Code of Conduct

Code of Conduct of The Quality Group GmbH and its affiliated companies

Code of Conduct
Date: September 2025

1. Our Value Compass

1.1

We, the TQG Group, are a young, growing company in a constantly changing society. We love the challenges that arise from this and try to keep pace with new developments. However, we are also a company with a sense of responsibility towards society, our customers, our employees, and business partners.

1.2

We are committed to living up to this responsibility by making our daily decisions in accordance with specific ethical, moral, and legal standards.

1.3

The Code of Conduct contains the commitment to these standards, which represent our value compass. It serves as a guide and applies to every one of us, regardless of position within our corporate group, and is simultaneously the standard we expect from our business partners. Managers bear a special responsibility in implementing the Code of Conduct. They are responsible for sensitizing their teams to our value compass, providing advice in case of uncertainties, and actively leading by example in complying with the Code of Conduct. Our employees receive regular training on the Code of Conduct and—depending on their area—on further guidelines. The goal is for everyone at the TQG Group to be aware of their responsibility and have a clear understanding of our standards.

2. Respect and Human Dignity

2.1

We respect human dignity and are committed to upholding internationally recognized human rights as set out in the United Nations (UN) Universal Declaration of Human Rights, the International Labour Organization (ILO) Core Labour Standards, and the OECD Guidelines for Multinational Enterprises.

2.2

We strictly reject any form of physical or mental abuse, intimidation, discrimination, and harassment. This specifically includes bullying, verbal or physical assaults, sexual harassment, threats, or unfair treatment of any kind.

2.3

We promote a work environment characterized by respect, openness, equality, and cultural diversity. We see different perspectives as an enrichment.

2.4

We do not tolerate drugs in the workplace and expect employees and third parties to act responsibly.

3. Prohibition of Child Labor and Forced Labor

3.1

We do not tolerate child labor and observe the applicable legal minimum age for admission to employment. In any case, we do not employ persons under the age at which compulsory schooling ends under the law of the place of employment, nor under the age of 15.

3.2

We expect our business partners to take necessary measures to prevent child labor.

3.3

We reject any form of forced or compulsory labor, including any form of debt bondage, serfdom, slavery or slave-like practices, human trafficking, or other involuntary labor and services that are incompatible with internationally recognized labor and social standards.

3.4

Employment must be on a voluntary basis. The withholding of identification documents, unjustified financial sanctions, or restrictions on movement are inadmissible.

4. Fair Remuneration, Compliance with Working Hours, and Occupational Safety

4.1

We comply with legal regulations regarding the remuneration of work. We ensure that the wages we pay do not fall below the applicable statutory minimum wage. Wages and salaries are settled transparently. There are no hidden deductions or unannounced wage waivers. We recognize the right to fair pay as a human right and also take cost of living and social security into account when determining remuneration.

4.2

We comply with legal regulations on working hours, including overtime, rest breaks, and annual leave, and adhere to internationally recognized labor standards.

4.3

The health and safety of our employees is our top priority. We are committed to acting responsibly and creating working conditions that are safe and healthy. To this end, we offer regular medical (preliminary) examinations, among other things. Regular training and guidelines are intended to continuously ensure the high safety standard to which we feel committed. We strictly adhere to all applicable laws and regulations on occupational health and safety at all locations where we operate.

4.4

All employees receive personal protective equipment provided by us—where necessary—and are encouraged to use it properly if required and appropriate. Dangerous or unsafe working conditions must be eliminated immediately—if possible without self-endangerment.

4.5

Furthermore, all employees are obliged to immediately report unsafe situations or behavior that could endanger their own safety or the safety of others.

5. Diversity and Inclusion, Non-Discrimination

5.1

We are as diverse as our society. We value this diversity as an added value and do not discriminate against anyone based on national or ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion, or belief.

5.2

We create a work environment in which all people are treated with respect and have equal opportunities—regardless of personal characteristics or individual backgrounds.

6. Fair Competition

6.1

We stand for fair and transparent competition. Our entrepreneurial actions are based exclusively on legitimate goals and honest business practices. We work with reputable partners and treat them with respect and appreciation.

6.2

Our success is based on performance—not on inadmissible agreements or anti-competitive behavior. We do not engage in discussions with competitors on topics that could impair fair competition. Likewise, we expect our business partners to act independently and in compliance with the law when dealing with their competitors—we do not influence this behavior. We have clear guidelines on topics relevant to competition law. Where sensible and necessary, we conduct targeted training to ensure safe and compliant behavior in competition.

