{"id":14691,"date":"2026-02-03T10:16:15","date_gmt":"2026-02-03T09:16:15","guid":{"rendered":"https:\/\/curato.de\/code-of-conduct\/"},"modified":"2026-03-26T15:25:28","modified_gmt":"2026-03-26T14:25:28","slug":"code-of-conduct","status":"publish","type":"page","link":"https:\/\/curato.de\/en\/code-of-conduct\/","title":{"rendered":"Code of Conduct"},"content":{"rendered":"<p><div class=\"fusion-fullwidth fullwidth-box fusion-builder-row-1 fusion-flex-container has-pattern-background has-mask-background nonhundred-percent-fullwidth non-hundred-percent-height-scrolling\" style=\"--awb-border-radius-top-left:0px;--awb-border-radius-top-right:0px;--awb-border-radius-bottom-right:0px;--awb-border-radius-bottom-left:0px;--awb-padding-top:220px;--awb-padding-right:80px;--awb-padding-bottom:80px;--awb-padding-left:80px;--awb-padding-top-medium:180px;--awb-padding-right-medium:40px;--awb-padding-bottom-medium:80px;--awb-padding-left-medium:40px;--awb-padding-top-small:120px;--awb-padding-right-small:10px;--awb-padding-bottom-small:40px;--awb-padding-left-small:10px;--awb-background-color:#f9f9f9;--awb-flex-wrap:wrap;\" id=\"faq\" ><div class=\"fusion-builder-row fusion-row fusion-flex-align-items-flex-start fusion-flex-justify-content-center fusion-flex-content-wrap\" style=\"max-width:calc( 1700px + 10px );margin-left: calc(-10px \/ 2 );margin-right: calc(-10px \/ 2 );\"><div class=\"fusion-layout-column fusion_builder_column fusion-builder-column-0 fusion_builder_column_3_4 3_4 fusion-flex-column fusion-flex-align-self-flex-start fusion-column-no-min-height\" style=\"--awb-padding-right-medium:0px;--awb-padding-left-medium:0px;--awb-padding-right-small:14px;--awb-padding-left-small:14px;--awb-bg-blend:overlay;--awb-bg-size:cover;--awb-width-large:75%;--awb-margin-top-large:0px;--awb-spacing-right-large:5px;--awb-margin-bottom-large:0px;--awb-spacing-left-large:5px;--awb-width-medium:100%;--awb-order-medium:0;--awb-spacing-right-medium:5px;--awb-spacing-left-medium:5px;--awb-width-small:100%;--awb-order-small:0;--awb-spacing-right-small:5px;--awb-spacing-left-small:5px;\" data-scroll-devices=\"small-visibility,medium-visibility,large-visibility\"><div class=\"fusion-column-wrapper fusion-column-has-shadow fusion-flex-justify-content-flex-start fusion-content-layout-column\"><div class=\"fusion-title title fusion-title-1 fusion-sep-none fusion-title-center fusion-title-text fusion-title-size-one\" style=\"--awb-margin-bottom:40px;--awb-margin-top-small:10px;--awb-margin-right-small:0px;--awb-margin-bottom-small:10px;--awb-margin-left-small:0px;--awb-font-size:72px;\"><h1 class=\"fusion-title-heading title-heading-center\" style=\"font-family:&quot;Archivo Black&quot;;font-style:normal;font-weight:400;margin:0;letter-spacing:var(--awb-typography1-letter-spacing);text-transform:var(--awb-typography1-text-transform);font-size:1em;line-height:var(--awb-typography1-line-height);\">Code of Conduct<\/h1><\/div><div class=\"fusion-text fusion-text-1 fusion-text-no-margin\" style=\"--awb-content-alignment:center;--awb-font-size:var(--awb-typography2-font-size);--awb-line-height:var(--awb-typography2-line-height);--awb-letter-spacing:var(--awb-typography2-letter-spacing);--awb-text-transform:var(--awb-typography2-text-transform);--awb-text-color:var(--awb-color5);--awb-margin-top:0px;--awb-margin-bottom:10px;--awb-text-font-family:var(--awb-typography2-font-family);--awb-text-font-weight:var(--awb-typography2-font-weight);--awb-text-font-style:var(--awb-typography2-font-style);\"><p>Policy for Proper Conduct Within the Company<\/p>\n<\/div><\/div><\/div><\/div><\/div><div class=\"fusion-fullwidth fullwidth-box fusion-builder-row-2 fusion-flex-container has-pattern-background has-mask-background nonhundred-percent-fullwidth non-hundred-percent-height-scrolling\" style=\"--awb-border-radius-top-left:0px;--awb-border-radius-top-right:0px;--awb-border-radius-bottom-right:0px;--awb-border-radius-bottom-left:0px;--awb-padding-top:80px;--awb-padding-right:80px;--awb-padding-bottom:180px;--awb-padding-left:80px;--awb-padding-top-medium:40px;--awb-padding-right-medium:40px;--awb-padding-bottom-medium:80px;--awb-padding-left-medium:40px;--awb-padding-top-small:0px;--awb-padding-right-small:24px;--awb-padding-bottom-small:40px;--awb-padding-left-small:24px;--awb-flex-wrap:wrap;\" ><div class=\"fusion-builder-row fusion-row fusion-flex-align-items-flex-start fusion-flex-justify-content-center fusion-flex-content-wrap\" style=\"max-width:calc( 1700px + 10px );margin-left: calc(-10px \/ 2 );margin-right: calc(-10px \/ 2 );\"><div class=\"fusion-layout-column fusion_builder_column fusion-builder-column-1 fusion_builder_column_3_4 3_4 fusion-flex-column\" style=\"--awb-padding-top:80px;--awb-padding-right:120px;--awb-padding-bottom:80px;--awb-padding-left:120px;--awb-padding-top-medium:0px;--awb-padding-right-medium:40px;--awb-padding-bottom-medium:80px;--awb-padding-left-medium:40px;--awb-padding-top-small:0px;--awb-padding-right-small:24px;--awb-padding-bottom-small:40px;--awb-padding-left-small:24px;--awb-overflow:hidden;--awb-bg-color:var(--awb-color1);--awb-bg-color-hover:var(--awb-color1);--awb-bg-size:cover;--awb-box-shadow:0px 