EXTENDED POLICY

This policy defines the principles for responsible and law-abiding management. It is binding for all managing directors, executive officers, and decision-makers within the SCANDIC Group.

We operate under a "best practice" approach, complying with the strictest standards across Hong Kong company law, EU GDPR, and the German Supply Chain Due Diligence Act (LkSG).

Management is responsible for proper business organization, effective risk management, and maintaining an internal control system (ICS) according to §§ 238, 242 HGB standards.

Management ensures that all tax obligations (KStG, EStG, UStG) are fulfilled. This includes timely filings, capital gains tax management (§ 43 EStG), and arm’s length transfer pricing (§ 1 AStG).

A risk-based CMS has been established to identify and mitigate risks related to corruption, money laundering, human rights violations, and environmental impacts.

Directors must meet "Fit & Proper" standards, possessing deep industry knowledge and an impeccable reputation, devoid of relevant criminal convictions.

Our code of conduct prohibits all forms of corruption and mandates the protection of confidential information and respect for human rights across all operations.

Shareholders evaluate management semi-annually based on financial targets, compliance metrics, and progress in sustainability and human rights due diligence.

We maintain ordered books and prepare annual financial statements according to applicable regulations, which are then audited by independent parties.

SCANDIC maintains a risk-based AML/CTF system and ensures no business is conducted with sanctioned individuals or organizations according to EU, UN, and OFAC lists.