Compliance is everybody’s responsibility.
Dr. Ilkin Karakaya
Group General Counsel and Head of Legal and Compliance
Dr. Anita Schieffer
Group Compliance Officer

We energize society with integrity. This is not just what we do — it defines who we are. Every day, our work shapes lives, communities, and the world around us. The trust placed in us is never simply given. It is earned through the decisions we make and how we act.
Everything is connected. Our complex geopolitical environment and the business decisions we make — including supplier choices, responses to customer requests, and how we handle privacy concerns, human rights questions, and export control issues —affect our company, our stakeholders, and the trust others place in us.
That is why this Code of Conduct is the heart of our Compliance System. It helps us prevent misconduct, identify risks, and respond fairly when concerns are raised. It turns our standards and policies into practical guidance by helping us recognize risks early, seek advice, raise concerns, and act consistently and fairly. It does not replace judgment — it supports it.
Every day, people across Omterra make decisions with legal, ethical, and reputational consequences. Some decisions are routine. Others involve external pressures, incomplete information, competing expectations, or uncertainty about the right next step. This Code of Conduct is written for those moments.
Legal and Compliance is here to support you in making responsible decisions. If you need guidance or have a concern, contact Legal and Compliance, your Manager, Human Resources, Employee Representatives, the Speak Up Hotline, or the Ombudsperson. Questions and reports will be handled with care, professionalism, and fairness. Omterra does not tolerate retaliation against anyone who speaks up in good faith.
Responsibility is always on. By living our Code of Conduct daily, we strengthen our ability to Energize Society with Integrity, today and in the future.

