As AIF Capital Group, we acquire and retain trust not only on the basis of the quality of our products and services. It is also essential here that we conduct ourselves legally correctly and professionally at all times when dealing with our clients, commercial partners and competitors, as well as in the public arena.

These values, which have always been elementary for the AIF Group, are consolidated in this Code of Conduct and constitute a binding behavioral benchmark for all board members, managing directors, managers and group employees, irrespective of their position and role. The objective of this Code of Conduct is to create an open and transparent environment, which not only inhibits illegal actions, but moreover achieves a sensitization with respect to ethically and morally questionable transactions and business practices.

A good reputation and the trust of our clients are essential for the competitiveness of the AIF Group.

All of us – board members, managing directors, members of the supervisory boards, managers and group employees – are therefore required to ensure that our actions remain constantly in line with the requirements of these guidelines and with the laws applicable to our respective field of work and scope of responsibility.

I. Principles

Since our establishment, seven principles have been the pillars on which we operate:

    • Authenticity
    • Decision-making power
    • Reliability
    • Customer orientation
    • Creativity
    • Partnership
    • Result orientation.

We are proud to having upheld these principles to this day and continue to do so.

In addition, where consistent with our fiduciary responsibilities, AIF Group as signatory to UN PRI commits to the following:

 

    • Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.
    • Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.
    • Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.
    • Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.
    • Principle 5: We will work together to enhance our effectiveness in implementing the Principles.
    • Principle 6: We will each report on our activities and progress towards implementing the Principles.

 

The regulations contained within this code constitute the minimum standard of the AIF Group. If individual group companies should impose further-reaching stipulations or – in particular with foreign companies – observe national rules of law that clash with the principles set out in this code or exceed them then such stipulations or rules of law must take precedence or be observed in addition to this code.

Managers must set an example to their employees. They are required to ensure that their employees are familiar with the contents of this code and that they observe the valid rules and principles of conduct.

II. Respect for human dignity and freedom of rights

We acknowledge the Articles described under Act 1 of the Basic Law for the Federal Republic of Germany (“Grundgesetz”).

We recognize that human dignity is inviolable and as it is acknowledged under Basic Rights (Act 1) of Basic Law for the Federal Republic of Germany.

We recognize that every person shall have the right to free development of his personality insofar as he does not violate the rights of others or offend against the constitutional order or the moral law.

We are convinced that economic success is also decisively dependent on moral values and the corporate culture. We therefore always endeavor to treat each other fairly and, when doing so, to act within the framework of valid standards. The framework of our commercial activity is formed here by the current legal and official regulations, which we are required to observe at all times and in all areas.

III. Anti-discrimination and equal treatment

We do not tolerate any discrimination based on any ground such as sex, race, color, ethnic or social origin, genetic features, language, religion or belief, political or any other opinion, membership of a national minority, property, birth, disability, age or sexual orientation. We treat all individuals equally, without prejudice.

We are convinced that diversity is a strength in the workplace and that harnessing this diversity will create a productive environment in which everyone feels valued, where their talents are fully utilized, and where organizational goals are met.

IV. Data protection and confidentiality

The collection, processing, or use of personal data without authorization is strictly prohibited. We respect and are committed to data secrecy and confidentiality. A data protection officer is set in place to consult all employees, should there be any doubt or uncertainty how personal data need to be handled.

In addition, all employees are required to comply and process personal data in accordance with the provisions of § 5 of the Federal Data Protection Act (“Bundesdatenschutzgesetz”). Specific guidelines are put in place that describe the regulatory requirements, as well as the applicable process in case of violation.

V. Avoiding conflicts of interest

We ensure that our employment and contractual obligations are not breached or put at risk by our own or our employees’ private interest. Through a collective decision-making process, personal liability, and multiple review bodies we ensure that any conflict of interests identified are communicated through the appropriate channels.

In addition, a conflict of interest officer is put in place to indicate whether a conflict of interest applies to each situation once reported. Specific guidelines are in place that describe the identification, reporting obligations, resolution of any conflict of interest.

VI. Insider trading rules

We are obliged to adhere to the insider trading rules described in Section 13 (1) of the German Securities Trading Act (“Wertpapierhandelsgesetz”). Any employee business associated with the misuse or improper disclosure of confidential information, violation of the AIF Group obligation under the provisions of the KAGB, asset consultation to another business or any other action that would constitute as misuse of information about ongoing orders is strictly prohibited. Specific guidelines are in place that describe all actions described as a violation of insider trading rules as well as the repercussions of say violations.

VII. Anti-corruption

We do not tolerate any act of active (bribery) and passive (corruptibility) corruption. These constitute a criminal offence in Germany and many other countries. This applies not only with respect to office holders but also in all other commercial transactions.

To create or offer prohibited advantages to commercial partners, their employees, other third parties or ourselves is strictly prohibited. Even an attempt may constitute a criminal offence. Prohibited advantages are also assumed if the type, scope and in particular the value of advantages either granted or offered are fit for the illicit influencing of the actions or decisions of the recipient, or one’s own decisions.

