Code of Conduct of PANALIS Solutions

Independence, responsibility and confidentiality

PANALIS Solutions sees itself as a responsible company and a reliable partner to all stakeholders. This Code of
Conduct is our self-commitment not only to behave in accordance with legal and regulatory requirements. Rather,
the principles set out in this document reflect our values and corporate culture. Among other things, they represent
a commitment to independence, responsibility and confidentiality – in the spirit of sustainable, transparent and
ethically correct cooperation with our partners and customers.
This Code of Conduct applies to all employees of PANALIS Solutions, regardless of function, rank or reputation.


PANALIS Solutions acts as an independent and non-partisan technology provider on behalf of its partners. The
dissemination of information and the political orientation of the search engine as well as the content and analysis
are not influenced by the interests of third parties, the personal interests of employees or the interests of the
company and clients. Our activity in a political environment commits us to the values of the German constitution
and its free-democratic rules in everything we do.

PANALIS Solutions is aware of the responsibility it has for the dissemination of information. We stand for freedom
of information and freedom of speech, although we check information for accuracy and exclude unverified sources.
Verified and audited information sources ensure that the editorial credibility of the publications and the high
standards of legally compliant content are preserved.

Maintaining confidentiality while observing the latest technical and organizational standards is the basis of
cooperation with our customers. All employees of PANALIS Solutions conclude confidentiality agreements.
Confidential information will under no circumstances be passed on to third parties unless there is a legal obligation.
Reports of violations are followed up consistently. Compliance with a data processing agreement enables a
transparent examination of all standards.

We are committed to digitization

The vision of PANALIS Solutions is to digitize business processes in the fields of strategy and politics and thus
improve the processes in political work. As a provider of digital solutions, PANALIS Solutions is committed to a
future-oriented and innovation-driven policy of digital transformation and encourages established associations,
organizations and companies to also be drivers of this development.

Compliance with Laws and Policies
We undertake to comply with all applicable laws, business standards and guidelines – nationally and internationally.
PANALIS Solutions pursues serious, legally unobjectionable and recognized business practices and fair
competition, in particular in compliance with the relevant antitrust and competition law requirements. Together with
the principles of this code of conduct, these regulations must be observed and may not be circumvented through
contractual agreements or comparable measures.
The respective legal regulations for combating corruption must be observed. When dealing with customers,
suppliers and service providers as well as state organizations, the interests of PANALIS and the private interests
of employees on both sides must be strictly separated. We make our decisions free of extraneous considerations
and personal interests. Monetary personal benefits such as invitations to eat, tickets or gifts may be accepted or
granted up to a maximum of €100.00 per business partner and year. All amounts more than this must be reported
to the management and, if necessary, approved.
Furthermore, our employees undertake not to offer, promise, demand, guarantee or accept any gifts, payments,
invitations or services in business transactions that could give the impression that a business relationship could be
improperly influenced.
The use of PANALIS funds and their booking must always be truthful, complete and accurate.
Our employees should avoid situations in which their personal, family or financial interests could conflict with those
of PANALIS. If such a conflict of interest becomes apparent, the employees should consult the responsible
managing director and disclose the conflict of interest.

Indications of bribery or corruption must be reported to the responsible member of management.

Antitrust and Competition Law
We respect fair competition with other market participants and expect our employees and those acting on behalf of
PANALIS Solutions to comply with all applicable domestic and foreign antitrust laws and the laws against unfair
competition. Agreements or activities that influence information, prices or conditions, allocate sales areas or
customers or impede free, open competition in any other impermissible way are prohibited.
Information on anti-competitive or anti-trust behavior must be reported to the responsible member of management.



Secrecy and Data Protection
An open corporate culture like that of PANALIS Solutions finds its limits in business confidentiality and the handling
of personal data. That is why our employees strictly protect company and business secrets. Confidential information
and documents may not be made accessible to unauthorized persons or the public unless express authorization
has been granted.

Occupational safety and health

The health and safety of our employees are important to us. That is why we ensure a safe, healthy and hygienic
working environment. This includes avoiding accidents and damage to health with the help of training, sports and
health offers. PANALIS Solutions provides the means necessary for daily work (protective clothing, skin care
products, etc.). We expect our employees to take responsibility for their health and give them the necessary and
sensible support.

Freedom of organization and assembly
We respect the employees’ freedom of organization and assembly as well as the right to collective bargaining
through their respective representatives and ensure that this is not impaired. We assure that employees who get
involved in this way will not face any negative consequences.

Promotion of employees and training
It is our employees who make up the PANALIS Solutions brand and ultimately the success of the company. That is
why we always treat them with respect and encourage their personal and professional development. If we demand
motivation and open-mindedness, this includes offering employees the appropriate opportunities or paving the way
with training and further education programs. In annual interviews, employees and managers give each other
feedback on their cooperation.

Diversity, equal opportunities and dealing with each other
The PANALIS Solutions values include independence, accountability and confidentiality. We want to treat each
other accordingly. Respect and fairness exclude any form of bullying, verbal or physical harassment, coercion or
We rely on the diversity of our employees. Any discrimination in employment or at work is prohibited. We strictly
prevent any distinction, exclusion or preference based on

– Ethical, national and social origin
– Race
– Skin color
– Gender
– Age
– Nationality
– Creed
– Political opinion
– Membership in a workers’ organization
– Physical or mental disability
– Sexual orientation

or other personal characteristics.



Environmental Protection
We respect the diversity of nature and all creatures that live in it. Accordingly, we are committed to protecting and
preserving them. We design our processes in an environmentally friendly manner and use resources such as paper,
electricity, heating energy, fuel and water sparingly. We avoid waste and adhere to the existing regulations for waste
separation. For business trips, preference should be given to the train over other means of transport wherever

Information, Complaints Procedure, Violations
This code of conduct is made known to all employees. We expect all employees to act responsibly in accordance
with this code of conduct. In the event of a reasonable suspicion of a violation of this code, the relevant member of
management must be informed. All reports are treated confidentially. Employees who report suspected misconduct
in good faith do not have to fear any negative consequences. However, the complaints procedure must not be used
to deliberately make false accusations. We would like to point out that we are legally obliged to pass on legally
relevant information to third parties (e.g. investigative authorities) in individual cases. In these cases, the reporting
person may be called as a witness.