Code of Conduct

Code of Conduct The Bertelsmann Code of Conduct Contents Foreword 4. Principles 8. Basic requirements 10. Compliance with the law 11. Freedom to speak up 12. Mutual respect and trust 13. Conflicts of interest 14. Protection of company assets 15. Corporate responsibility 16. Human rights 17. Fair and healthy working conditions 18. Environment and climate protection 19. Business partners and third parties 20. Dealings with business partners 21. Anti-corruption and anti-bribery 23. Fair competition 24.

2.4.6 Statements regarding products and services 35 2.4.7 Information technology use and security 36 2.4.8 Confidentiality and communication 37 3.0 Decision-making guide 38 4.0 Raising concerns and reporting violations 42 4.1 Contacts in your local working environment 46 4.2 Contacts in the Bertelsmann Corporate Center 47

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