Code of Conduct

The following Code of Conduct is valid throughout the entire Pfeiffer Vacuum Group. It may be supplemented by detailed operating regulations as long as they are in line with the principles set forth in
this document. In the event of deviation, the stricter rule shall have precedence.
 

This enables foreign subsidiaries to pay tribute to local requirements when putting the Code of Conduct into practice, as long as the requirements are in line with the basic principles set forth in this document. National laws shall prevail if they are stricter.
 

Law Abiding Behavior
Observance of the law and the legal system is a fundamental principle for our Company. Every employee shall obey the laws and regulations of the legal systems within which they are acting. Violating the law must be avoided under all circumstances, especially violations punishable by jail, monetary penalties, or fines.
 
Regardless of the sanctions foreseen by the law, any employee guilty of a violation will be liable to disciplinary consequences because of the violation of his/her employment duties.
 
Senior and executive management
Board members and senior managers have an important function as role models for compliance with the Pfeiffer Vacuum Code of Conduct.

The standards used to assess any potential misconduct by Board members and senior managers are stricter than those used for other employees.

Board members and senior managers are responsible for ensuring that the Pfeiffer Vacuum Code of Conduct is complied with at all times. The manager must see to it that compliance with provisions of the law is monitored on a constant basis (duty of monitoring). The manager must clearly communicate to the employees that violations of the law are disapproved of and will have employment consequences.

Treatment of Business Partners and Third Parties
Dealings with customers, suppliers and service providers
It is essential that a clear line be drawn between the company’s and its employees’ personal interests when dealing with business partners (customers, suppliers, service providers, etc.) and government/public bodies.

No employee may directly or indirectly offer or grant unjustified advantages to others in connection with business dealings, neither in monetary form nor as some other advantage.

The employee must inform his/her supervisor of any personal interest he/she could possibly have in connection with the execution of his/her professional duties.

There must be no unfair discrimination for or against any suppliers in their competition for contracts.

Invitations from business partners may only be accepted if the occasion and scope of the invitation are appropriate and if refusing the invitation would be discourteous.
 

Gifts from business partners must be refused and returned unless they are occasional gifts of insignificant value.
 

No employee may have private contracts fulfilled by companies with which he/she has company business dealings if he/she could derive any advantage therefrom. This is particularly applicable if the employee exercises or is capable of exercising a direct or indirect influence upon having that company receive a contract from Pfeiffer Vacuum.
 

No donations are made to political parties. Modest donations are made only to local facilities and institutions, with the focus on both educational as well as social and sports engagement.

Pfeiffer Vacuum strongly endeavors to prevent any and all unlawful activities relating to nuclear explosives or nuclear fuels, as well as to the development and production of chemical or biological weapons.

There is a central Export Approval Office for inquiries from countries that are either subject to an embargo or for which export permits must be obtained for our products.

Employees who have acquired/are planning to acquire material financial stakes in competing enterprises, customers, or suppliers are bound by a duty of disclosure to require the prior approval of their personnel department.
 

Material financial stakes held by employees’ immediate family members that might result in a conflict-ofinterest situation must also be disclosed.
 

'Material financial stake' means any direct or indirect financial interest amounting to:

Secondary employment refers to any additional employment

at a non-Pfeiffer Vacuum Group company.

Except as agreed otherwise, secondary employment requires the prior approval of the relevant personnel department.
 

The devices and equipment in offices and workshops (such as telephones, copying machines, PCs, software, Internet/Intranet, machines, tools) are to be used only for company business. Exceptions, and payment if applicable, can be agreed upon locally. In no case may any information be retrieved or transmitted which incites racial hatred, glorification of violence, or other criminal acts, or contains sexually offensive material which is sexually offensive within the respective cultural background. No employee shall be permitted without the consent of his/her superior to make records, databases, video and audio recordings, or reproductions unless this is directly due to company business.
 

Open and effective cooperation requires accurate and truthful reporting. This applies equally to the relationship with investors, employees, customers, and business partners, as well as with the public and all governmental offices. Any records and reports produced internally or distributed externally must be accurate and truthful. According to proper bookkeeping principles, data and other records must always be complete, correct, and appropriate in terms of time and system. The requirement of truthful statements applies to expense accounts as well.
 

