Compliance

We create sustainable value

We are convinced that sustainable success is only possible if we act responsibly, ethically, and in compliance with applicable laws. At Mutares, compliance and integrity are of paramount importance. They are an integral part of our daily business and shape our corporate culture.

Mutares is committed to acting with integrity and in compliance with the law, in accordance with nationally and internationally recognized standards. We assume corporate responsibility and consider the impact of our business activities. To this end, we have established a compliance management system that includes a code of conduct covering all relevant areas.

We expect all employees at all levels to behave responsibly, ethically, and with integrity. This means that they perform their duties in accordance with applicable laws, regulations, voluntary commitments, and our corporate principles. Integrity forms the basis for our decisions and serves as a guide, especially in complex situations. For us, this means not only complying with internal and external rules, but also acting in accordance with our values.

These expectations also apply to third parties, such as business partners and suppliers, who contribute to our company’s reputation. Our requirements for third parties are set out in our Code of Conduct for Suppliers and Business Partners.

Our Code of Conduct

Sustainable success is only possible if we act responsibly and make informed decisions. Our Code of Conduct clearly defines what integrity means at Mutares, which rules apply to everyone, and which principles guide our actions.

Our Code of Conduct for Business Partners and Suppliers

We believe in partnerships that create added value. Integrity, compliance with laws, and sustainable business practices are essential to us. Those who work with us share this commitment as the basis for responsible action and long-term mutual success.

We are convinced that sustainable success is only possible if we act responsibly, ethically, and in compliance with applicable laws.

Our Compliance Management System

Values-based compliance is a central component of our daily business.

Value-based compliance is a central component of our daily business.
This means acting consistently in accordance with applicable laws, regulations, and our corporate principles. Mutares’ compliance management system (CMS) defines clear standards and measures to promote integrity and compliant behavior in all areas of the company.

Our principles

We make decisions and act quickly. Our organization is lean and our processes are efficient. Our compliance department ensures that we act responsibly and in line with our values.

This includes an effective compliance management system (CMS) that sets clear standards and structures. Each portfolio company appoints a compliance officer who implements appropriate measures.
The respective management team, in cooperation with the compliance manager, is responsible for implementing appropriate
compliance measures at the portfolio company level.

We are turnaround investors.
Our CMS therefore pursues the following two objectives:

Minimize liability
…for Mutares SE & Co. KGaA, its national units, and key decision-makers.
Strengthen portfolio companies
… and ensure that they fulfill their responsibility to act in accordance with laws and regulations. We provide standards, tools, and processes and offer customized advice as needed.

Our values

Entrepreneurship
Integrated Management
Sustainability
Personal Integrity

Our Vision

“First in mind – first in choice” at Private Equity Turnaround

Our Goal

Maximizing value creation for our shareholders through sustainably profitable business.

Our Mission

Creating value by turning risks into opportunities and successes.

Our compliance program: Responsibility in three steps

Our compliance approach follows the cycle of “prevention – detection – response.” This ensures that risks are identified early, violations are investigated, and improvements are implemented.

Prevent

Risk Assessments
Codes of Conduct and Compliance Policies
Communication and "Tone from the Top"
Trainings and Advisory Support

Detect

Empowered employees and an open communication culture
Support from management and internal experts
Compliance Helpdesk
Compliance Audits performed by Internal Audit
Whisteblower System
Internal Controls

Respond

Monitoring and Reporting
Internal Investigations
Continuous Improvement

Focus areas

Ensuring compliance with capital market regulations
Prevention of bribery and corruption
Prevention of money laundering and terrorist financing
Privacy
Compliance with antitrust and competition law
Combating other forms of serious economic crime

Compliance throughout the entire portfolio lifecycle

Every compliance management system must be tailored to the respective company and its business model. Accordingly, the implementation of compliance measures in our portfolio companies is tailored to the respective phase of the portfolio life cycle.

Acquisition
We acquire companies or parts of companies with potential for sustainable development—provided that their business practices are lawful and ethical.
Realignment
At this stage, our portfolio companies are often under significant cost pressure. Nevertheless, compliance with regulations remains essential. Fundamental measures such as codes of conduct, relevant guidelines, and a whistleblower portal are implemented as early as possible.
Optimization
As the company develops, the CMS must also evolve accordingly. Management and designated compliance officers are responsible for ensuring this. The compliance department monitors developments and provides support as needed.
Harvesting
In this phase, the focus is on documenting the CMS. The aim is to be able to demonstrate the suitability and effectiveness of the system to potential buyers.

As a turnaround investor, we create the conditions necessary for our portfolio companies to operate with clear and effective compliance structures. In this way, we promote compliant and responsible behavior across all companies in our group.

Lennart Bauernfeind

Head of Compliance

Whistleblower Portal– Mutares Integrity Line

In order to identify potential violations at an early stage and respond appropriately, the Mutares Compliance Office has set up the Integrity Line. This provides a secure and confidential channel for reporting potential compliance violations and suspected human rights or environmental violations, including the option of making anonymous reports.

All reports are reviewed professionally and independently by the Compliance Office. We guarantee the highest level of confidentiality and protect whistleblowers from any form of retaliation. Each report is carefully reviewed to minimize risks to Mutares, our employees, and business partners and to prevent potential damage.

The Mutares Integrity Line is available not only to our employees, but also to external partners and third parties. We encourage anyone who has reasonable suspicion of misconduct to contact us without fear of reprisals.

The Mutares Integrity Line can be accessed online via the following link:

Visit Integrity Line

mutares-compliance-umwelt-menschenrechte

Environment and human rights

As an internationally active company, we take responsibility for respecting human rights and protecting the environment throughout our entire supply chain. We comply with the requirements of the German Due Diligence Act and have established clear standards for identifying, assessing, and mitigating risks.

Our policy statement sets out the principles that guide our actions and defines how human rights and environmental due diligence obligations are embedded in our processes.

Policy Statement in accordance with LkSG