE DEAL OPENLY WITH CONFLICTS OF INTEREST AND RESOLVE THEM

WE are aware that our private interests can collide with those of HANSA-HEEMANN. Decisions that we make, or should make, in the course of our work for HANSA-HEEMANN must be based on objective criteria and must not be influenced by personal interests.

WE WORK TOGETHER TO ENSURE COMMERCIAL SUCCESS.

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WE WANT TO CONTINUOUSLY IMPROVE OUR ECOLOGICAL FOOTPRINT

WE take care to minimize resource requirements, such as ma-terial and energy use, water consumption, waste and emis-sions, and potential environmental impacts in the supply chain, all whilst developing our business at the same time.

WE promote the responsible use of resources through com-prehensive measures, such as the support and usage of recycling loops in the deployment of materials or the conti-nuous development of our processes, procedures and pro-duction facilities. Processes and standards developed and

employed by us meet or exceed legal requirements. We also demand the same of our business partners. WE ASSUME OUR RESPONSIBILITY IN STRENGTHENING THE REGIONAL ENVIRONMENT.

WE assume social responsibility locally by supporting re-gional initiatives and events. We refer to our internal guide-lines and principles of conduct when making donations and sponsoring activities.

WE MANAGE RESOURCES RESPONSIBLY AND ARE COMMITTED TO STRENGTHENING THE REGIONAL ENVIRONMENT

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WE naturally, and without exception, ensure compliance with current legislation and our internal rules in all our busi-ness dealings and activities. We also respect our business partners and their internal guidelines for proper business dealings with us.

WE ARE PROUD OF OUR GOOD REPUTATION AND OF OUR PRODUCTS.

Our products are renowned for their high quality, product sa-fety and unconditional compliance with all food safety stan-dards. We attach particular importance to this throughout the entire value chain.

WE deal professionally with our customers and business part-ners in all our commercial activities.

WE PROTECT LAWFUL BUSINESS

WE only enter into business relationships with reputable busi-ness partners in knowledge of the business purpose pursued. Customers, service providers or third parties with whom we have a business relationship or with whom we seek to esta-blish such a relationship are scrutinised and the desired pur-pose of the relationship is made transparent.

WE always work together with suppliers and service providers in a trusting and transparent manner. Our actions are always responsible and comprehensible. We select our business part-ners according to objective criteria and in compliance with our internal guidelines. We can only work together successfully if our partners are competent and a perfect match for us.

WE OBSERVE CURRENT LEGISLATION, REGULATIONS AND OUR OWN INTERNAL GUIDELINES IN OUR DAY-TO-DAY WORK.

WE APPLY THE PRINCIPLES OF FAIR COMPETITION IN OUR BUSINESS.

WE are committed to fair, free and responsible competition and work to safeguard it in all markets. Compliance with com-petition and antitrust laws is our top priority and for this rea-son, coordinated practices intended to influence prices, quan-tities, markets, territories or customers are not tolerated.

WE COMPLY WITH OUR INTERNAL GUIDELINES WHEN GRAN-TING AND ACCEPTING BENEFITS

WE understand that benefits such as gifts, entertainment or in-vitations may form part of business relationships. However, we always make sure that these are kept within reasonable limits and continue to observe our internal guidelines. If in doubt, we contact our supervisor. This also applies to the dispensing of donations to authorities, public officials or public institutions.

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WE uphold tolerant, appreciative and respectful relation-ships with each other. We are all committed to diversity, equal treatment and equal opportunities. We therefore do not tolerate any discrimination or harassment under any circumstances.

WE respect internationally recognized human rights and ensure that they are observed. We treat all employees equally, regardless of culture or ethnic origin, gender, re-ligion or belief, disability, age, sexual orientation or other personal characteristics.

WE maintain open and direct communication as well as the sharing of information with each other. This fosters cooperation which in turn helps us to maintain our good reputation in the marketplace and to provide the best possible service. We seek to promote a spirit of mutual trust and we address problems openly.

