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.

Information to business partners To our valued business partners: Our Compliance Program also addresses the issue of gifts and invitations. To avoid embarrassing situations, an extract from those rules is also made available to our business partners. Gifts from business partners to our employees Gifts in kind the value of which does not exceed EUR 150[1] per employee, business partner and calendar year are unobjectionable. Gifts of money must not be accepted. Gifts of a quasi-monetary nature (e.g., shopping vouchers, toll stickers, vouchers for weekend trips, etc.) and gifts of higher value may be accepted but have to be made available to the company, which may make further use of them, e.g., for raffles during company events. Business lunches or dinners, business entertainment As a matter of principle, invitations to business lunches or dinners may be accepted to the extent they are customary in the trade and position. The same applies to business entertainment according to local custom (coffee, mineral water, lunch in the canteen, etc.). Business entertainment (e.g., buffet) during general company events (Open House, inauguration of a new ropeway, anniversary celebrations, etc.) are also considered to be unproblematic if attended by a large number of customers. Placing of private contracts with Doppelmayr/Garavena suppliers by our employees Employees are allowed to place private contracts with suppliers of a company of the Doppelmayr/Garaventa Group if the terms granted are available to all employees of the respective company. However, employees are not allowed to make a company order placed with the supplier contingent on more favorable terms granted for private orders that only apply to individuals. We appreciate your understanding and thank you in advance for your cooperation in this regard. [1] National laws providing for a lower value limit than provided for in the Instruction "Anti-Corruption" shall be duly considered.

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