1. Compliance with Laws

KST commits to uphold laws.

All members of staff must respect and comply with the laws in force and the official regulations. The same applies to internal instructions and guidelines of KST.

2. Dealing with Gifts and Benefits

We do not engage in illegal business practices such as corruption, bribery or the taking of bribes.

Members of staff shall not request or allow themselves to be promised or accept services, gifts or any other advantages by customers, suppliers or other third parties which affect or might affect their activities for KST.

Members of staff may not offer customers, suppliers or other third parties services, gifts or any other advantages which would cause KST to take unfair advantage.

On certain occasions it is of course a standard practice in the business world to give your business partner or the staff member of your business partner a small gift or to extend an invitation. The following principle applies:

  • In no way may a gift serve a certain business deal, a public decision or to gain any other improper advantage.
  • With regard to the specific circumstances the upper limit of a gift value may not create the impression that in return a certain behaviour is expected from the recipient of the gift. The gift may not trigger feelings of obligation in the recipient.

Any impression of dishonesty and impropriety must be avoided. Alternatively, a limit value of 35 € net per year and business partner or staff member of the business partner can be used.

The acceptance or donation of cash or cash equivalents is strictly forbidden.

Stricter standards have to be applied especially in what concerns dealings with officials and representatives of public institutions. With regard to these groups of persons, gifts and invitations shall be permitted only in exceptional cases and only if refusing an invitation would be discourteous.

3. Fair Competition

We comply with applicable antitrust and competition laws.

We express our clear and unconditional commitment to the principles of a free market economy and fair competition. Our business objectives are pursued solely on the basis of performance principles in compliance with the applicable competition rules. This concerns the applicable antitrust- and commercial laws and the respective laws for retail price maintenance, competition and consumer protection. We expect the same from our competitors and business partners.

  • Prohibited are in particular agreements with competitors and concerted practices which have as their object or effect the prevention or restriction of competition for example agreements on prices, offers, production- and sales quotas as well as agreements on the sharing of customers, geographic areas and markets.
  • The prohibition applies not only to formal agreements but also to concerted practices, informal discussions and gentlemen’s agreements.

4. Handling Conflicts of Interest

We ensure, that our private interests do not conflict with those of the company.

A conflict of interest may arise when an employee, his/her family members or close friends are engaged in activities which could affect the objectivity and impartiality of the staff member in connection with the execution of his/her professional duties. The range of such activities might include supporting services for customers, suppliers, service providers and competitors or significant financial interests or participation in these activities.

If there exists, could exist or if there appears to be a conflict of interest the respective employee shall immediately and fully inform his superior or the chief compliance officer about these circumstances.

5. Money Laundering

We ensure that KST is not misused for money laundering or other illegal purposes.

Money laundering refers to the process of financial or economic transactions by which illegally acquired liquid assets are introduced into the legitimate financial system. We hereby explicitly point out that according to the provisions on criminal liability money laundering is a criminal offence. All employees shall procure sufficient information about the client’s business environment, the client itself and the purpose of the intended business.

6. Compliance with the Code of Conduct

We adhere to the Code of Conduct. We cannot accept any breaches of KST‘s principles.

6.1. Legal Consequences of Violations

All staff members of KST take personal responsibility to ensure that his or her actions comply with this Code. In cases of severe and/or particularly clear violation of this Code of Conduct, labour-law related measures are taken in the context of the applicable laws and regulations.

6.2. Clarification of Questions and Acceptance of Evidence

For questions and comments in relation to the provisions of this Code of Conduct, staff members are invited to contact the compliance officer of KST (