Code of Conduct
Code of Conduct of The Quality Group GmbH and its affiliated companies
Code of Conduct
Date: 08.09.2025
1. Our Compass of Values
1.1 We, the TQG Group, are a young, growing company in a constantly changing society. We love the challenges this presents and strive to keep pace with new developments. However, we are also a company with a sense of responsibility toward society, our customers, our employees, and our business partners.
1.2 We are committed to fulfilling this responsibility by making our daily decisions in accordance with certain ethical, moral, and legal standards.
1.3 The Code of Conduct contains a commitment to these standards, which represent our Compass of Values. It serves as a guide and applies to each of us, regardless of our position in the TQG Group, and at the same time represents the standards we expect our business partners to meet. Managers and leaders at the TQG Group have a special responsibility in implementing the Code of Conduct. They are responsible for sensitizing their teams to our values, providing advice in cases of uncertainty, and actively exemplifying compliance with the Code of Conduct. Our employees receive regular training on the Code of Conduct and, depending on their area of work, on other guidelines. The aim is to ensure that everyone at the TQG Group is aware of their responsibilities and has a clear understanding of our standards.
2. Respect and Human Dignity
2.1 We respect human dignity and are committed to upholding internationally recognized human rights as set out in the United Nations (UN) Universal Declaration of Human Rights, the International Labor Organization (ILO) Core Labor Standards, and the OECD Guidelines for Multinational Enterprises.
2.2 We strictly reject any form of physical or psychological abuse, intimidation, discrimination, and harassment. This includes, in particular, bullying, verbal or physical assault, sexual harassment, threats, or unfair treatment of any kind.
2.3 We promote a working environment characterized by respect, openness, equality, and cultural diversity. We see different perspectives as an enrichment.
2.4 We do not tolerate drugs in the workplace and expect employees and third parties to act responsibly.
3. Prohibition of Child and Forced Labor
3.1 We do not tolerate child labor and observe the applicable legal minimum age for admission to employment. In any case, we do not employ people under the age at which compulsory education ends according to the law of the place of employment or under the age of 15.
3.2 We expect our business partners to take the necessary measures to prevent child labor.
3.3 We reject all forms of forced or compulsory labor, including any form of debt bondage, serfdom, slavery or slavery-like practices, human trafficking or other involuntary labor and services that are not compatible with internationally recognized labor and social standards.
3.4 Employment must be on a voluntary basis. The withholding of identity documents, unjustified financial penalties, or restrictions on movement are not permitted.
4. Fair Remuneration, Compliance with Working Hours, and Occupational Safety
4.1 We comply with legal provisions regarding remuneration for work performed. We guarantee that the wages we pay do not fall below the applicable statutory minimum wage. Wages and salaries are calculated transparently. There are no hidden deductions or unannounced wage cuts. We recognize the right to fair remuneration as a human right and also take into account the cost of living and social security when determining remuneration.
4.2 We comply with legal provisions on working hours, including overtime, rest breaks and annual leave, and adhere to internationally recognized labor standards.
4.3 The health and safety of our employees is our top priority. We are committed to acting responsibly and creating working conditions that are safe and healthy. To this end, we offer regular medical examinations and check-ups, among other things. Regular training and guidelines are designed to continuously ensure the high safety standards to which we are committed. We strictly comply with all applicable laws and regulations on occupational health and safety at all locations where we operate.
4.4 All employees receive personal protective equipment from us, where necessary, and are required to use it properly, where necessary and appropriate. Dangerous or unsafe working conditions must be eliminated immediately, where possible without endangering oneself.
4.5 In addition, all employees are obliged to immediately report unsafe situations or behavior that could endanger their own safety or the safety of others.
5. Diversity and Inclusion, Prohibition of Discrimination
5.1 We are as diverse as our society. We value this diversity as an asset and do not discriminate against anyone based on national or ethnic origin, social background, health status, disability, sexual orientation, age, gender, political opinion, religion, or worldview.
5.2 We create a working environment in which all people are treated with respect and have equal opportunities – regardless of personal characteristics or individual backgrounds.
6. Fair Competition
6.1 We stand for fair and transparent competition. Our business activities are based exclusively on legitimate goals and honest business practices. We work with reputable partners and treat them with respect and appreciation.
6.2 Our success is based on performance – not on illegal agreements or anti-competitive behavior. We do not engage in discussions with competitors on topics that could impair fair competition. We also expect our business partners to act independently and in compliance with the law in their dealings with their competitors – we do not influence this behavior. We have clear guidelines on topics relevant to competition law. Where appropriate and necessary, we conduct targeted training to ensure safe and compliant behavior in competition.
