Code of Conduct of the Handtmann Group of Companies

In the Handtmann Group of Companies, we not only want to provide outstanding products and services. Our conduct should also be without reproach at all times. What this means exactly we have summarised in the "Handtmann Code of Conduct".

The Handtmann Code of Conduct is based on the values of the Handtmann family and of the Handtmann Group of Companies, as well as on already existing regulations. A key factor for us was the guiding principle of the proper actions of a businessman. The Code of Conduct stipulates concrete patterns of conduct based on this guiding principle. It applies to all employees of the Handtmann Group of Companies throughout the world.

We abide by the laws of the countries which we operate in. This is in line with our fundamental values and applies irrespectively of the penalties that may be imposed.

Unlawful actions put the interests of our company at risk as they can result in serious damage to our reputation, criminal proceedings, compensation and the loss of orders. 

Employees who act unlawfully are in danger of being subject to criminal proceedings. Law-abiding conduct therefore helps to protect staff as well as the company.

This applies above all in countries in which criminal proceedings do not always comply with constitutional principles.

All employees are obliged to find out the required information about the laws and regulations valid in their area of responsibility and to comply with them.

In the case of doubt, consult the department responsible or your manager.

 

We comply with the laws for protecting competition and do not come to any agreements with competitors concerning our competitive conduct. 

The following are forbidden in particular: agreeing on prices and terms and conditions, dividing up markets and regions, allocating customers and agreeing on quote preparation strategies or production strategies. In this respect, it is not only explicit agreements which are prohibited but also agreed conduct. Even simply sharing information which could form the basis of agreed conduct of this nature (e.g. prices, costs, margins, terms and conditions, customers, production capacities etc.) with competitors is prohibited. Infringements to these prohibited actions are prosecuted systematically by the monopolies authorities and can result in sanctions which put the company in jeopardy.  

Bribery is unlawful and constitutes a high degree of risk for our employees and our group of companies. It must be refrained from in all situations. We do not offer our business partners any unlawful gains and do not accept any ourselves.  

We act with caution when it comes to accepting and giving presents and other benefits. On no account are these to be in a form that necessitates the recipient keeping its acceptance a secret or obliges the recipient to give anything significant in return. In the case of doubt, consult your superior. Particular caution is to be shown in connection with holders of official posts. The very strict legal stipulations throughout the world are to be complied with at all costs.  

Commission and remuneration received by dealers, agents or consultants may only be paid for authorised services which have actually been provided and must be in suitable proportion to these services.  

We comply with the regulations applicable to cross-border trade. This applies, first and foremost, to complying with existing import and export restrictions, obtaining necessary authorisations and paying the stipulated customs fees and taxes. In the event of uncertainty, the export officers are to be consulted. Compliance with these stipulations is subject to regular checks on the part of the authorities. In the event of infringements, the responsible parties and the company are at risk of significant sanctions.  

Business-related secondary employment on the part of an employee must be agreed on with the appropriate management team in advance. This applies in particular in relation to secondary employment with competitors, customers or suppliers or a financial interest in the above. If close relatives are involved in employment or financial interests such as this, this must be reported to the central Human Resources department.  

We keep business and private interests strictly separate and do not use our employment with the Handtmann group of companies for private gain. Commissioning business partners for private purposes is to be avoided. Business partners must not be favoured due to reasons of private interest.  

We comply with all the legal stipulations with respect to taxes and subsidies and also do not aid and abet tax evasion or subsidy fraud.

All employees must be aware that the risk of being detected is particularly high with tax offences due to regular and thorough checks on the part of the tax authorities.

Suspicious circumstances very quickly lead to the involvement of the law enforcement authorities.

If customers or suppliers are involved disclosures are sent to the tax authorities responsible for them and vice versa.

The assessment of circumstances in accordance with tax/subsidy law is often difficult. In the case of doubt, your superior must become involved and/or the central Finance department must clarify the situation.

We demand extremely high standards with respect to the quality and safety of our products and services.

We check our products thoroughly and help the customer to avoid risks.

We provide a safe working environment. Safety regulations are to be strictly complied with and are to be subject to continual checks to ensure that they are effective. Deficiencies are to be reported and rectified immediately.

We employ measures for health and safety in the workplace in line with the national and in-house directives.

We use natural resources sparingly and also aim to achieve this with our products. We avoid having any negative impact on the environment.

We protect the intellectual and tangible property of the Handtmann group of companies.

We use supplies and equipment carefully and in accordance with their intended purpose. We do not use supplies and equipment, including PCs, laptops, landline and mobile telephones, for private purposes unless this is explicitly permitted.  

We treat the property of the Handtmann group of companies in a responsible way. Unnecessary costs are to be avoided.

We make business decisions on the basis of commercially accountable analyses of opportunities and risks. In doing so, we also respect the integrity of our business partner.

As a technology company with a high level of investment in research and development, we are particularly reliant upon protecting our inventions and our know-how.

We are therefore extremely careful with trade secrets. Confidential information must not be accessed by unauthorised third parties. This also applies to confidential information we receive from our business partners.

We respect and support compliance with internationally-recognised human rights.

As a global company, we operate in an international market and a multicultural environment. We view diversity amongst people as an enrichment. Staff, employee representatives and management executives are aware of their responsibility and their impact as role models.

We therefore insist upon interaction with each other which is characterised by honesty and trust. We respect and protect the personal dignity of each individual person.

We oppose unequal treatment or debasement on the basis of gender, race or origin, religion or ideology or disability, as well as any other discriminatory conduct.

We do not tolerate any discrimination or harassment of our staff. We have a working relationship with the employee representatives that is based on trust.

Staff are to be protected from physical punishment and from physical, sexual and psychological harassment. The private sphere of each employee is respected.

The ban on forced labour of any kind is complied with. In particular, the Convention Concerning Forced and Compulsory Labour from 1930 (convention 29 of the International Labour Organisation) and the Convention Concerning the Abolition of Forced Labour from 1957 (convention 105 of the International Labour Organisation) are complied with. We comply with the regulations covering the ban on child labour applicable in each case.

 

 

Internal and external reports must be correct and complete in order that the recipient is given an accurate picture. We restrict ourselves to representing the facts and an objective mode of expression.

Documents which are required for ongoing or expected internal enquiries or investigations by authorities must not be destroyed, removed or changed.

We use personal data concerning our staff and contractual partners solely for the purposes for which it was provided and we treat it with confidentiality.

This Code of Conduct is binding for all employees of the Handtmann Group of Companies throughout the world. Infringements to this Code of Conduct will not be tolerated and will result in disciplinary action. Every indication of an infringement will be investigated.

The first point of contact for every employee in the event of questions or uncertainty about the principles of conduct is their superior.

Furthermore, every employee can consult the works council.

The following contact is also available at any time for further queries:

E-mail: compliance@handtmann.de

This e-mail address is forwarded to an external lawyer who will ensure that the information is treated with confidentiality.  

Each company in the Handtmann Group of Companies and each corporate division is responsible for compliance with the Code of Conduct and all internally-stipulated regulations. The relevant Handtmann management companies such as Albert Handtmann Holding GmbH & Co. KG or Handtmann Auslands-Beteiligungen GmbH have unrestricted information and auditing rights, provided that there are no statutory regulations which oppose this.

Biberach, 24.11.2015

Company Management            Group Works Council