0px 47px 39px rgba(211,211,211,0.2);;--awb-border-radius:30px 0px 30px 30px;--awb-width-large:75%;--awb-margin-top-large:0px;--awb-spacing-right-large:5px;--awb-margin-bottom-large:10px;--awb-spacing-left-large:5px;--awb-width-medium:100%;--awb-order-medium:0;--awb-spacing-right-medium:5px;--awb-spacing-left-medium:5px;--awb-width-small:100%;--awb-order-small:0;--awb-spacing-right-small:5px;--awb-spacing-left-small:5px;\"><div class=\"fusion-column-wrapper fusion-column-has-shadow fusion-flex-justify-content-flex-start fusion-content-layout-column\"><div class=\"fusion-text fusion-text-2\" style=\"--awb-font-size:var(--awb-typography4-font-size);--awb-line-height:var(--awb-typography4-line-height);--awb-letter-spacing:var(--awb-typography4-letter-spacing);--awb-text-transform:var(--awb-typography4-text-transform);--awb-text-color:var(--awb-color4);--awb-text-font-family:var(--awb-typography4-font-family);--awb-text-font-weight:var(--awb-typography4-font-weight);--awb-text-font-style:var(--awb-typography4-font-style);\"><h2>A. Objectives and Compliance Organization<\/h2>\n<h3>I. Objectives<\/h3>\n<p>The success of Curato Holding AG (hereinafter referred to as \u201cCurato\u201d) depends to a significant extent on all employees consistently upholding and implementing Curato\u2019s corporate values at all times and in all places. The Code of Conduct is intended to help you apply Curato\u2019s values and objectives in your daily work. It therefore sets out standards of conduct and guidelines designed to enable you to comply with all applicable obligations.  <\/p>\n<p>The Code provides guidance on how to handle, among other things, topics such as invitations, data protection, competitors, as well as financial integrity.<\/p>\n<p>We are all collectively \u2014 as well as each individual \u2014 responsible for implementing and complying with this Code of Conduct. Business results must never be valued above integrity. Failure to adhere to these principles may result in significant harm both to you personally and to Curato as a whole.<br \/>For this reason, the Management Board monitors and reviews compliance with the Code of Conduct and the requirements arising from it. In doing so, it engages the support of an external law firm, which assists the Compliance Officer in the performance of their duties on a case-by-case basis.   <\/p>\n<p>Curato is committed to fostering a strong compliance culture built on integrity, transparency, and a sense of responsibility. Every employee actively contributes to strengthening this corporate culture through their conduct. <\/p>\n<h3>II. Compliance Organization<\/h3>\n<h4>1. Compliance Responsibility<\/h4>\n<p style=\"padding-left: 40px\">Compliance is a responsibility of the entire organization and must be upheld equally by both managers and employees. In addition to serving as role models, managers have a particular duty to foster an environment in which ethical conduct is promoted and violations are identified at an early stage \u2014 through exemplary behavior, open communication, and consistent action.<br \/>They are also responsible for ensuring that all employees within their area of responsibility are familiar with this Code of Conduct and the associated compliance policies, and that these are duly observed.  <\/p>\n<p style=\"padding-left: 40px\">It is essential that every Curato employee takes responsibility for complying with all applicable laws, regulations, and corporate policies. Always bear in mind that violations of the law may have serious consequences both for you personally and for Curato. <\/p>\n<h4>2. Compliance Reporting<\/h4>\n<p style=\"padding-left: 40px\">If there are indications of a violation of this Code of Conduct or the associated Curato compliance policies, all employees are expected to report such matters to their supervisor, the Management Board, or Curato\u2019s Compliance Officer. The Management Board and the Compliance Officer shall keep each other informed of any reports they receive. <\/p>\n<p style=\"padding-left: 40px\">The Compliance Officer will treat your reports confidentially and, where legally permissible, anonymously upon your request.<\/p>\n<p style=\"padding-left: 40px\">In addition, an internal whistleblowing channel is available to you (<a href=\"https:\/\/portal.bdolegal-whistleblower.de\/\" target=\"_blank\" rel=\"noopener noreferrer\">https:\/\/portal.bdolegal-whistleblower.de\/<\/a>), through which you can also submit reports anonymously in accordance with the Whistleblower Protection Act. This whistleblowing portal is managed by three external lawyers acting as ombudspersons. No one may be disadvantaged for making a report in good faith.  <\/p>\n<h4>3. Questions in Cases of Doubt<\/h4>\n<p style=\"padding-left: 40px\">This Code of Conduct, including its annexes, cannot address all questions that may arise in your daily work. It is therefore supplemented by additional company policies and employment-related provisions. You should always be familiar with the topics covered in this Code.  <\/p>\n<p style=\"padding-left: 40px\">We trust that, in cases of doubt, you will seek advice from the Management Board or the Compliance Officer and report any violations of laws or corporate policies that you become aware of.