CECONOMY : Code of Conduct 2021

CODE OF CONDUCT

TABLE OF

CONTENTS

1	Compliance - Better safe than sorry	03
2	Integrity in our business conduct	05
2.1	Human rights, labor and social standards	06
2.2	Health and safety at work	07
2.3	Climate and environmental protection	08
2.4	Compliance with laws and regulations	09
2.5	Conflicts of interest	10
2.6	Gifts and benefits	11
2.7	Competition and antitrust law	12
3	Integrity in dealing with each other	13
3.1	Anti-discrimination and employee diversity	14
4	Integrity in dealing with our information	15
4.1	Company data and personal data	16
4.2	Insider information	17
5	Reporting of violations	18

CECONOMY / CODE OF CONDUCT

TABLE OF CONTENTS

02

1	COMPLIANCE -
	BETTER
	SAFE THAN
	SORRY
CECONOMY / CODE OF CONDUCT	TABLE OF CONTENTS 03

Dear colleagues,

Our successful cooperation in the CECONOMY Group is primarily based on mutual trust. We all contribute to a trustful relationship on a daily basis - by behaving with integrity, i.e. in compliance with the law and ethically correct, by acting responsibly and by creating transparency. After all, the trust of our customers, business partners and the public are the basis for our joint economic success. In doing so, we follow the guiding principle of an honorable businessman.

CECONOMY is more than a retail company. We are the European leader for consumer electronics concepts and brands. The digitalization of the world is increasing every day - and we offer the products, services and solutions that simplify the everyday lives of our customers. We pursue a clear ambition: to be the first choice for customized solutions in a technology-driven world.

Together we pursue the goals of the CECONOMY Group. The joint success of the company takes precedence over individual interests. Thereby, we always respect our customers, business partners and competitors and treat them fairly.

Our Code of Conduct, which is binding for all employees and managers, formulates clear rules of play and thus gives us orientation in all situations of our everyday professional life. We are not only committed to the Code of Conduct, but live its values and principles - each in his or her own responsibility. The Code of Conduct is substantiated by the CECONOMY Group guidelines. The guidelines also take into account social, cultural and legal framework conditions of the countries in which the CECONOMY Group is represented.

We do not tolerate violations of the Code of Conduct, guidelines or laws under any circumstances. Any abuse of one's position for one's own benefit, for the benefit of a third party or to the detriment of the CECONOMY Group will be prosecuted and sanctioned. This principle applies to all of us. Therefore, it is our own responsibility to familiarize ourselves with the relevant guidelines and laws and to comply with them, also in order to prevent damage to our company as well as to ourselves.

Our motto is therefore: "Compliance - Better safe than sorry."

Our guidelines can be found on the intranet.

If you have any questions in this context, our supervisors or our Compliance Officers are available at [e-mail] any time.

In addition, the following is available as a central contact person: Dr. Kai Schumacher

Chief Compliance Officer Mobile: [phone]

E-mail:[e-mail]

For reports, you can use our group-wide Whistleblowing System - also anonymously - at https://www.bkms-system.net/mediasaturngroup/speakup.

We are convinced that this Code of Conduct forms the basis for collegial and cooperative collaboration in the CECONOMY Group and sets corresponding standards for fair cooperation.

Dr. Karsten Wildberger	Florian Wieser
CEO	CFO
CECONOMY AG	CECONOMY AG

CECONOMY / CODE OF CONDUCT

TABLE OF CONTENTS

04

2	INTEGRITY
	IN OUR
	BUSINESS
	CONDUCT
CECONOMY / CODE OF CONDUCT	TABLE OF CONTENTS 05