6.3

We consciously refrain from advertising with the brands or intellectual property rights of other companies. We earn the reputation of our products and brands through our own efforts.

7. Prohibition of Corruption and Bribery

7.1

We resolutely reject any form of bribery and corruption—and avoid even the mere appearance of unfair influence. This specifically includes accepting or granting inappropriate invitations, gifts, or other advantages with the aim of influencing business decisions or gaining competitive advantages. We do not offer unfair advantages to third parties and expect the same behavior in return. Our actions are based on transparency, fairness, and traceability. To this end, we have clear internal guidelines that define compliant behavior and serve as a binding guide for employees.

7.2

We act in accordance with all applicable regulations on import and export control. We also follow legal requirements for the prevention of money laundering. Compliance with these regulations is an essential part of our corporate responsibility and our compliance culture.

8. Conflicts of Interest

8.1

We expect all employees to act in the best interest of the TQG Group and to clearly separate personal interests from business decisions. A conflict of interest exists when private or family relationships or personal advantages impair objectivity, loyalty, or freedom of decision in a work context, or create such an appearance.

8.2

Gifts, invitations, and hospitality may only be accepted or granted if they are appropriate, customary, and not likely to influence decisions or create the appearance of influence. Cash or cash equivalents are generally not allowed.

8.3

All employees are obliged to immediately disclose potential or actual conflicts of interest, e.g., to their manager, the compliance department, or via the whistleblower system. Violations of these regulations can lead to disciplinary consequences.

8.4

We have defined binding internal guidelines for the responsible handling of conflicts of interest. These are mandatory for all employees and form the basis for compliant behavior in this area.

9. Data Protection and Confidentiality

9.1

The protection of product developments, business secrets, and confidential information is a top priority for our company. We commit to processing personal data of employees, business partners, and customers in accordance with applicable data protection laws (such as the GDPR) and to ensuring information security through appropriate technical and organizational measures.

9.2

Particularly in direct customer business, the careful handling of sensitive customer information—especially payment and contact details—is of central importance. Therefore, we have an information security program with administrative, technical, and physical protective measures. In the event of a data protection incident, we commit to reporting it immediately and transparently to the relevant authorities. Employees and external partners are required to sign confidentiality agreements and to maintain silence even after the end of the collaboration. Disclosing confidential information or late reporting of security-relevant incidents (e.g., loss of devices with company data) represents a clear violation of our company guidelines.

9.3

Our goal is not only to meet minimum legal requirements but to sustainably strengthen the trust of our customers and partners through an active commitment to data security and confidentiality. We place the highest value on protecting our product developments and other operational and business secrets within our corporate group. To the same extent, we protect sensitive data and confidential information entrusted to us or made accessible by business partners from unauthorized acquisition, use, and disclosure.

9.4

We respect the personal rights of our employees, business partners, and customers and adhere to applicable legal and regulatory requirements for processing personal data and information security when handling personal information. According to our value compass, our community is one of the pillars of our company. Protecting our community and its data is a key pillar of our self-image.

9.5

We have binding guidelines for handling confidential information, which are regularly communicated and made accessible to all employees. Through internal guidelines and training—both general and area-specific—and regular reviews of our standards, we ensure a consistently high level of data protection throughout the company.

10. Product Quality, Product Safety, and Consumer Safety

10.1

The quality and safety of our products are part of the TQG Group’s self-image and have the highest priority. They shape every step from raw material purchasing to the finished product. We develop and produce according to the highest standards that go beyond legal requirements to win the trust of our customers and ensure consistently high product quality.

10.2

Our own production facility is FSSC 22000 certified and operates with a fully implemented HACCP system. Physical product safety is ensured by a multi-stage control system that includes metal and X-ray detectors, magnetic separation, and fine screening. Before a raw material is included in our supply chain, it undergoes a structured testing process including a comprehensive risk assessment. Only trustworthy and qualified partners are approved. Incoming raw materials are checked for purity and identity. Furthermore, additional risk-based controls are regularly carried out by independent external accredited laboratories.