<\/p>\n<p style=\"padding-left: 40px\">All employees are required to report known or suspected violations without undue delay. Early action protects both the company and its employees. <\/p>\n<p style=\"padding-left: 40px\">Individuals who seek advice or submit a compliance report in the event of a suspected issue need not fear any adverse measures from Curato. Our primary concern is that potential issues are raised in a timely manner. The foremost objective is compliance with the law and the protection of the company. By making a prompt and, from your perspective, justified inquiry or report, you not only protect the company but also yourself and the security of your position.   <\/p>\n<h2>B. Scope and Binding Nature<\/h2>\n<p>This Code of Conduct, including its annexes, applies to all Curato companies, managers, and employees. This includes all companies that are affiliated with Curato Holding AG within the meaning of corporate law. <\/p>\n<p>In addition to this Code of Conduct, all other Curato policies referenced in this document shall apply at all times.<\/p>\n<p>All provisions set out in this Code of Conduct are binding. Any deviations from the rules contained in this Code of Conduct are only permissible with the prior approval of the Management Board or the Compliance Officer of Curato. <\/p>\n<p>This Code of Conduct must also be complied with where applicable laws or regulations are less stringent. Please note, however, that stricter laws and regulations than those set out in this Code of Conduct may apply. In such cases, those stricter laws and regulations shall prevail.  <\/p>\n<h2>C. General Principles of Our Conduct<\/h2>\n<p>Violations of laws, other binding regulations, or internal policies may result in criminal, employment-related, and civil consequences for the Curato employees involved. For Curato, such violations may lead to substantial fines, regulatory sanctions, claims for damages from customers or competitors, as well as serious reputational harm.<br \/>In addition, regulatory investigations, internal inquiries, or negative media coverage resulting from breaches of applicable laws or other rules may adversely affect Curato\u2019s business operations.  <\/p>\n<p>Such risks and damages may have a lasting impact on the economic viability and survival of the affected company. Ultimately, such conduct therefore jeopardizes the jobs of all Curato employees. <\/p>\n<p>Curato expects its employees to act in a lawful, honest, and loyal manner in the course of their business activities and in all matters related to such activities.<\/p>\n<h2>D. Key Specific Provisions<\/h2>\n<h3>I. Combating Corruption<\/h3>\n<p>Corruption impedes progress and innovation, distorts competition, and can significantly damage Curato\u2019s reputation and financial integrity. Curato rejects and actively combats all forms of corruption. <\/p>\n<p>Curato employees are strictly prohibited from influencing decisions by granting advantages of any kind. This applies both to public officials and to employees of other companies and institutions, whether domestically or abroad. <\/p>\n<p>Corrupt conduct is often\u2014though not exclusively\u2014associated with the granting of benefits to and from business partners (e.g. invitations, gifts, donations). The acceptance and granting of such benefits within existing business relationships is customary and generally permissible, provided that it remains within an appropriate scope. However, if this scope is exceeded, the individuals involved may be suspected of bribery or corruption.  <\/p>\n<p>Corruption is a widespread societal issue in many industries and countries and, moreover, constitutes a serious violation of the law in most jurisdictions, which may result in severe penalties, including substantial prison sentences.<\/p>\n<p>In addition to social condemnation, bribery and corruption also constitute a significant economic risk for any affected company. Beyond the criminal liability of the employees involved and the substantial fines imposed on the company, corrupt practices can cause severe reputational damage, the economic consequences of which are difficult to predict and may threaten the existence of Curato and, consequently, all jobs within the company. <\/p>\n<p>The Anti-Corruption Policy, which applies in addition to this Code of Conduct, is binding for all Curato employees. It is attached to this Code of Conduct as <b>Annex 1<\/b>. Curato clearly expects all employees to familiarize themselves with it and to observe it in their daily work.  <\/p>\n<p>In cases of doubt, please consult the Management Board or the Compliance Officer in advance.<\/p>\n<h3>II. Prohibition of Money Laundering &amp; Terrorist Financing<\/h3>\n<p>Effective efforts to combat terrorism, drug-related crime, and organized crime begin on the financial side.<\/p>\n<p>Curato expressly prohibits all forms of money laundering and any involvement therein.