Confidentiality must be maintained with regard to internal corporate matters which have not been made known to the public. As an example, this includes details concerning the Company's organization and equipment, as well as matters of business, manufacturing, research and development, and internal reporting figures. The obligation to maintain confidentiality shall extend beyond the termination of the employment relationship.
 

Access to the Intranet and Internet, worldwide electronic information exchange and dialogue, electronic business dealings - these are crucial requirements for the effectiveness of each and every one of us, and for the success of the business as a whole. However, the advantages of electronic communication are tied to risks in terms of personal privacy protection and data security. Effective foresight with regard to these risks is an important component of IT management, the leadership function, and also the behaviour of each individual.

Personal data may only be collected, processed, or used insofar as this is necessary for pre-determined, clear, and legitimate purposes. High standards must be ensured with regard to data quality and in technical protection against unauthorized access.

 

People who have insider information with regard to Pfeiffer Vacuum or some other company are not allowed to deal in these companies' securities, whether listed on the stock exchange or in free trade. Insider information means any information which is not public knowledge and which can be used to influence an investor's decision to purchase, sell, or keep a security.

Insider information must not be transmitted without authorization to persons outside Pfeiffer Vacuum (e.g. to journalists, financial analysts, customers, consultants, family members, or friends). Even within Pfeiffer Vacuum, such information may only be transmitted if the recipient truly needs it in order to perform his/her job. Furthermore, one must always make sure that insider-relevant knowledge is so secured or kept under lock and key that unauthorized persons cannot gain access to it.

Persons who have insider information are also not allowed to give investment tips to third parties.

Environment and Technical Safety

Protecting the environment and conserving its resources are high-priority targets for our Company. A worldwide environmental management ensures observation of the law and sets high standards for this purpose. Already at the product development stage, environmentally friendly design, technical safety, and health protection must be fixed targets.
 

Responsibility vis-à-vis employees and colleagues requires the best possible accident prevention measures. This applies both to the technical planning of workplaces, equipment, and processes and to safety management and personal behaviour in the everyday workplace. The work environment must conform to the requirements of health oriented design.
 

Implementation and Controlling of the Pfeiffer Vacuum Code of Conduct
The management of Pfeiffer Vacuum and its subsidiaries throughout the world shall actively foster the widespread distribution of the Business Conduct Guidelines and see to it that they are implemented permanently.

Compliance with the law and observance of the Business Conduct Guidelines shall be monitored worldwide in all Pfeiffer Vacuum companies on a regular basis. This shall be done in accordance with the national procedures and legal provisions in question.
 

A specially-appointed Compliance Commissioner is responsible for the implementation and observance of the Pfeiffer Vacuum Code of Conduct. The Compliance Commissioner is required to address in an independent and objective manner all issues directed to him. The Compliance Commissioner is there to answer employees’ questions and advise them on matters relating to the Pfeiffer Vacuum Code of

Conduct. The Compliance officer is bound to treat all information in confidence.

The Compliance Commissioner must record and follow up on all information he receives with due care. All information received must be treated confidential. If a Compliance Commissioner has accumulated sufficient evidence indicating a potential infringement of the basic principles of the Pfeiffer Vacuum Code of Conduct, he must include the relevant personnel or internal audit department in further proceedings.

 

We expressly encourage all employees to direct all issues pertaining to the Pfeiffer Vacuum Code of Conduct to their Compliance Commissioner or manager. We give our assurance that employees who pass on information to Compliance Commissioners will not suffer any negative consequences as a result.

Compliance Commissioner of the Pfeiffer Vacuum Group is Mrs. Katia Witting-Alvites (Controllling Depart., Phone: +49 (0) 6441 802-130)

Disciplinary measures

Any infringement of the basic principles of the Pfeiffer Vacuum Code of Conduct may result in disciplinary measures or sanctions under labor legislation, in accordance with usual corporate practice.

Asslar, December 2008

Manfred Bender                                 Dr. Matthias Wiemer

Berliner Str. 43

35614 Asslar

Germany

phone +49 (0) 6441 802-0

Besides the laws and regulations in each country there is a number of Conventions and Recommendations from international organizations. They are primarily addressed to Member States and not directly to companies. Nonetheless, they are important guidelines for the conduct of multinational companies and their employees. Pfeiffer Vacuum therefore emphasizes the importance of being globally in accordance with these guidelines. Pfeiffer Vacuum also expects this from its suppliers and business partners.

Hereafter we list the most relevant Conventions of this kind: