Mutual trust, predictability, honesty and straightforwardness both internally and externally are basic principles that are firmly anchored in the Würth Group – and thus also at Internationales Bankhaus Bodensee AG. The commitment to these values can already be found in the company philosophy written by Reinhold Würth in the 1970s.

This involves not only compliance with all applicable rules and laws, but also a corresponding inner attitude on the part of employees, which is an essential building block for sustainable corporate success. And it is precisely this inner attitude that we want to promote. At the same time, we also demand strict compliance with all applicable national and international rules and laws. In order to make this transparent for our employees as well as for our customers and business partners, we have derived specific rules of conduct on the basis of our corporate values, which are summarized once again in the Code of Compliance of the Würth Group.

With our Code of Compliance, we are committed to behaving with integrity in our dealings with each other and with our customers and business partners. Research shows that third-party tips often lead to the detection of white-collar crime. For this reason, we have set up a system with which both employees of Internationales Bankhaus Bodensee AG and third parties can provide information about criminal acts and other compliance violations. This is the Internet-based BKMS system (Business Keeper Monitoring System).

You can use the BKMS system, among other things, if you wish to report violations of the following regulations and legal bases, among others, while maintaining the confidentiality of your identity:

• Regulation (EU) No 575/2013,
• Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (Market Abuse Regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC (OJ L 173, 12.6.2014, p. 1), as last amended by Regulation (EU) 2016/1033 (OJ L 175, 30.6.2016, p. 1; L 287, 21.10.2014, p. 1). L 173, 12.6.2014, p. 1), which was last amended by Regulation (EU) 2016/1033 (OJ L 175, 30.6.2016, p. 1; L 287, 21.10.2016, p. 320; L 306, 15.11.2016, p. 43; L 348, 21.12.2016, p. 83),
• Regulation (EU) No 600/2014
• Regulation (EU) No 1286/2014,
• Regulation (EU) 2017/1129 of the European Parliament and of the Council of 14 June 2017 on the prospectus to be published when securities are offered to the public or admitted to trading on a regulated market and repealing Directive 2003/71/EC (OJ L 168, 30.6.2017, p. 12)
• German Banking Act (KWG) or ordinances issued on the basis of the German Banking Act
• Securities Trading Act (WpHG) or ordinances issued on the basis of the Securities Trading Act
• any criminal offences

In addition, the BKMS system can be used to report violations that fall within the scope of the Whistleblower Protection Act (Section 2 HinSchG). Information submitted in accordance with the Whistleblower Protection Act can alternatively be addressed to an external reporting centre. The whistleblower office of the Federal Financial Supervisory Authority and the whistleblower office of the Federal Office of Justice are available for this purpose. In these cases, whistleblowers are generally free to decide whether to record information in the BKMS system or to send it to an external reporting centre. However, it is advisable to give preference to the BKMS system so that IBB AG can initiate analyses of the facts that are the subject of the notification immediately and in a targeted manner. Maintaining confidentiality is a top priority throughout the entire whistleblowing process.

For reports in the BKMS system on the above legal sources, when indicating a category, please indicate Violation of Policy / PAP (Policy And Procedure) or Compliance issues if other of the indicated categories do not apply.

If you would like to give us a hint via the BKMS system, you can do so by name or anonymously. However, because we seek open communication, we encourage you to use your name when providing tips. In any case, we will treat your information as strictly confidential and take into account the legitimate interests of all parties involved. Please create a mailbox in the BKMS system where we can contact you. This is important in case of queries or if you want to add further information to your report later. Communication via the mailbox can – if desired – also be anonymous.

Here you can submit your tip:

www.bkms-system.net/wuerth

Thank you for your support!