<\/p>\n<p>Curato is required to comply with all applicable anti-money laundering laws. These include, among other things, the obligation to identify contractual partners, to use permissible forms of payment, and to determine how potential money laundering activities can be detected. <\/p>\n<p>Money laundering is understood to mean the introduction of illegally obtained funds or assets into the legitimate financial and economic system. Curato combats all forms of money laundering and takes measures to avoid becoming involved in money laundering activities. It may constitute a criminal offense to accept, invest, or hold assets if they originate from certain criminal activities.  <\/p>\n<p>It is particularly important to note that a person may also be liable to prosecution if they negligently fail to recognize the origin of an asset. If, out of gross negligence or indifference, you disregard an obvious suspicion regarding the origin of certain assets, you may be committing a criminal offense. <\/p>\n<p>The prohibition equally extends to the financing of terrorism. In the event of any irregularities (e.g. unusual payment methods, cash payments, accounts in third countries), the transaction must be halted and the Compliance Officer must be informed. <\/p>\n<p>You should therefore always obtain appropriate information about your customer or other business partner in accordance with legal requirements (Know Your Customer principle).<\/p>\n<h3>III. Fair Competition and Procurement<\/h3>\n<p>Curato is committed to independent, free, and fair competition, which is protected by national and international competition and antitrust laws. Violations of competition and antitrust law are prosecuted worldwide by antitrust and law enforcement authorities and may result in severe, potentially existential sanctions amounting to millions for the companies involved, as well as significant penalties for managers and employees. <\/p>\n<p>Furthermore, agreements may be rendered invalid, third parties may assert claims for damages against Curato, and there is a risk of reputational harm and negative publicity if legal violations become public.<\/p>\n<p>Anti-competitive and restrictive practices are not tolerated at Curato. Instead, customers and other business partners should be convinced by the quality of our services. <\/p>\n<p>To prevent harm to Curato arising from antitrust and competition law violations, the Antitrust Policy, which applies in addition to this Code of Conduct, is binding for all Curato employees. It is attached to this Code of Conduct as <b>Annex 3<\/b>. Curato clearly expects all employees to familiarize themselves with it and to observe it in their daily work.  <\/p>\n<h3>IV. Avoidance of Conflicts of Interest<\/h3>\n<p>Conflicts of interest may give rise to doubts about the quality of business decisions made and the integrity of the individuals making such decisions.<\/p>\n<p>All Curato employees are obliged to act with full loyalty towards the company. Each employee commits to making business decisions solely on the basis of objective and fair criteria, without regard to personal interests. <\/p>\n<p>A breach of this duty occurs if you act in a manner that conflicts with the interests of the company or is likely to give rise to such a conflict.<\/p>\n<p>A conflict of interest may arise where an employee takes action intended to obtain a benefit or advantage for themselves or for a third party close to them.<\/p>\n<p>As guidance and a standard of conduct for identifying when a conflict of interest exists and how to act in such cases, the Management Board of Curato has issued a Conflicts of Interest Policy, which applies in addition to this Code of Conduct and is binding for all Curato employees. It is attached to this Code of Conduct as <b>Annex 4<\/b>. Curato clearly expects all employees to familiarize themselves with it and to observe it in their daily work.  <\/p>\n<h3>V. Fair Employment and Workplace Safety<\/h3>\n<p>Curato is committed to fair employment conditions and actively combats all forms of illegal employment. Illegal employment relationships can jeopardize legitimate jobs and hinder the creation of new lawful employment opportunities. <\/p>\n<p>Curato is committed to international human rights and categorically rejects all forms of child labor. Curato actively promotes diversity, equality, and inclusion. All employees should have equal opportunities regardless of origin, gender, age, religion, disability, or sexual identity.  <\/p>\n<p>Curato employees can only deliver the required performance in a safe working environment. Therefore, every Curato employee is required to comply with all occupational health and safety regulations. <\/p>\n<p>Drug and alcohol abuse pose a serious risk to Curato, particularly to the safety, health, and productivity of its employees.<\/p>\n<p>Curato therefore does not tolerate the possession, use, or procurement of drugs on company premises. The term \u201cdrugs\u201d refers to substances whose possession, use, procurement, or attempted procurement is prohibited or restricted under applicable local laws. In particular, it is not tolerated that employees are under the influence of drugs during working hours.  <\/p>\n<p>The consumption of alcohol on company premises is generally prohibited. Exceptions require prior approval from management and may, for example, be granted for company-organized events. Employees must not be under the influence of alcohol during working hours.  <\/p>\n<p>Be vigilant and promptly inform your supervisor, the Management Board, or the Compliance Officer if you identify any risks that may endanger the safety of your workplace.<\/p>\n<h3>VI. Protection of Company Assets, Trade and Business Secrets, and Confidential Information<\/h3>\n<p>Curato\u2019s company assets are intended to support the achievement of Curato\u2019s business objectives and may be used exclusively for business purposes. Curato expects its employees to handle company assets with care and in the best interests of the company. Every employee is responsible for ensuring that company assets are not damaged, misused, or wasted.   <\/p>\n<p>In addition, every employee is required to remain vigilant and to report theft, embezzlement, misappropriation, fraud, and other offenses.<\/p>\n<p>These rules apply equally to Curato\u2019s assets and to the assets of third parties to which you are granted access in the course of your duties or on occasion.<\/p>\n<p>Curato possesses valuable know-how as well as extensive trade and business secrets. This knowledge forms the basis of our business success and is therefore subject to a particular need for protection. <\/p>\n<p>Confidential information includes all information relating to Curato, as well as to Curato\u2019s customers and business partners, that is not publicly known and is disclosed to our company on a confidential basis or becomes known in any other way. Even the existence of a contractual relationship with a customer may fall under this definition. <\/p>\n<p>Curato fully respects the intellectual property of competitors and business partners. Every employee is required to keep third-party know-how as well as trade and business secrets confidential and to use them only within the scope of their intended disclosure and the agreed framework. <\/p>\n<p>Employees must not misuse confidential information for their own benefit or disclose it to third parties without authorization.<\/p>\n<p>The disclosure of such confidential information is prohibited both during and after the termination of the employment relationship and, in case of doubt, is only permissible in coordination with the Management Board. Even with approval, such information may only be disclosed to individuals who have a legitimate and appropriate interest in receiving it (\u201cneed-to-know\u201d basis). Data may only be stored on secure systems authorized by the company.  <\/p>\n<p>Es kann auch strafbar sein, sich vertrauliche Informationen von Dritten (z.B. Wettbewerbern oder auch Kunden) ohne Zustimmung des Dritten zu verschaffen. Dies w\u00e4re zum Beispiel der Fall, wenn Sie einen abgeworbenen Mitarbeiter dazu anhalten, sich vor dem Ausscheiden bei dem Wettbewerber noch dessen Kundenstamm oder andere Daten zu sichern. <\/p>\n<p>In cases of doubt, please contact the Compliance Officer.<\/p>\n<h3>VII. Data Protection, Data Security, and IT Security<\/h3>\n<p>Special legal provisions exist for the protection of personal data. Curato recognizes the particular importance of data protection and data security and is fully committed to complying with all applicable legal requirements. <\/p>\n<p>Personal data of all kinds must be carefully protected against unauthorized access and misuse.<\/p>\n<p>The company continuously reviews the application of data protection and data security rules, as well as their practical implementation, and updates them where necessary. In doing so, Curato is supported by a Data Protection Officer, who is available to assist you with any questions in this area. <\/p>\n<p>Information technology (IT) and electronic data processing (EDP) are indispensable in Curato\u2019s daily operations. While they facilitate the handling of information, they also give rise to new risks. Curato takes these risks very seriously, both in its own interest and in the interest of its customers and other business partners, and addresses vulnerabilities promptly as they become known while implementing appropriate protective measures.<br \/>Curato employees are required to familiarize themselves with the applicable IT\/EDP policies and to comply with the requirements set out therein. In particular, always ensure that the IT systems you use are adequately protected against unauthorized access. Do not leave your workstation without locking your screen. Change your passwords regularly and use only passwords that meet current security standards. Do not share passwords with third parties.       <\/p>\n<p>Be aware that email is not a secure means of communication. Confidential information should therefore only be sent by email in exceptional cases and must be encrypted when doing so. <\/p>\n<p>The internet, intranet, and email communication are essential tools in our daily work.<\/p>\n<p>Do not use Curato\u2019s IT systems for personal matters. In particular, do not store or download any content from the internet or other third-party systems onto Curato\u2019s network unless this is required for business purposes. The use of our IT systems for illegal purposes is strictly prohibited.<br \/>Inappropriate use of the internet, intranet, email, or computer systems is not permitted. Inappropriate use includes, in particular, unauthorized access to another user\u2019s email account, the unauthorized transmission of secret or confidential information, the sending of offensive materials or messages, the transmission of materials that infringe third-party copyrights, as well as other unlawful or unethical activities.<br \/>Please ensure that you comply with all internal policies governing the use of information and communication technology.     <\/p>\n<p>In cases of doubt, please contact Curato\u2019s Data Protection Officer.<\/p>\n<p>All employees are required to report data protection breaches (e.g. loss of documents, misdirected transmission of personal data) to the Data Protection Officer without undue delay<br \/> (<a href=\"helmke@agad.de\">helmke@agad.de<\/a>).<\/p>\n<h3>VIII. Equal Opportunity, Equal Treatment, Mutual Respect, and Non-Discrimination<\/h3>\n<p>We are committed to the principles of respectful, fair, and loyal interaction with one another. In particular, the principles of equal opportunity, equal treatment, and mutual respect play a central role. All employees are provided with equal opportunities both at the time of hiring and throughout their employment with Curato.<br \/>Curato rejects all forms of discrimination and will take action against it. In particular, no one may be disadvantaged or harassed on the basis of ethnic origin, gender, sexual orientation, religion or belief, disability, age, or similar factors. Instead, we expect our employees to treat one another with tolerance, courtesy, and respect, thereby contributing to a productive and positive working environment.     <\/p>\n<p>The Anti-Discrimination and Anti-Harassment Policy, which applies in addition to this Code of Conduct, is binding for all Curato employees. It is attached to this Code of Conduct as <b>Annex 5<\/b>. Curato clearly expects all employees to familiarize themselves with it and to observe it in their daily work. <\/p>\n<p>Curato reserves the right to take disciplinary action against employees who treat or harass other employees, customers, or suppliers in an improper manner. Disciplinary measures may also include the issuance of ordinary or extraordinary termination of employment. <\/p>\n<h3>IX. Dealings with Business Partners<\/h3>\n<p>Curato is aware that its customers and other business partners rely on the quality of its services. Therefore, Curato works with its business partners in a spirit of trust and on a fair basis for both parties.<br \/>We aim to be perceived by our customers as the company that best understands and meets their needs and provides the most competent solutions. We are guided by our customers\u2019 requirements and act in a results-oriented manner, without disregarding applicable laws, regulations, and rules.   <\/p>\n<p>Curato also expects its business partners to act in a lawful and ethical manner. Please ensure that you inform yourself about any additional specific requirements of the customer or other business partner and to what extent these must also be observed by our company when entering into a business relationship with them. <\/p>\n<p>We provide only truthful and complete information to (potential) customers regarding our services. False statements and misleading information must be avoided, as they may result in legal consequences, such as claims for damages. <\/p>\n<p>Before entering into a new business relationship, a compliance review (Business Partner Check) is conducted to assess risks related to corruption, human rights, and sustainability.<\/p>\n<h3>X. Social Responsibility<\/h3>\n<p>Curato assumes social responsibility and aims to make a positive contribution to the well-being of all. Only within a stable environment can Curato achieve sustainable economic success.  <\/p>\n<p>Any engagement in or support for political parties on behalf of Curato, as well as donations or other contributions in the form of monetary or non-monetary benefits in Curato\u2019s name, require prior approval from Curato. The same applies to the organization of any political events on company premises or in business facilities. <\/p>\n<p>You are, of course, free to engage in political activities in a private capacity, provided that you do not act as an employee or representative of Curato. If such political involvement affects the interests of Curato, prior approval must be obtained from the company. Curato supports sustainable projects and is committed to responsible engagement in line with ESG principles.  <\/p>\n<h3>XI. Political Activities, Donations &amp; Sponsorship<\/h3>\n<p>Political activities on behalf of Curato are prohibited. Party donations and donations\/sponsorships may only be made in accordance with the four-eyes principle, following prior review (compliance\/tax) and with transparent documentation (recipient, amount, purpose). Benefits to public authorities or officials are not permitted; hospitality is allowed only within the framework of the Anti-Corruption Policy.  <\/p>\n<h3>XII. Environment<\/h3>\n<p>Curato is aware of its environmental responsibility, recognizes the importance of global environmental protection, and complies with all applicable environmental laws and principles. Curato strives to achieve climate neutrality and is committed to using resources efficiently and continuously reducing CO\u2082 emissions. <\/p>\n<p>Curato is committed to compliance with product- and substance-related regulations and expects all departments dealing with raw materials or materials to provide evidence of conflict-free sourcing throughout the supply chain. Any suspected cases must be reported to Procurement and Compliance. <\/p>\n<h3>XIII. Export Control, Sanctions &amp; Foreign Trade Law<\/h3>\n<p>Curato and all employees strictly comply with international export\/import and sanctions regulations (including EU sanctions law and dual-use rules). Business relationships with sanctioned individuals, organizations, or countries are prohibited.<br \/>Prior to entering into cross-border service agreements, a sanctions and export control review must be carried out by the responsible departments. Any violations must be reported to the Compliance Officer without undue delay.   <\/p>\n<h3>XIV. Taxes, Tax Strategy &amp; Tax Compliance<\/h3>\n<p>Curato fulfills all tax obligations accurately and on time (direct and indirect taxes). Tax planning follows the arm\u2019s length principle and does not pursue purely tax-driven purposes without economic substance. Interactions with tax authorities are conducted in a cooperative and transparent manner.<br \/>Internal policies govern transfer pricing and documentation; any violations must be reported.   <\/p>\n<h3>XV. Insider Trading &amp; Handling of Insider Information<\/h3>\n<p>The use of non-public, material information (e.g. relating to financial results, M&amp;A activities, or pricing strategies of major customers or suppliers) for trading in securities \u2014 including those of third parties \u2014 is prohibited. Insider information must not be disclosed or used to make recommendations. In cases of doubt, the Compliance Officer must be consulted prior to any transaction.  <\/p>\n<h3>XVI. Cooperation and Dealings with Authorities<\/h3>\n<p>Curato seeks to cooperate with public authorities in a spirit of trust and in accordance with applicable law. Accordingly, all lawful orders issued by public authorities must be complied with, while at the same time safeguarding the legal rights of the company. <\/p>\n<p>In the course of ordinary business or as part of a formal investigation, representatives of authorities or public officials may direct specific inquiries to Curato. If you are confronted with official requests or investigative measures, you must always inform the local Legal Department without undue delay, act cooperatively, and comply with the relevant internal policies. <\/p>\n<h3>XVII. Use of Artificial Intelligence (AI) &amp; Automated Tools<\/h3>\n<p>The use of AI systems must be responsible, secure, and compliant with applicable laws. Prior to use, risks (data protection, intellectual property, bias, reliability) must be assessed; personal data or confidential information may only be processed with appropriate authorization and safeguards in place.<br \/>The use of unauthorized or unapproved AI tools is prohibited. Outputs generated by AI must be clearly identified as such and subject to professional review. All applicable internal policies must be observed.    <\/p>\n<h3>XVIII. Media Relations, Social Media &amp; Public Appearances<\/h3>\n<p>As a company, our reputation largely depends on how we are perceived externally, particularly in our interactions with the media. It is therefore essential for our public image to present a consistent external appearance and to provide truthful information. <\/p>\n<p>All media inquiries must therefore be forwarded to the responsible department. You are not permitted to make written or verbal statements on behalf of or about Curato to media representatives without prior approval from the company. <\/p>\n<p>Publications, presentations, and interviews that relate to Curato should also be coordinated with the responsible department in order to maintain a consistent public image.<\/p>\n<p>If, after receiving approval, you speak with media representatives or in public about our business, you should always exercise sound judgment. If you have any concerns regarding specific media inquiries, the responsible department will provide you with all necessary information and support. <\/p>\n<p>Employees also represent Curato on social media. Posts must be lawful, respectful, and truthful. In particular:<br \/>(i) Do not publish any confidential, internal, or personal information (confidentiality\/GDPR).<br \/>(ii) Do not speak on behalf of Curato or use logos\/trademarks without explicit authorization; clearly identify personal opinions as such.<br \/>(iii) Do not post derogatory, discriminatory, or reputation-damaging content; adhere to appropriate standards of online conduct.<br \/>(iv) Do not share or use copyrighted content without the necessary rights.<br \/>(v) Do not use insider information to influence markets or prices.