Office holders and public employees are obligated in the general interest. It is therefore prohibited to offer them any gratuities, which may make their impartiality questionable.

VIII. Donations and sponsoring

AIF Group promotes education and science, art and culture, as well as social and other generally recognized purposes.

Donations from group companies to organizations, associations, private individuals and other recipients that could damage the reputation of the AIF Group are prohibited. No donations are made to political parties or political office holders.

When sponsoring, we ensure that no imbalance exists between our services and the intended economic or immaterial objective. The granting of donations and sponsorship measures is only permitted within the framework of a transparent approval process within the respective framework of the relevant legal provisions and in accordance with the applicable internal rules of the AIF Capital Group.

IX. Complying with competition law

We wish to secure and develop our market position solely through our products and services. We are obligated to comply with the rules of competition and anti-trust law at all times. These prohibit any agreements with competitors regarding prices and conditions, the dividing up of markets or client bases, as well as the handover or exchange of information that is sensitive according to anti-trust law.

X. Preventing money laundering and the financing of terrorism

We pursue the objective of preventing and fighting money laundering and the financing of terrorism. For this reason, we only participate in transactions if our partners can be properly identified. We only participate in commercial relationships if the invested funds are of legitimate origins.

We act diligently to ensure that the AIF Group companies are not misused for illegal purposes. Each individual is required to critically observe our commercial fields and to act on any initial suspicions.

XI. Employee Engagement, Health & Well-being

We recognize our employees and endeavor to meet their needs in the workplace. We respect our employees’ engagement and strive to create a communication channel about their role, their work and value within the AIF Group through active feedback.

We ensure that a safe and healthy working environment exists within the AIF Group, based on the applicable industrial health and safety laws. We promote and demand a trusting and convivial working atmosphere within the AIF Group.

XII. Environmental protection

Responsible treatment of our environment is an elementary constituent of our self-image. We observe the environmental regulations, endeavor to protect natural resources at all times during our operations and seek sustainable environmental-friendly solutions.

We endeavor through our internal processes to encourage practices that have a low negative environmental impact, through decreased energy and water consumption, and low greenhouse gas emissions generation.

XIII. Addressing climate change

We recognize that climate change poses a threat to our ecosystems, as well as undermines the foundation of our fundamental rights, by deepening inequalities within our community. We endeavor to adapt to climate change and mitigate its impacts, through which we strive to become resilient at the event of a catastrophe or disaster.

In addition, we are committed to implementing and promoting the principles of responsible investment introduced by UN PRI.

XIV. Community Engagement

We recognize that we are part of a larger community and acknowledge that it is part of our responsibility to contribute to its development. We strive through our business practices and culture to contribute to the preservation and development of our community.

We are committed to upholding the UN Sustainability Development Goals within our business practices.

XV. Use of company resources

We act carefully when utilizing all equipment, economic values and resources of AIF Group, and ensure efficient and cost-aware use. Company property must be used exclusively for company purposes. The property of the AIF Group companies must be protected against misuse, loss and theft.

We endeavor to sustainably procure company resources and source office material from manufacturers that comply with the pollution prevention regulations.

XVI. Communication with the media

We believe that open, honest, and accurate communication is essential to our integrity and our way of doing business.

Through the use of broad In communication regarding our activities we are transparent about our actions for which we are accountable to the public. In doing so, we take a balanced and objective approach to ensure fairness, honesty and overall confidence in the AIF.

Personality and freedom rights, such as the right to privacy and freedom of speech apply. The principles of media, competition and criminal law, from those governing intellectual property or competition claims, through to the provisions of criminal law on defamation offences and other rights infringements also apply.

XVII. Complaints management

All forms of complaints, both internal or external are highly regarded and examined thoroughly. Throughout our business practices a complaints officer to which all complaints are directed to is determined. In addition, a complaint management process is put into place describing the process of addressing and resolving a complaint.

We acknowledge and respect any complaints that are made and endeavor to further improve our practices and business operations.

XVIII. Adhering to this Code of Conduct

Infringements of legal regulations, this Code of Conduct and the applicable internal guidelines may have negative consequences for the company and for each one of us, starting from reputation damage and concrete financial disadvantages, right through to personal penal consequences. Adhering to the behavior principles in this code therefore serves to protect us all, whilst also requiring the cooperation and attention of us all. The  is available for advice and support at all times in this regard.

If legal violations, infringements of this code or any other regulations should arise, it is possible for employees to report these initially to their manager, to the responsible compliance officer or directly to the Chief Executive Officer (CEO). Employees are also able to contact an external notification office (whistleblowing- system) if they prefer.

Employees shall not experience any disadvantages as a result of this notification, insofar as this information is provided in good faith. This applies irrespective of whether the notification should transpire to be wholly without grounds. The board of the AIF Group has expressly undertaken to observe this.

 

Stuttgart, December 2021 Mario Caroli (Managing Partner)