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COMPLIANCE

Compliance at SDS

Fairness, integrity and appreciation.

Fair interaction and compliance

When SDS does business, fairness, integrity and appreciation is always kept in mind. However, this not only applies to compliance, meaning adhering to regulations and laws, but also to the fair interaction with business partners, colleagues or authorities. Private interests and personal benefits must not influence our corporate decision-making.

To meet this demand, SDS has introduced clear directives which apply to everyone – from management to employees. Group-wide (Deutsche Telekom Group) compliance structures ensure that laws, regulations and codes of conduct are abided by in the interest of a responsible corporate management.

TELL ME! SUBMISSION OF HINTS AND COMPLAINT MANAGEMENT

Compliance rules only make sense if violations become known so that they can be properly addressed and prevented in the future. For this purpose, the reporting system “Tell me!” exists. Anyone who becomes aware of a compliance violation at SDS or wishes to report misconduct by an employee or business partner in connection with the business relationship with SDS can do so by sending a report to sds-compliance@sds.at, providing their name, or anonymously via the Deutsche Telekom Group’s whistleblower portal. Misconduct, rule violations, or justified suspicions of breaches of legal regulations, guidelines, and internal policies can be reported there.

In compliance with the HSchG (Whistleblower Protection Act), whistleblowers (and individuals close to them) are under special protection, in particular their identity and other information related to them. The whistleblower will be informed within 7 days of submission of the hint and will be notified of any follow-up measures within 3 months (if the whistleblower’s contact details are known).

It is guaranteed that reports made to the best of one’s knowledge and belief will not result in any disadvantages. The hints will be checked with the utmost discretion by employees of the “internal unit” (compliance department) who are specifically trained for the job and sworn to secrecy and – if necessary – further investigation will be carried out.

The whistleblower might also submit information about violations of the law to the competent authorities and external bodies in accordance with the HSchG, such as the Federal Office for Preventing and Combating Corruption. Since hints can mostly be clarified more quickly and more effectively by the internal unit of the company (compliance department), the whistleblower should always consider whether it would not be better to report the information to the internal unit of the company/the compliance department first. If careful handling of the information in the internal whistleblowing system is not possible, not appropriate or not reasonable, or has proven unsuccessful or futile, the whistleblower will be asked to hand over the information to an external body (Federal Office for Preventing and Combating Corruption).

Where and how can information be submitted?

Information can be submitted via email to sds-compliance@sds.at or directly/in person to our Compliance Manager, Ms. Janely Stelzer, via email, telephone or via mail.

Anonymous reports can be submitted via the Deutsche Telekom Group’s whistleblower portal.

ASK ME! ELIMINATING AMBIGUITIES AND UNCERTAINTIES

For all questions regarding compliance (e.g. Are you allowed to invite an SDS employee to an event? What is permitted according to the internal regulations?), please do not hesitate to get in touch via email at sds-compliance@sds.at!

Senior Management SDS Management and Division Heads.

By providing a state-of-the-future software and service portfolio, we are continuously setting digital standards in securities transaction, reporting, compliance and testing solutions for the international financial industry.