WE CULTIVATE RESPECTFUL AND APPRECIATIVE RELATIONSHIPS

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WE implement all precautions as required by law to ensure fair and safe working conditions. It is especially important for us that this is also the case with our business partners.

WE PROMOTE SAFETY SIDE BY SIDE IN THE WORKPLACE

WE comply with occupational health and safety regulations and every manager has to make their employees aware of their responsibilities, and offer support in fulfilling them. This also applies with regard to promoting healthy beha-viour, which we support as part of our company health ma-nagement program.

WE engage all employees under current legislation and compensate them accordingly. We also respect the right to form employee representative bodies.

WE demand that business partners and subcontractors of HANSA-HEEMANN adopt the same standards for their emp-loyees and this requirement will be taken into account when it comes to the selection and collaboration.

WE PROMOTE PROFESSIONAL AND PERSONAL DEVELOP-MENT WITHIN THE COMPANY

WE consider professional and personal development to be essential for our company‘s future success. This is why we encourage and support our employees in the successful completion of their further training programs.

WE PROMOTE SAFETY IN THE WORKPLACE AS WELL AS PROFESSIONAL AND PERSONAL DEVELOPMENT

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WE take great care with information. Our business and tra-de secrets as well as our technical know-how are the foun-dation of our business success. This knowledge must be protected.

WE therefore ensure that information, whether in-house or entrusted to us, is handled in confidence and will not permit any unauthorized internal or external access to our trade and business secrets. We have taken appropriate measures to protect against loss or access by unauthorized third par-ties. Intellectual property and trade secrets of our business

partners and competitors are also respected. Likewise, we expect our business partners to treat our information with the same care.

WE recognize the need to represent HANSA-HEEMANN with clear and consistent external communication. As a matter of principle, we do not make any public statements on be-half of HANSA-HEEMANN or in social networks. If there are enquiries, we contact our supervisors.

WE take care of the property entrusted to us for the per-formance of our tasks and protect it from loss and damage. We use it exclusively for operational purposes or adhere to internal guidelines. In the event of damage, we follow our internal chain of reporting. Theft will be prosecuted.

WE HANDLE PERSONAL DATA PROPERLY AND GUARANTEE ITS SECURITY ACCORDINGLY.

WE HANDLE CONFIDENTIAL INFORMATION AND COMPANY ASSETS CONSCIENTIOUSLY

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WE do not process any personal data without legal justifi-cation. As a matter of course, personal data is protected and is handled in accordance with data protection laws to safeguard privacy. We guarantee an appropriate degree of security in information processing to ensure the availabili-ty, confidentiality, integrity and traceability of information worthy of protection and to prevent its unauthorized use. If there is any uncertainty regarding the handling of personal data, we will contact our data protection officer.

WE have internal guidelines and regulations on IT security in place to avoid damage to HANSA-HEEMANN through un-authorized use of our IT systems, malware, programming errors or external misuse.

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WE support each other in bringing our Code of Conduct to life and following it. The maintenance of our basic rules is our shared responsibility.

WE are aware that violations of our Code of Conduct may result in civil, labour or, in serious cases, criminal penalties. If we become aware of violations of our Code of Conduct, other internal regulations or legislation, we will immediately report them to our supervisor or ombudsman at

BAY Ltd Certified Public Accountants and legal practice E-mail: hansa-heemann@bay-gmbh.com Phone: 089 / 90 420 49 62

Our ombudsman is independent and treats our reports, infor-mation and our data with the utmost confidentiality. We can also make reports anonymously. When we report or refuse to cooperate with a violation, it is always done in accordance with the principles of our Code of Conduct.

WE RESPOND APPROPRIATELY TO INFRINGEMENTS OF LAW OR OUR CORPORATE VALUES

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HANSA-HEEMANN AGHalstenbeker Weg 98

D-25462 Rellingen