Code of Conductfor companies of the Doppelmayr/Garaventa Group and their employees

Dear Colleagues,

We are all global players. Thanks to you we have become one of the world’s market leaders. We have clearly defined values. Our vision is to be fair and respectful to our employees and any third parties, to act with integrity, and to conduct our worldwide operations in compliance with national and international regulations.

This Code of Conduct is based on values, the Corporate Statement and the Corporate Objectives of our Group and is to be followed by employees at all levels. The reputation and future of our globally operating Group are dependent on each and every individual.

Employees who lead others are particularly responsible to see that the Code of Conduct is followed in everything we do. They serve as role models and must ensure that the employees reporting to them understand the requirements of the Code of Conduct. In addition, they must monitor compliance with the Code of Conduct.

Dear valued business partners,

Our success is based on the conduct and actions of the employees of the Doppelmayr/Garaventa Group and the cooperation with business partners. We act upright, respectfully and fair and conduct our worldwide businesses in strict accordance with national and international regulations.

The present Code of Conduct is a guideline that applies for all activities of the Doppelmayr/Garaventa Group and sets definite standards regarding integrity and correct business conduct. It forms the basis of our compliance management system. Advisers, representatives, consultants, retailers, suppliers or other persons working for the Doppelmayr/Garaventa Group should also follow this Code of Conduct.

Within the framework of our compliance programme, we have also regulated the topic of gifts and invitations. In order to avoid inconvenient situations, the most important rules are summarized below.
            

Basics

The fundamental principle is that every acceptance of an advantage and every granting of an advantage, that may convey the impression that someone is influenced in their decision making by the advantage, must be avoided.

Gifts and invitations by business partners to our employees

Occasional granting of advantages of a value of up to EUR 100 is basically admissible, provided that it is not directly linked to a business transaction. Gifts of money may not be accepted. In other words: Non-cash gifts of a value of up to EUR 100 per employee or business partner are unobjectionable. Gifts of money may not be accepted. Gifts with quasi-monetary character (i.e. shopping vouchers, toll stickers, vouchers for weekend trips, etc.) as well as presents of a higher value may be accepted after prior written approval of the superior but must be made available to the company which can then use them, i.e. for raffles in the course of company events.

Placing of private orders of our employees to suppliers of the Doppelmayr/Garaventa Group            

The commissioning of suppliers of a member company of the Doppelmayr/Garaventa Group for private purposes is allowed if the conditions granted are possible for all employees of the respective company. However, it is not allowed to condition the company orders for the supplier on more attractive terms for private orders that only apply for individuals.

We thank you very much for your cooperation and are looking forward to future collaborations.

Wolfurt, May 2013
Michael Doppelmayr, Hanno Ulmer
DOPPELMAYR HOLDING AG
BOARD OF DIRECTORS