20. Conduct that Complies with the Law and Policy

The company discloses which measures, standards, systems and processes are in place to prevent unlawful conduct and, in particular, corruption, how they are verified, which results have been achieved to date and where it sees there to be risks. The company depicts how corruption and other contraventions in the company are prevented and exposed and what sanctions are imposed.

Good Corporate Governance involves responsible, value-based and sustainable corporate management and control. This includes the efficient cooperation between the Management Board and the Supervisory Board, respect for the interests of employees and shareholders, open and transparent communication as well as an appropriate approach to risk. This directly contributes to SDG BRAIN is targeting full operational alliance with all legal requirements and its own values. In addition, it is absolutely key for our business success to protect our Intellectual Property. To achieve this we have defined in our ESG Objectives Roadmap 2032: 

Detailed Actions Goals
The group engages in regular training sessions for all of its employees on compliance topics, data protection laws and workplace safety. All new employees have to complete an initial training and have to complete a standardized onboarding procedure.

Compliance
BRAIN has a legally trained internal compliance officer who conducts regular compliance trainings, monitors all compliance relevant processes and interacts with the respective authorities. The company has also established a whistle blower framework and will further adjust this to the upcoming new legal requirements. The compliance officer advises the board in coordination with investor relations on all potentially insider related matters. In addition, for science topics the company has established educational measures and checks to comply with laboratory and genetic regulations.

Tax Strategy
BRAIN Biotech believes its obligation as a responsible taxpayer is to comply with the tax legislation of the countries in which it operates and pay the right amount of tax at the right time. BRAIN does not only aim to comply with the letter of the law, but also with its spirit. BRAIN uses business structures that are aligned with business activities and that are driven by commercial considerations. BRAIN only makes use of tax incentives where they are (i) aligned with business activities and operational objectives, (ii) generally available to all market participants and (iii) specified by law. As such, tax strategy always follows the business decision.   BRAIN pays tax on profits according to where value is created within the normal course of its business activities. BRAIN does not use aggressive tax planning strategies or tax havens to minimize its tax burden. The transfer pricing of intercompany transactions is done in accordance with the arm’s length principle developed by the OECD and is applied consistently throughout the group. BRAIN maintains an open and constructive dialogue with tax authorities based on transparency and trust. BRAIN engages with them in honesty, integrity and respect.