Codes of conduct

for companies of the
Doppelmayr/Garaventa Group
and their employees


Dear Colleagues,

Our companies operate globally, and our products are used worldwide. It is your dedication and commitment that has made us number one in the world.

We have clearly defined values. Our vision is to be fair and respectful to our employees and any third parties, act with integrity, and conduct our worldwide operations in compliance with national and international regulations.

This Code of Conduct is intended to serve as a guide for implementing the values 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.

Wolfurt, October 2011
Michael Doppelmayr Hanno Ulmer
DOPPELMAYR HOLDING AG
MANAGEMENT BOARD


Table of Contents
I. Purpose and Scope
II. Compliance with Applicable Law
III. Employees
IV. Open and Fair Competition
V. Granting and Accepting Undue Advantages
VI. Relations with Customers and Suppliers
VII. Conflicts of Interest
VIII. Protection of Trade Secrets
IX. Protection of Assets
X. Safety, Health, Environment
XI. Money Laundering, Corruption
XII. Books of Account
XIII. Implementation

I. Purpose and Scope
This Code of Conduct is a guideline that applies to all business activities of the Doppelmayr/Garaventa Group. It sets clear standards for integrity and correct business practices and is binding on all employees of the Doppelmayr/Garaventa Group.
Employees are required to exercise sound judgment in a responsible and circumspect manner and to be guided by honesty, reliability and uprightness. Employees must not use their position to gain an advantage for themselves, or encourage or tolerate any behavior contrary to this Code of Conduct.
Consultants, representatives, dealers, subcontractors or other persons working for the Doppelmayr/Garaventa Group are also required to abide by this Code of Conduct.

II. Compliance with Applicable Law
Each and every employee must comply with the laws and regulations of the legal system under which he or she operates.

III. Employees
All employees should show common courtesy, mutual respect, fairness and trust when working together. Open communication should be a constant feature.
Every employee is to be treated respectfully. The privacy of each and every employee is to be duly respected.
Employees should be selected and promoted on the basis of their qualifications for the intended position, without regard to race, age, sex, nationality, religion, sexual orientation, health status. Employee safety at work must be given top priority.

IV. Open and Fair Competition
The Doppelmayr/Garaventa Group is committed to fair and open competition in the global markets. Anti-competitive agreements with competitors on prices, production services, distribution, bidding, resale prices, market sharing, abuse of a dominant position in the market are not permitted.

V. Granting and Accepting Undue Advantages
Employees are allowed to give or accept gifts within the ambit of maintaining ordinary business relations, provided such gifts are of a very small intrinsic value or are socially customary.
In business dealings or dealings with the public authorities, employees are not allowed to procure advantages to business partners, their employees, members of the authorities or political parties, whether directly or indirectly, if the type and scope of such advantages are likely to influence the actions and decisions of the person receiving such an advantage.
Similarly, employees must not demand such advantages of or accept them from business partners.

VI. Relations with Customers and Suppliers
Customers and suppliers are selected based on objective and transparent evaluation criteria.
The Doppelmayr/Garaventa Group acts correctly and with integrity in dealing with its suppliers and customers.

VII. Conflicts of Interest
Employees must act in the best interest of the Doppelmayr/Garaventa Group and not on the basis of personal interests. Accordingly, situations where personal interests collide with the interests of the Doppelmayr/Garaventa Group must be avoided. Employees shall inform their supervisors of any such conflicts of interest that may arise.
In particular, employees must not acquire an interest in or enter into their own business relationships with competitors, suppliers or customers, except for interests in listed companies.

VIII. Protection of Trade Secrets
Every employee is obligated to keep confidential any business information about the Doppelmayr/Garaventa Group or its business partners that has not been made known to the public, to take precautions to prevent such information from becoming known unintentionally and to use such information only to the extent necessary to safeguard business interest.
Employees must respect the business secrets of competitors. Information about competitors must be collected in a fair and lawful manner.
When exchanging information electronically, effective measures must be taken to ensure data security and protect the personal rights of all those concerned.
Maintaining relations between the Doppelmayr/Garaventa Group and the mass media is reserved exclusively to the competent employees.

IX. Protection of Assets
The Doppelmayr/Garaventa Group makes available to its employees the tangible fixed assets, such as buildings, facilities, equipment, and other assets, such as inventories, liquidity, industrial and intellectual property rights, know-how, that are required for performing their work.
Employees must treat such tangible fixed assets and other assets with care and protect them against loss, theft or damage.
As a matter of principle, the tangible fixed assets and other assets of the Doppelmayr/Garaventa Group must not be used for purposes other than business. Private use is not permitted without written consent.

X. Safety, Health, Environment
The Doppelmayr/Garaventa Group commits itself to preventing damage to persons, physical assets and the environment in any business operations.
It supports the responsible use and conservation of the environment and natural resources. This especially applies to the development and use of new products and manufacturing technologies.

XI. Money Laundering, Corruption
The Doppelmayr/Garaventa Group maintains business relationships with customers, consultants and business partners with good reputation only.
The Doppelmayr/Garaventa Group acts in compliance with national and international anti-money-laundering and anti-corruption regulations. Employees must abide by the relevant regulations.

XII. Books of Account
The business processes and transactions of the Doppelmayr/ Garaventa Group must be correctly entered in the books of account, in compliance with the laws and accounting standards applicable in the respective country.
The entries must be complete, with a reasonable level of detail, and made in accordance with the internal control system.
All financial transactions must be properly documented in the relevant books. The books and documentation must be available for inspection by the audit department.

XIII. Implementation
The Management of each company of the Doppelmayr/Garaventa Group must ensure that the employees take note of and abide by this Code of Conduct.
If an employee discovers that this Code of Conduct has been violated, he or she must report the violation to the Management of the respective company, or to the Management Board of Doppelmayr Holding AG. Such reports are guaranteed to be kept confidential. No employee may suffer any adverse consequences as a result of reporting a violation in good faith.
Any violation of this Code of Conduct by an employee can entail measures under labor law, including even termination of employment, and other legal consequences.


Doppelmayr Holding AG
Rickenbacherstraße 8-10
A 6961 Wolfurt/Austria
T +43 5574 604
F +43 5574 75590
dm@doppelmayr.com / www.doppelmayr.com

11 / 2011