Code of Conduct for Subcontractors and Suppliers

1. Anti-Corruption / Anti-Bribery

Subcontractors and Suppliers shall not, directly or indirectly, engage in any act of corruption, extortion or embezzlement, nor in any form of bribery. This includes but is not limited to the promising, offering, giving or accepting of any improper monetary or other incentive such as bribes, unreasonable business entertaining and gifts as well as kickbacks.

2. Counteracting Corruption

Subcontractors and Suppliers shall actively and systematically prevent any form of criminal, corrupt, or otherwise unethical conduct that could influence decisions by Mimacom or any external organization. They are required to maintain, document, and enforce adequate internal controls and compliance measures to prevent corruptibility within their own operations and supply chains.

3. Bid Rigging

Subcontractors and Suppliers do not participate in anti-competitive bid rigging and take action against illegal cartels.

4. Counteracting Illegal Employment

Subcontractors and Suppliers comply with the applicable legal requirements and effectively eliminate illegal employment.

5. Respect for the Fundamental Rights of Employees

Subcontractors and Suppliers respect the health, safety and personal rights of their employees and adhere to the principles of respect, fairness and non-discrimination. They employ and remunerate their employees on the basis of fair and compliant contracts. They maintain international minimum labour standards.

6. Respect for the Environment

Subcontractors and Suppliers shall observe all relevant legal environmental standards and commit to minimising their negative environmental impact.

7. Governance

Subcontractors and Suppliers forbid gifts to private or public officials that aim to influence business decisions or otherwise encourage them to act contrary to their obligations. Subcontractors and Suppliers respect the privacy and confidential information of all their employees and business partners as well as protect data and intellectual property from. Subcontractors and Suppliers implement an appropriate Compliance Management System, which facilitates compliance with applicable laws, regulations, and standards.

a)

Mimacom requests from its Subcontractors and Suppliers that they require their own subcontractors and suppliers also to comply with the principles of this Code of Conduct.

b)

Subcontractors and Suppliers are required to report their own violations of this Code of Conduct, insofar as these affect their business relations with Mimacom. They are also asked to report any knowledge of misconduct on the part of Mimacom employees.

c)

Subcontractors and Suppliers are required to actively resolve any suspicious cases and to cooperate unconditionally with Mimacom in this regard. If there are reasonable grounds to believe that a Subcontractor or Supplier has violated this Code of Conduct or if a Subcontractor or Supplier, when a suspicious case arises, fails to sufficiently meet his obligations to resolve the case and to cooperate, Mimacom, on the basis of existing contractual or legal rights, can end all business relations with the Subcontractor or Supplier with immediate effect. In the event of a violation of this Code of Conduct, Mimacom retains the right to initiate further legal measures, particularly damage claims.

d)

Mimacom, from time to time, can appropriately update this Code of Conduct and expects that its Subcontractors and Suppliers accept any such changes.

Scope

The Code applies to the Suppliers and Subcontractors of all Mimacom legal entities, notably:

Switzerland and EU countries

• Mimacom AG
• Mimacom Deutschland GmbH
• Mimacom Iberica s.l.u.

Non-EU countries

• Mimacom USA Inc.