<br \/>(vi) In the event of inquiries regarding crises, legal matters, or business topics: refer them to the PR department.<br \/>Violations may result in employment-related disciplinary action.         <\/p>\n<h3>XIX. Retention of Documents and Records<\/h3>\n<p>In order for Curato to meet its record retention obligations, you must properly and carefully maintain the documents and records within your area of responsibility. You are also responsible for ensuring the completeness of the documentation and must be familiar with the storage and retrieval of data relating to the documents and records for which you are responsible. <\/p>\n<p>Please also ensure that, within your area of responsibility, you are informed about which documents and records must be retained, in what form (e.g. as originals or in electronic form), and for how long. The destruction or alteration of documents and records subject to retention obligations before the expiry of the applicable retention period may significantly hinder or impede investigations, (tax) audits, and the successful conduct of legal proceedings, thereby causing substantial harm to Curato. <\/p>\n<h2>E. Investigation of Suspected Compliance Violations<\/h2>\n<p>Every suspected case of a compliance violation will be investigated and clarified by Curato in an impartial manner.<\/p>\n<h2>F. Training<\/h2>\n<p>Curato conducts regular training sessions and informational events on the contents of this Code of Conduct and the associated compliance policies in order to ensure and promote awareness and understanding of the requirements set out therein.<\/p>\n<h2>G. Monitoring \/ Audit \/ Reporting of Violations (\u201cWhistleblowing\u201d)<\/h2>\n<p>Curato monitors compliance with this Code of Conduct and the associated compliance policies through appropriate reviews and, where necessary, makes use of external support.<\/p>\n<p>If you become aware of any conduct that violates the rules set out in this Code of Conduct or in other applicable laws and regulations and\/or constitutes a criminal offense (\u201cviolation\u201d), you should inform your supervisor, the Management Board, the Compliance Officer, or another appropriate person within the company.<\/p>\n<p>A whistleblowing portal is also available for reporting concerns at <a href=\"https:\/\/portal.bdolegal-whistleblower.de\/\" target=\"_blank\" rel=\"noopener noreferrer\">https:\/\/portal.bdolegal-whistleblower.de\/<\/a>, where you can find further information on the intranet.<\/p>\n<p>The Whistleblowing Policy, which applies in addition to this Code of Conduct, is binding for all Curato employees. It is attached to this Code of Conduct as <b>Annex 6<\/b>. Curato clearly expects all employees to familiarize themselves with it and to observe it in their daily work.  <\/p>\n<h2>H. Contact Persons<\/h2>\n<p>For all questions relating to this Code, its annexes, or any other legal matters, you may contact your respective supervisor, the Management Board, or the Compliance Officer. In the area of data protection, a Data Protection Officer is also available to you as a point of contact. <\/p>\n<h3>I. Compliance Officer<\/h3>\n<p>Curato\u2019s Compliance Officer is the designated internal point of contact for all matters relating to compliance, corporate governance, and internal policies.<\/p>\n<h4>You can reach the Compliance Officer using the following contact details:<\/h4>\n<p style=\"padding-left: 40px\">Mrs. Julia Wiesehahn<br \/>Curato Holding AG<br \/>Schiessstra\u00dfe 47 &#8211; 49<br \/>40549 D\u00fcsseldorf<br \/>0178 356 2363 \/ <a href=\"mailto:j.wiesehahn@curato.de\">j.wiesehahn@curato.de<\/a><\/p>\n<h3>II. Data Protection Officer<\/h3>\n<p>Curato\u2019s Data Protection Officer is available to you as a point of contact for all matters relating to data protection at Curato.<\/p>\n<h4>You can reach Curato\u2019s Data Protection Officer using the following contact details:<\/h4>\n<p style=\"padding-left: 40px\">Mr. Dr. Nils Helmke (Rechtsanwalt)<br \/>Waldring 43 \u2013 47<br \/>44789 Bochum<br \/>0234 282 533-20 \/ <a href=\"mailto:helmke@agad.de\">helmke@agad.de<\/a><\/p>\n<\/div><div class=\"fusion-text fusion-text-3 small-text\" style=\"--awb-content-alignment:right;--awb-font-size:var(--awb-typography5-font-size);--awb-line-height:var(--awb-typography5-line-height);--awb-letter-spacing:var(--awb-typography5-letter-spacing);--awb-text-transform:var(--awb-typography5-text-transform);--awb-margin-top:40px;--awb-text-font-family:var(--awb-typography5-font-family);--awb-text-font-weight:var(--awb-typography5-font-weight);--awb-text-font-style:var(--awb-typography5-font-style);\"><p><em><strong>Status as of<\/strong><\/em><br \/><em>February 2026<\/em><\/p>\n<\/div><\/div><\/div><\/div><\/div><\/p>\n","protected":false},"excerpt":{"rendered":"","protected":false},"author":2,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"open","template":"100-width.php","meta":{"footnotes":""},"class_list":["post-14691","page","type-page","status-publish","hentry"],"yoast_head":"<!-- This site is optimized with the Yoast SEO plugin v27.9 - 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