6.3 We deliberately refrain from advertising with brands or property rights of other companies. We build the reputation of our products and brands on our own.
7. Prohibition of Corruption and Bribery
7.1 We firmly reject any form of bribery and corruption – and avoid even the mere appearance of unfair influence. This includes, in particular, accepting or granting inappropriate invitations, gifts, or other benefits with the aim of influencing business decisions or gaining competitive advantages.
7.2 We do not offer unfair advantages to third parties and expect the same behavior in return. Our actions are based on transparency, fairness, and traceability. To this end, we have clear internal guidelines that define compliant behavior and serve as binding guidance for employees.
7.3 We act in accordance with all applicable import and export control regulations. We also comply with the legal requirements for the prevention of money laundering. Compliance with these regulations is an essential part of our corporate responsibility and our compliance culture.
8. Conflicts of Interest
8.1 We expect all employees to act in the best interests of the TQG Group and to clearly separate personal interests from business decisions. A conflict of interest exists when private or family relationships or personal advantages impair objectivity, loyalty, or freedom of decision-making in the work context, or give the appearance of doing so.
8.2 Gifts, invitations, and hospitality may only be accepted or granted if they are appropriate, customary, and not likely to influence decisions or give the appearance of influencing them. Cash or monetary benefits are generally not permitted.
8.3 All employees are obliged to disclose potential or actual conflicts of interest immediately, e.g. to their manager, the compliance department or via the whistleblower system. Violations of these regulations may result in disciplinary action.
8.4 We have defined binding internal guidelines for the responsible handling of conflicts of interest. These are mandatory for all employees and form the basis for compliant behavior in this area.
9. Data Protection and Confidentiality
9.1 The protection of product developments, trade secrets, and confidential information is a top priority for our company. We undertake to process personal data of employees, business partners, and customers in accordance with applicable data protection laws (such as the GDPR) and to ensure information security through appropriate technical and organizational measures.
9.2 In direct customer business in particular, the careful handling of sensitive customer information – especially payment and contact details – is of central importance. That is why we have an information security program in place with administrative, technical, and physical protective measures.
9.3 In the event of a data protection incident, we undertake to report it immediately and transparently to the relevant authorities. Employees and external partners are required to sign confidentiality agreements and to maintain confidentiality even after the end of the collaboration.
9.4 The disclosure of confidential information or the delayed reporting of security-related incidents (e.g., loss of devices containing company data) constitutes a clear violation of our company guidelines.
9.5 Our goal is not only to meet the minimum legal requirements, but also to strengthen the trust of our customers and partners in the long term through an active commitment to data security and confidentiality. We attach great importance to protecting our product developments and other trade and business secrets within our group of companies. To the same extent, we protect sensitive data and confidential information entrusted to us or made available to us by business partners from unauthorized access, use, and disclosure.
9.6 We respect the personal rights of our employees, business partners, and customers and comply with the applicable legal and regulatory requirements for the processing of personal data and information security when handling personal information. In accordance with our Compass of Values, our community is one of the pillars of our company. The protection of our community and data is an essential pillar of our self-image.
9.7 We have binding guidelines for handling confidential information, which are communicated regularly and made available to all employees. Through internal guidelines and training – both general and department-specific – and regular reviews of our standards, we ensure a consistently high level of data protection throughout the company.
10. Product Quality, Product Safety, and Consumer Safety
10.1 The quality and safety of our products are part of the TQG Group's identity and have the highest priority. They shape every step from the purchase of raw materials to the finished product. We develop and manufacture according to the highest standards, which exceed legal requirements, in order to gain the trust of our customers and ensure consistently high product quality.
10.2 Our own production facility is FSSC 22000 certified and operates with a fully implemented HACCP system. Physical product safety is ensured by a multi-stage control system that includes metal and X-ray detectors, magnetic separation, and fine screening.
10.3 Before a raw material is accepted into our supply chain, it undergoes a structured testing process that includes a comprehensive risk assessment. Only trustworthy and qualified partners are approved. Incoming raw materials are tested for purity and identity upon delivery. In addition, risk-based checks are regularly carried out by independent, externally accredited laboratories.
