Legal
Code of Conduct
Last updated: May 2025
1. Preamble
Amaranth believes in "Navigate through complexity" and we all stand behind this basic conviction, as well as other important values that guide us through all situations in our working lives. Whether a certain behavior is right or wrong is something we can usually answer with common sense and a sense of what is right and what is wrong. Nevertheless, especially with regard to our growth, it is necessary to codify our common principles and to remind ourselves of them again and again. The minimum that is required by law is just as important as internal regulations on issues of human coexistence and work, some of which set further or higher standards.
Acting in accordance with these shared values is the basis for our clients' trust and has a significant influence on Amaranth's reputation. It determines the quality of our work and creates an environment in which we are happy to provide our services and meet the highest standards. We do not need rigid rules for this - rather, this code is intended to remind us of the values that apply in the context of our work. It is intended to help us make daily decisions about what is right and what is wrong and to support us in acting correctly.
2. Area of application
Responsibility for compliance with and implementation of this policy lies with all employees (together AAmembers) of the Amaranth Group, i.e. Amaranth Advisory GmbH (Berlin, Germany) and Amaranth Advisory GmbH (Zurich, Switzerland).
3. Guidelines for behavior towards AAmembers
The culture at Amaranth should be characterized by mutual appreciation and respectful interaction. Every AAmember contributes to a positive working atmosphere with their behavior. This includes ensuring that colleagues are seen and treated with respect regardless of their gender, sexual orientation, age, skin color, political or religious beliefs, social or ethnic background, disability or nationality. This also means that we do not tolerate negating behavior, but instead advocate equal treatment. We work as a team, support each other, rely on our diverse strengths and achieve our goals together. There is no room for arrogance, condescending behavior or going it alone. We can only realize our strengths and meet our customers' and our own expectations if we make use of the cohesion and synergy effects.
4. Guidelines for behavior towards Amaranth
Amaranth has a extensive responsibility towards all AAmembers. As AAmembers, we also acknowledge our responsibility to Amaranth. We are committed to performance and act with the highest standards of quality in every context. We also avoid behavior that could harm Amaranth at all costs. We accompany the constant change to which Amaranth is subject, recognize the need for change and contribute to actively shaping the new and accepting it as a necessary prerequisite for the continued success of Amaranth and thus of all AAmembers.
Compliance with legal requirements
Our professional activities are subject to a legal framework, which we strictly observe. Where necessary, we seek legal advice. As laws change, we monitor these changes and adapt our processes accordingly.
Data protection and information security
We are aware of our responsibility for the protection of personal and business data that we process as a company operating in the IT sector and implement the necessary security measures appropriately. We handle the data of our clients, business partners and AAmembers carefully, confidential and secure and in accordance with legal requirements.
Dealing with organizational property
All AAmembers are constantly working to create an inspiring working atmosphere, which we greatly appreciate. The work tools and IT equipment are also kept up to date. In return, responsible handling of Amaranth's property is requested, both in the form of IT equipment and furnishings. The "Clean Desk Policy" must also be observed in particular. No less important is intangible property - know-how and industrial property rights. Confidential company information is essential for business success and must be kept secret and protected against access by third parties. Trade and business secrets must be protected and may not be used unfairly for private purposes.
Innovation and development
We are constantly improving our processes in order to provide our clients, business partners and AAmembers with services that are tailored to their needs in terms of quality and quantity. To this end, we share our knowledge, anticipate changes and use them as a necessary condition and opportunity for innovation and for continuously developing and strengthening Amaranth as an institution and as a community of AAmembers.
Conflicts of interest
Conflicts of interest can arise when private interests conflict with those of Amaranth, e.g. due to secondary employment or private equity investments. Conflicts of interest may arise if there are personal, family, financial or other connections to business partners or competitors of Amaranth that could influence rational decisions or actions, even in the context of working for Amaranth. As a preventive measure, it is important to avoid these and only enter into secondary activities and equity investments if this does not adversely affect Amaranth's interests. This also applies to charitable and voluntary activities. Sideline activities at and not insignificant shareholdings in companies of business partners and competitors must be coordinated with Amaranth and require Amaranth's approval. If a (potential) conflict of interest becomes apparent, transparency must be created and addressed with Amaranth's management.
Environmental protection, occupational safety and sustainability
Our behavior at work influences our working environment and our environment. Every action has an impact on both. Therefore, all AAmembers are required to be mindful in their working environment and considerate of nature and to align their own actions with the principles of environmental protection and sustainability. In addition, care must be taken to create a safe working environment both when working on site and when working on the move.
5. Guidelines for dealing with business partners and competitors
"Client first" is a value we live by: our daily work is subject to this motto and is consistently geared towards the expectations of our clients. Respectful interaction is a matter of course and we share responsibility for successful relationships with satisfied business partners. Condescending, arrogant and unprofessional behavior has no place here, nor in our dealings with other employees. We always strive to exceed expectations in terms of the quality of our work and our reliability. The trust of our clients is a valuable asset that must be reaffirmed every day through work that meets the highest standards.
Confidentiality
In the course of contract negotiations, projects and general dealings with our business partners, we are often provided with confidential information for the provision of our services. Protecting this information and handling it with appropriate care is just as important as protecting such information from Amaranth itself. Most information exchanged with business partners is subject to confidentiality agreements that must be adhered to.
Competition law
We operate in a highly competitive and challenging market. It is an exciting challenge to try to win this competition for Amaranth. Under no circumstances, however, should we attempt to avoid this competition by unfair means. Under no circumstances should agreements be made with competitors that violate competition and antitrust law. The exchange of secret information, such as pricing, is particularly sensitive. To be on the safe side, it is important to seek legal advice before meeting with competitors and to always be aware of the sensitivity of the information in question.
Bribery and corruption
Any form of bribery or corruptibility must be strictly rejected. Bribery is committed by anyone who offers, promises or grants someone an unfair advantage and expects an act in breach of duty in return. Corruptibility occurs when someone demands, is promised or accepts such an advantage. An advantage can be material (e.g. money, gifts) or immaterial (e.g. promotion). Facilitation payments, a medium of bribery with the purpose of enforcing or facilitating a justified claim to an official act more quickly, are also not an acceptable means and are punishable under criminal law. Further information is summarized in the Anti-Corruption Guideline.
Third parties
Of course, what we are not allowed to do ourselves, we are also not allowed to do by commissioning third parties. This means that no company may be commissioned to provide unlawful services or for unfair purposes.
Donations and sponsoring
Donations are generally made for legitimate purposes. They are voluntary donations for a scientific, charitable, religious, cultural, economic or political purpose. In the case of sponsorship, there is also a quid pro quo that supports the company's own communication and marketing objectives, for example. Benefits that constitute a donation or sponsorship must be granted with particular care despite the wellintentioned purpose, especially when donations are made to political parties and associations. In all cases, permission must be obtained from the management.
6. Indicating and reporting violations
In the event of violations of legal regulations, contractual obligations or internal guidelines, the person responsible for the project and/or the management must always be contacted. They will treat the information confidentially and ensure that the reporting person does not suffer any disadvantages as a result of the report. A solution can then be found for each situation. Although this document should be understood as a guideline for action, actions that violate the values listed here can lead to serious internal sanctions if they also violate laws or binding internal policies. In order to avoid these violations, all AAmembers should consult the contact persons in the project as well as the Managing Partners or the management in case of doubt.
