
Fronius International GmbH Group Directives
Specified in Controlled Docment for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)

CODE OF CONDUCT
Our values – Community, Innovation, Creativity, Sustainability, Quality Awareness and Cost
Effectiveness – are the guiding principles at the heart of everything we do. Through this code of
conduct, we are committing ourselves to acting responsibly and in an appropriate manner. In
this way, our employees will be better equipped to make business decisions and take action as
autonomous individuals.
Our employees are crucial to the success of our company because they are the bedrock of our
reputation and of the trust that our customers place in us. It is precisely for this reason that
clear ethical and moral principles need to be built into our business approach.
This code of conduct applies to all Fronius employees (white- and blue-collar employees,
apprentices, interns and leased staff) regardless of their position within the company. We also
expect our business partners to behave with integrity and in accordance with the law in line with
this code, throughout the entire supply chain.
Each and every employee is individually responsible for complying with and implementing the
code of conduct. Managers are required to set a good example for employees by putting the
code of conduct into practice themselves. They must also instruct their employees so that they
know how to respond to the code of conduct, must check that their employees are actually
following it and – with assistance from the compliance department– provide them with training.
When interpreting the rules of the code of conduct, employees must also rely on their own
judgement and must ask themselves whether a particular course of action is ethically or morally
questionable or could potentially provoke criticism. However, in those cases where legal
regulations apply, there is absolutely no room for personal discretion.
If employees have any questions or doubts about the code of conduct, they are welcome to seek
clarification from their line managers and the compliance department at any time. The
compliance department is also the ultimate authority for settling controversies or questions of
interpretation, and its interpretation shall be binding.
The compliance department can be contacted via the following e-mail address:
compliance@fronius.com
Gender-specific formulations refer equally to the female and male form.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)

1. LEGISLATION/OTHER REGULATIONS
Die Einhaltung der geltenden Gesetze sowie der internen und externen Vorschriften ist die
Grundlage aller unserer unternehmerischen Aktivitäten und Entscheidungen.
2. FREE/FAIR COMPETITION
Professional, fair and transparent conduct in the marketplace is conducive to safeguarding our
interests in the long term and helps Fronius to securely maintain its competitiveness in a
sustainable way.
− When participating in the market, we steer clear of underhand marketing arrangements,
market abuse or concentrations of power. We avoid any restriction of free competition
and any breach of competition and antitrust laws. We respond to the challenges on the
market by ensuring that our employees are qualified and motivated, that our processes
are efficient and that our products are of high quality.
− In our dealings with our competitors, the following are strictly prohibited: arrangements
of any kind relating to prices or production quantities; discrimination against other
market participants; splitting or dividing up the market by apportioning customers,
suppliers, territories or business areas; exerting unreasonable pressure on business
partners; sham offers and similar agreements with other competitors; collusive
tendering; and any exchange of confidential information belonging to other market
participants, including, in particular, price calculations, production capacities, production
costs, terms and conditions of sale.
− We do not exchange information on sales offers with other market participants,
competitors, or customers. Sales offers from our competitors are neither examined nor
accepted for information. Likewise, our own sales offers are not disclosed and requests
from other market participants or competitors for further offers to customers are firmly
rejected.
− In our conduct towards our customers and dealers, specifications of fixed or minimum
prices for the resale of our products are prohibited. Any statement on sales prices must
be declared as a non-binding price recommendation and must be lived as such.
− By passive sales we mean, when we do not solicit the sale but a request for quote is
issued to us without our active involvement or sales measures. Passive sales are always
allowed! Internet sales are also fundamentally understood as passive sales. Far be it
from us to restrict or prohibit passive sales and internet sales of our competitors as well
as dealers and customers in any way or to exert pressure or threaten consequences
because of such sales activities.
Specified in Controlled Document for this pdf: CS-000007_Code of conduct, Version 4 (10/2022)