10.4 After production, each product batch is tested in our own laboratory for sensory appeal and recipe conformity. In addition, further regular external laboratory tests are carried out by independent, accredited institutes – for example, to check nutrient profiles, analyze possible contaminants, and confirm the accuracy of declarations.
10.5 Some products are also HALAL or organic certified and listed on the Cologne List®.
10.6 We guarantee complete traceability throughout our entire supply and production chain and are ready to recall products at any time. Our team is trained and supported by external experts.
10.7 Customer feedback is systematically evaluated and complaints are handled as part of a CAPA (Corrective and Preventive Action) process. Improvement projects are led by Six Sigma-certified teams, supported by external quality experts.
11. Research, Innovation, and Development
11.1 Our Research & Innovation team combines interdisciplinary experience and expertise in medicine, nutritional science, food chemistry, and food technology. When developing new products, whether they are “better-for-you” products or health and performance supplements, our experts analyze scientific studies to develop the best possible formulations – now supported by AI for even greater precision and leverage.
11.2 Each ingredient and each dosage (including additives) is carefully checked against the current state of research and chemical and technological properties. As soon as new findings become available, existing recipes are updated. Each formulation is reviewed at least once a year.
11.3 Our product developers create our products based on the formulations developed by the Research & Innovation Team. In our own development laboratory, the sensory properties and quality of the product are perfected. For example, every texture and flavor profile is developed specifically for our products – we do not use standard, off-the-shelf flavors.
11.4 Our athletes and creators are closely involved in every product and flavor development – as the direct voice of our community. Development only ends when the majority of those involved are satisfied. In practice, this means no shortcuts.
11.5 We actively collect feedback from the community. If there is a need for optimization, it is implemented immediately.
12. Sustainability
12.1 Sustainability is part of our corporate responsibility. We are working to consistently embed environmental, social, and ethical standards in our company. We collaborate with an internationally recognized platform for assessing sustainability performance and align ourselves with its standards to ensure transparency, comparability, and continuous improvement.
12.2 We have a dedicated contact person for the coordination and implementation of our sustainability initiatives. In addition, our leadership team is actively involved in strategically anchoring sustainable action and incorporating it into all areas of the company.
12.3 Our goal is to gradually make sustainability an integral part of our business processes, decision-making, and corporate culture.
13. Requirements for our Producers, Suppliers, Cooperation Partners, and other Business Partners
13.1 Our Code of Conduct is not only our Compass of Values – it also describes our expectations of producers, suppliers, cooperation partners, and all other business partners in our supply chains.
13.2 The TQG Group is committed to making a positive contribution to society and the environment – through ethical conduct and maximum transparency. In addition to the separate Code of Conduct for Suppliers and Business Partners, the Code of Conduct sets out minimum standards for our suppliers and service providers in order to reduce risks in the supply chain and improve traceability. Together with our partners, we want to identify, avoid, and reduce negative impacts on people and the environment at an early stage – in accordance with international standards and applicable national law, in particular for the protection of human rights and the environment.
13.3 We apply various due diligence methods – including physical audits or equivalent procedures where necessary – both before entering into a business relationship and during the term of the contract, particularly in the event of renewals or significant changes.
13.4 We also work with Scrioo, a specialized digital compliance platform, to better assess supplier risks and strengthen transparency in our purchasing and risk processes.
14. Reporting Violations
14.1 Anyone who suspects that a violation of the above-mentioned regulations is occurring or has occurred in a TQG Group company has the option of contacting various internal departments or an external body. These include the supervisor, the HR business partner, any member of the executive team, the Chief Compliance Officer, or our external ombudsman.
14.2 Reports will be investigated objectively and anonymously if requested. Appropriate measures will be taken to clarify the incident, remedy the violation, and/or prevent further incidents.
14.3 All employees are obliged to report any form of harassment or inappropriate treatment and any violation of the Code of Conduct without delay. We ensure that reports are taken seriously, treated confidentially, and followed up without fear of reprisals.
14.4 Our ombudsperson can be reached in the following ways and will process reports completely anonymously if requested:
Attorney at law Dr. Kathrin J. Niewiarra, Ombudswoman
Philippistrasse 11
D-14059 Berlin
Tel.: +49 (0) 30 / 4036750-17
TQGG@compliance-aid.com
compliance-aid-tqgg.hintbox.de – Hintbox
14.5 The Chief Compliance Officer can be contacted at compliance@tqgg.de
15. Documentation and Review Cycle
15.1 This policy must be reviewed annually for updates and as required. The contact person named on page 1 is responsible for this.