10.3

After production, every product batch is tested for sensory stimuli in our own laboratory. In addition, regular external laboratory tests are carried out by independent, accredited institutes—for example, to check nutrient profiles, analyze possible contaminants, and confirm declaration accuracy.

10.4

Some products are additionally HALAL or organic certified and listed on the Cologne List®.

10.5

We ensure full traceability throughout our entire supply and production chain and are ready for recalls at any time. Our team is trained and supported by external experts.

10.6

Customer feedback is systematically evaluated and complaints are processed within a CAPA (Corrective and Preventive Action) process. Improvement projects are led by Six Sigma-certified teams, supported by external quality experts.

11. Research, Innovation, and Development

11.1

Our Research & Innovation team combines interdisciplinary experience and expertise from medicine, nutritional science, food chemistry, and technology. When developing new products, whether “Better-For-You” products or health and performance supplements, our experts analyze scientific studies to develop the best possible formulations—now supported by AI for even more precision and leverage. Every ingredient and every dosage (incl. additives) is carefully checked against current studies, as well as chemical and technological properties. As soon as new findings are available, existing recipes are updated. Every formulation is reviewed at least once a year.

11.2

Our product developers create our products based on the formulations from the Research & Innovation team. In our own development laboratory, the sensory properties and quality of the product are perfected; for example, every texture and flavor profile is developed in-house—we do not use standard “off-the-shelf” flavors. Our athletes and creators are closely involved in every product and flavor development—as the direct voice of our community. Development only ends when the majority of those involved are satisfied. In practice, this means: no shortcuts. We actively collect feedback from the community. If there is a need for optimization, it is implemented immediately.

12. Sustainability

12.1

Sustainability is part of our corporate responsibility. We are working to consistently anchor ecological, social, and ethical standards in our company. We work with an internationally recognized platform for assessing sustainability performance and align ourselves with their standards to ensure transparency, comparability, and continuous improvement.

12.2

We have a dedicated contact person for the coordination and implementation of our sustainability initiatives. Furthermore, our leadership team is actively involved in strategically anchoring sustainable action and considering it in all areas of the company.

12.3

Our goal is to make sustainability an integral part of our business processes, decision-making bases, and corporate culture step by step.

13. Expectations of Our Producers, Suppliers, Cooperation Partners, and Other Business Partners

13.1

Our Code of Conduct is not just our value compass—it also describes our expectations of producers, suppliers, cooperation partners, and all other business partners in our supply chains.

13.2

The TQG Group is committed to making a positive contribution to society and the environment—through ethical action and the greatest possible transparency. In addition to the separate Code of Conduct for Suppliers and Business Partners, the Code of Conduct formulates minimum standards for our suppliers and service providers to reduce risks in the supply chain and improve traceability. Together with our partners, we want to identify, avoid, and reduce negative impacts on people and the environment at an early stage—in accordance with international standards and applicable national law, particularly for the protection of human rights and the environment.

13.3

We apply different methods of due diligence—including physical audits or equivalent procedures where necessary—both before starting a business relationship and during the contract term, especially in the case of renewals or significant changes.

13.4

In doing so, we also work with Scrioo, a specialized digital compliance platform, to better assess supplier risks and strengthen transparency in our purchasing and risk processes.

14. Reporting Violations

14.1

Anyone who suspects that there is or has been a violation of the aforementioned regulations in a TQG Group company has the opportunity to contact various internal departments or an external body. Among others, supervisors, HR Business Partners, anyone from the Executive Team, the Chief Compliance Officer, or our external ombudsman office are available.

14.2

Reports are reviewed objectively and, if desired, anonymously. Appropriate measures are initiated to clarify the incident, eliminate the violation, and/or prevent further incidents.

14.3

All employees are obliged to immediately report any form of harassment or inappropriate treatment and any violation of the Code of Conduct. We ensure that reports are taken seriously, treated confidentially, and followed up without fear of retaliation.

14.4

Our ombudsperson can be reached via the following channels and processes reports completely anonymously upon request:

Attorney Dr. Kathrin J. Niewiarra, Ombudswoman
Philippistrasse 11
D-14059 Berlin
Tel.: +49 (0) 30 / 4036750-17
TQGG@compliance-aid.com
compliance-aid-tqgg.hintbox.de – Hintbox

14.5

The Chief Compliance Officer can be reached at compliance@tqgg.de.

Signed:
Board of Directors of Asterix HoldCo SE