This Code of Conduct is binding for all employees of the Handtmann Group of Companies throughout the world. In the event of a violation of this Code, laws or internal guidelines, employees must expect appropriate consequences, including measures under labour law and disciplinary measures. Such violations can also result in consequences under criminal and liability law which can endanger the existence of the company as well as its employees. In order to comply with our voluntary commitment to ethical conduct, we are dependent on every employee – including interns, people in training, external and holiday workers – and all stakeholders (e.g. customers or suppliers) who identify a potential violation of this Code of Conduct, reporting it immediately.
The responsibilities and procedures for dealing with and protecting persons who provide information on violations of the Code of Conduct (hereinafter referred to as “whistleblowers”) are regulated as follows:
The first point of contact for every employee in the event of questions or uncertainty about the principles of conduct is their superior. Every employee can also contact the works council or the compliance officer. In addition, an external lawyer is available as a contact for further inquiries and for reporting material violations of the Code of Conduct at firstname.lastname@example.org. Feedback on the next steps will be given according to the situation, at the latest within three months.
Anonymous messages cannot be processed in a targeted manner. For possible queries and information on further action, the name of the whistleblower of the first reference person is to be named. The contact persons and compliance officers must treat all contacts confidentially and follow them up immediately. Upon request, the identity will hereafter be treated anonymously.
Any employee who asks for advice in good faith or provides evidence of misconduct thus fulfils his obligation under the Code of Conduct; no employee has to fear disadvantages – subject to sanctions for a violation of the Code of Conduct.
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, 11th July 2018
Company Management, Human Resources Manager, Group Works Council
*“In the interest of better legibility, no explicit distinction is made between gender-specific denominations of persons. The male form chosen shall include an adequate female form on an equal footing.”