Code of Conduct
Code of Conduct
Partners and Suppliers
January 2026
I. Purpose and Scope
The SKD SE (“Company”) aspires to be a modern and future-oriented organization that delivers ex-cellent performance and adheres to the core values of the society. The Company is responsible for creating and maintaining a corporate culture that ensures compliance with relevant legal regulations and ethical principles to the greatest extent possible.
The Company believes in the necessity of strengthening European resilience through technological superiority and mass-deployability, deterring future aggressions. This requires rapid innovation only achievable through a high-paced environment and the willingness to embrace challenges. The Com-pany wants everyone of its employees, partners and suppliers to adopt an attitude of solution-ori-ented thinking.
Given the multitude of laws and regulatory requirements, it is nearly impossible to provide a pre-defined solution for every conceivable situation. However, to ensure actions are in line with laws and ethical values as far as possible, the Company has formulated this Code of Conduct. This Code of Conduct sets out the ethical, legal, and professional standards expected by the Company from all third parties with whom it conducts business. It defines the general standards for behaviour in busi-ness, include, but are not limited to, authorities, customers and business partners, suppliers, sub-contractors, distributors, resellers, consultants, agents, consortium members, joint venture part-ners, and any other entity entering into a contractual or cooperative relationship with the Company (“Partners and Suppliers”).
This Code of Conduct applies to Partners and Suppliers. Partners and Suppliers are also responsible for ensuring that these principles are applied throughout their own supply chains and business rela-tionships, where relevant. This Code of Conduct and other applicable policies must be read carefully.
This Code of Conduct must be observed even if applicable laws or regulations are less far-reaching. Please note, however, that stricter laws and regulations or contractual obligations may apply than those outlined in this Code of Conduct. In such cases, these stricter laws and regulations or contrac-tual obligations take precedence.
The Company thanks in advance for the commitment to complying with this Code of Conduct. By doing so, everyone contributes to upholding the high standards in interactions with each other, thereby ensuring the foundation for a successful future for this Company.
By engaging in business with the Company, Partners and Suppliers confirm that they have read, un-derstood, and agree to comply with this Code of Conduct. Compliance with this Code is a material obligation of any contractual relationship with the Company.
__________________________________________________________
Place, Date Signature
______________________________
Name of the Supplier/Partner
II. Specific Topics
1. Insider Trading
Partners and Suppliers may, in the course of their work, become aware of non-public information that is relevant to the trading of securities. The use of such information may constitute insider trading.
Insider trading refers to the unlawful use or disclosure of insider information. Insider information includes specific details about non-public circumstances related to an issuer of insider securities (financial instruments such as stocks, bonds, warrants, and derivatives) or the securities them-selves, which are significant enough to influence an investor's decision to buy, sell, or hold securities.
In particular, the following examples may constitute insider information:
The regulations governing insider trading are complex. Even the suspicion of a violation of insider trading laws and regulations can damage reputations. Furthermore, insider trading is punishable by law.
Therefore, it is prohibited:
Ensure that insider information is shared internally only with individuals authorized to access it and who need it for their work.
In case of doubt, the person of contact or the legal department of the Company must be consulted to determine whether the information possessed qualifies as insider information and whether, due to stricter laws in other countries, trading securities is prohibited.
2. Fair Competition
The Company places great importance on compliance with applicable antitrust and competition laws, as non-compliance can have severe consequences. These may include fines or other monetary penalties for the Company, invalidation of agreements, potential claims for damages by third parties, and reputational damage or negative press in the event of publicized violations.
To prevent harm to the Company due to antitrust and competition violations, the following must be observed:
Agreements of any kind or coordinated behaviour (e.g., informal cooperation) with competitors or customers that aim to restrict competition or have anti-competitive effects are considered viola-tions of antitrust law. Even business discussions with competitors may be regarded or interpreted as antitrust violations.
If a business-related discussion with a competitor involves one or more of the following topics, it is necessary not to participate in the discussion or to leave the meeting, as such discussions may indi-cate or constitute anti-competitive cooperation:
Written documents must always be carefully worded. Ambiguous statements that could be misun-derstood or misinterpreted must be avoided.
The Company expects its Partners and Suppliers to conduct their activities responsibly, sustainably, and in accordance with internationally recognized standards relating to antitrust and competition laws. Prohibited practices include price-fixing, bid-rigging, market allocation, and the exchange of sensitive competitive information. Partners and Suppliers shall not engage in fraud, deception, mis-representation, or any form of unfair or misleading business conduct.
This Code represents a minimum standard. Where local laws or internal policies impose higher standards, the more stringent requirements shall apply.
3. Export Control
Export control refers to government regulations that restrict the sale or transfer of certain goods, technologies, and software to other countries or entities. These regulations are put in place to pro-tect national security, prevent the proliferation of weapons, and maintain foreign policy objectives.
Please be aware that international trade is subject to export control regulations, including prohibi-tions, restrictions, approvals, and monitoring requirements. This extends beyond physical goods to include technologies and software. These regulations apply not just to actual deliveries but also to temporary exports, such as taking objects and technical drawings on business trips, and technical transmissions via email or cloud services. Any transactions with individuals or entities on sanctions lists are strictly prohibited. Violations can severely impact the Company and lead to serious legal consequences for Partners and Suppliers. Partners and Suppliers must comply with all applicable import, export, customs, and trade control laws, including sanctions and embargo regulations im-posed by relevant authorities. Transactions involving prohibited destinations, entities, or individuals are strictly forbidden, this includes for example Russia and Belarus.
It is the Company's policy to comply with all import and export regulations for goods, services, and information (including technology transfers and document transmissions). When considering any import or export decisions, it is crucial to verify if they are subject to export control regulations. The relevant department and the legal department must immediately be consulted in such instances. They can help determine the applicable export restrictions, such as United Nations embargoes, and it is prohibited from entering into any contracts that involve exports to restricted countries until a complete review has been conducted.
4. Product Excellence and Safety
The Company is committed to delivering products that meet the highest standards of quality, safety, and compliance. Ensuring product conformity and safety is a fundamental responsibility that re-flects the dedication to protecting customers, maintaining trust, and upholding the integrity of the Company.
All products must comply with applicable laws, regulations, and industry standards in the regions where they are manufactured, distributed, and sold. This includes adherence to safety, environmen-tal, and quality standards, as well as any specific requirements for labelling, packaging, and testing.
The safety of the customers of the Company and all people coming in contact with the products of the Company is paramount and priority. Products must be designed, manufactured, and tested to ensure they are safe for their intended use. Any potential risks associated with the product must be clearly communicated through proper instructions, warnings, and labels.
Rigorous quality assurance processes must be implemented at every stage of the product lifecycle. This includes regular inspections, testing, and audits to ensure that products meet both internal and external standards. Any non-conformities must be addressed immediately with corrective actions.
We are committed to continuous improvement in product safety and quality. Partners and Suppliers are encouraged to identify and report potential risks or areas for enhancement. Lessons learned from product performance, customer feedback, and market trends should inform future product de-velopment and safety measures.
Any incident involving product safety must be reported promptly through the appropriate channels. A clear and effective response plan must be in place to address safety concerns, including product recalls, customer notifications, and collaboration with regulatory authorities when necessary.
By adhering to these principles, the Company ensures that products of the Company not only meet but exceed customer expectations, fostering trust and confidence in everything we deliver.
5. Supply Chain
The Company is committed to maintaining a responsible and ethical supply chain that aligns with the values and principles of the Company. The Company carefully select suppliers and service providers based on objective criteria, ensuring that they meet the high standards for quality, integrity, and compliance. This selection process reflects the dedication to fostering partnerships with organiza-tions that share the commitment to ethical business practices.
Partners and Suppliers are expected to implement responsible sourcing practices, including due dil-igence in their supply chains to avoid contributing to armed conflict, modern slavery, human rights abuses, or illegal activities.
This further includes respecting adhering to fair labour practices, ensuring environmental sustaina-bility, and conducting business in an ethical and lawful manner. Suppliers must also meet or exceed industry standards for quality and safety, demonstrate accountability through transparent opera-tions, and actively work to minimize their environmental impact.
By upholding these principles, the Company ensures that the supply chain reflects the values, sup-ports sustainable and ethical practices of the Company, and contributes to the long-term success of business and partners.
6. Data Protection
Data protection safeguards the right of individuals to informational self-determination, i.e., the right of every person to control the dissemination and use of their personal data, such as name, postal address, email address, phone number, financial circumstances, etc. Data protection is essential to prevent violations of fundamental personal rights.
The Company places a high priority on protecting personal data. Therefore, the Company does not process (i.e., collect, store, modify, transmit, block, delete, etc.) or use personal data unless full com-pliance with applicable laws has been ensured in advance. The handling of personal data must be transparent to the affected individual. Additionally, the affected person must have the right to be informed about how their personal data is handled and to request corrections. Similarly, they have the right to object to the processing of their personal data under legal conditions or to request its deletion or blocking.
In countries where data related to legal entities is protected to the same extent as data related to individuals, the processing of such data must also comply with applicable laws.
Personal data disclosed or accessed during the work for the Company may only be processed if there is a legal basis for doing so (e.g., necessity for fulfilling contractual obligations, employment rela-tionships, or with the consent of the individual). This also applies to the exchange of personal data between companies within the corporate group. Partners and Suppliers must comply with all appli-cable data protection and privacy laws, including GDPR. Further information can be found in the pri-vacy policy of the Company (https://stark-defence.com/en/privacy-policy/).
7. Protection of Third-Party Intellectual Property (e.g., Copyright, Trademark, Design, Patent Rights)
The unauthorized use of third-party intellectual property rights is prohibited and not tolerated by the Company. Copyright laws prohibit the reproduction, performance, distribution, licensing, or display of copyrighted works without prior permission from the copyright holder. Permission is also required to create derivative works. Trademark laws protect names, logos, and other Company identifiers.
It must be ensured that an agreement with the rights holder exists before using their intellectual property. In case of uncertainty, especially before using a name, logo, or other identifier in business transactions, the Point of Contact or the legal department of the Company must be consulted.
8. Compliance with Anti-Money Laundering Laws
The Company and its Partners and Suppliers are obligated to comply with applicable anti-money laundering laws. This includes identifying contractual partners, selecting permissible payment methods, and determining ways to uncover potential money laundering activities.
If money laundering is suspected, report it immediately to the Company (legal department). Pay par-ticular attention to transactions involving unusually large cash sums or structures designed to avoid reporting obligations or bypass proper accounting procedures.
9. Media Relations
As a globally operating Company, the reputation significantly depends on how the Company is per-ceived externally, particularly in dealings with the media. Therefore, it is essential to present a uni-fied image to the public and provide truthful information.
All media inquiries related to the Company must first be forwarded to the Company and the Director Communications. Any statements related to the or about the Company must be approved by the Company in writing.
10. Communication and Marketing
The Company values clear and open communication with all stakeholders, ensuring it is upright and legally compliant. All communication partners must be treated with respect for their achievements and reputation. To maintain trust, all communication and marketing activities must be coordinated with the Director Communications.
There must not be made public statements on behalf of the Company. Inquiries should be directly forwarded to the Company and the Director Communications.
Besides that, it is not allowed to display the affiliation to the Company on any social media service without the prior approval in writing.
III. Business Environment Conduct
1. Discrimination-Free and Harassment-Free Workplace
All Partners and Suppliers, have the right to fair, respectful, dignified, polite, and non-discriminatory treatment. Partners and Suppliers are expected to respect fundamental human rights and treat all individuals with dignity and fairness. The Company is committed to this principle and aim to ensure this right within the Company and in relations with Partners and Suppliers.
It is the Company’s responsibility to ensure a work environment free from sexual harassment or any other unlawful discrimination. Any form of sexual harassment or other prohibited discrimination based on gender, race, ethnic origin, religion or belief, disability, age, or sexual orientation is not tol-erated and must cease.
Sexual harassment is any unwanted, sexually determined behaviour, including unwanted sexual acts or requests, sexually determined physical contact, comments of a sexual nature, and the unwanted display or visible placement of pornographic material. Such behaviour violates the dignity of the af-fected person, especially when it creates an intimidating, hostile, degrading, humiliating, or offen-sive environment. Sexual harassment is unlawful.
The Company reserves the right to take disciplinary action against Partners and Suppliers who treat other business partners, freelancers, employees in an unlawful or inappropriate manner. Disciplinary measures may include regular or extraordinary termination of business or/and partner relationship.
2. Prohibition of Forced and Child Labor
Partners and Suppliers shall not engage in, support, or benefit from forced, bonded, or involuntary labour, including human trafficking. Child labour is strictly prohibited. No person below the minimum legal working age, as defined by applicable law or international labour standards, may be employed or contracted.
3. Protection of Intellectual Property
The Company possesses important rights and licenses to intellectual property, such as copyrights, related rights, and trademarks. When dealing with these intellectual property rights, appropriate steps to protect the Company’s interests should always be taken. Unauthorized use can lead to the loss of ownership rights or significant devaluation.
4. Confidential Information
In the course of the business relation a significant amount of information may be disclosed. Infor-mation marked as confidential or identifiable due to the nature of the information as such (“Confi-dential Information”) must be protected and kept secret. The form in which the Confidential Infor-mation is embodied, and the medium on which it is stored, shall be immaterial; this shall, in particu-lar, include information disclosed orally. It shall also be immaterial whether documents or other me-dia embodying the confidential information were created by one of the Parties or by a third party. The same confidentiality obligations apply to information shared with the Company by Partners and Suppliers under a confidentiality agreement.
All Partners and Suppliers shall:
5. Gifts and Benefits
The Company is committed to transparency in its dealings with customers, suppliers, and authori-ties. It adheres to international standards for combating corruption and complies with national and local anti-corruption and anti-bribery regulations. Partners and Suppliers must conduct business with honesty and integrity.
Business decisions and contracts must be based solely on justifiable, performance- and quality-re-lated criteria. This can only be achieved if every Partners and Suppliers takes responsibility for ad-hering to the following rules:
Offering, promising, giving, requesting, or accepting any gifts, bribe, improper payment or ad-vantage intended to influence a decision or secure an undue benefit of any kind to individuals or companies with whom the Company has or seeks to establish a business relationship, and which may influence or appear to influence their business decisions, is strictly prohibited. Similarly, accepting or soliciting gifts of any kind is also prohibited. Partners and Suppliers must comply with all applica-ble anti-corruption and anti-bribery laws, including those with extraterritorial effect, where applicable.
IV. Conflicts of Interest
Conflicts of interest can raise doubts about the quality of business decisions and the integrity of the individuals making those decisions. Conflicts of interest, or even the appearance of such conflicts, must always be avoided. If avoiding a conflict is not possible, it must be addressed actively, openly, and honestly. Partners and Suppliers must identify, avoid, and appropriately manage situations that could create actual or perceived conflicts of interest.
V. Implementation of the Code of Conduct
1. Questions and Guidance
This Code of Conduct cannot provide detailed guidance for every possible situation. Applying and implementing the standards outlined in this Code of Conduct may require clarification in certain cases.
If there is uncertainty about the appropriate course of action, the person of contact, the relevant department, or the legal department, should be consulted.
2. Part of the Partners and Suppliers Relationship
This Code of Conduct is an integral part of the Partners and Suppliers relationship and essential for the Company’s operations. Violations of the mandatory provisions of this Code of Conduct will not be tolerated. Failure to read or acknowledge this Code of Conduct does not exempt from the responsi-bility to comply with it.
Violations of this Code of Conduct may result in corrective measures, suspension, or termination of the business relationship with the Company without prejudice to any other contractual or legal rem-edies. If a violation of this Code of Conduct also constitutes a breach of applicable law, it may lead to claims for damages and/or criminal prosecution.
In light of the above, the Company urges to act responsibly and adhere to this Code of Conduct for the benefit and the everyone’s success.