CODE OF CONDUCT
CONTENT
1. HUMAN RIGHTS
1.1 Fundamental social rights and principles
1.2 Equal opportunities, principle of non-discrimination and mutual respect
2. PROTECTING THE ENVIRONMENT
3. DEALING WITH BUSINESS PARTNERS
AND THIRD PARTIES
3.1 Fair competition and avoiding tax evasion
3.2 Trade control
3.3 Dialogue with retailers and business partners
4. ANTI-CORRUPTION MEASURES AND AVOIDING CONFLICTS OF INTEREST
4.1 Corruption and bribery
4.2 Donations and sponsorships
4.3 Conflicts of interest
5. DATA PROTECTION AND DATA SECURITY
6. COMPANY PROPERTY AND BUSINESS
AND TRADE SECRETS
6.1 Company property
6.2 Business and trade secrets
7. EMPLOYEES
8. SAFETY AT WORK & HEALTH PROTECTION
Responsible, ethical and lawful actions are the fundamental requirements for the success of our company. This has always been an integral part of our company culture and forms the basis of the trust that our customers, business partners and the public have in us.
Our company group includes the companies hauck GmbH & Co. KG, the EURET 3000 GmbH and the KP Family International GmbH. Our business environment is becoming ever more complicated due to the numerous legal requirements, increasing the risk of non-compliance. The company group is aware of these challenges and has therefore adopted the following Code of Conduct.
The Code of Conduct is based on fundamental principles that apply to all employees and management of the company group. All our employees must adhere to the laws, regulations, standards and internal rules and act in accordance with the principles and corporate values of the company group. The reputation of the company group is based on the behaviour, actions and conduct of each individual. The inappropriate behaviour of just one employee can cause considerable damage to the company group. When carrying out their activities and appearing in public, all our employees pay attention to adhering to the applicable laws and not damaging the reputation of the company.
Every employee is personally responsible for complying with this Code of Conduct. Every supervisor/manager must ensure that their employees know and adhere to the Code of Conduct. If you have any questions about the principles of conduct, please first contact your supervisor or a manager. Violations against the Code of Conduct can be reported to the contact address for whistleblower protection.
1. HUMAN RIGHTS
1.1 Fundamental social rights and principles
The company group undertakes to comply with international human rights within its sphere of influence. We are staunchly opposed to child labour. All our employees must be at least the national minimum working age as prescribed by law. We reward performance with fair wages which are based on expertise, responsibility and experience. We reject any form of forced labour; all employees must be employed of their own free will. We respect our employees’ right to freedom of association. Notwithstanding the above, we always empower our employees to directly express their interests.
1.2 Equal opportunities, principle of non-discrimination and mutual respect
We guarantee equal opportunities and equal treatment regardless of ethnic origin, skin colour, gender, disability, philosophical beliefs, religion, nationality, sexual orientation, social background or political affiliation, provided this is based on tolerance and respect towards people with different opinions. We always source, hire and promote our employees on the basis of their skills and qualifications. All employees are obligated to refrain from any form of discrimination (such as unfair treatment, harassment or bullying) and to facilitate a respectful working environment.
Our requirements…
- We always treat our colleagues, managers, business partners, customers and suppliers with respect.
- Do not judge any fellow human beings on the grounds of ethnic origin, skin colour, gender, disability, philosophical beliefs, religion, nationality, sexual orientation, social background or political affiliation or age.
- No bullying or discrimination is tolerated. Regardless of whether it affects you or a fellow human being, we always turn to the person of trust when an incident occurs.
- Always speak respectfully about people as if they were present. In the event of conflicts and disagreements, we speak WITH the person concerned and not ABOUT the person.
- No verbal or physical disputes will be tolerated. All forms of violence are prohibited.
My self-monitoring…
- Do I look away when I notice that someone is being treated unfairly, ostracised or bullied?
- Do I treat others with whom I don’t get along in a respectful and fair manner?
- Do I gossip with others or in groups?
2. PROTECTING THE ENVIRONMENT
The company group respects and wishes to preserve the environment; the company is active in implementing sustainability as well as environmental and social responsibility towards our employees, customers and the public. We use resources efficiently, continually optimise our processes and comply with all requirements of country-specific environmental laws.
We want a future where the healthy development of children is driven by our product innovation and our way of working. To this end, we always strive to deploy new and innovative technology in manufacturing and development. Environmental efficiency and sustainability should affect the entire lifecycle of the product.
We encourage employees to become involved with protecting the environment and to use all the resources that we use in our business appropriately, economically and efficiently.
Our requirements…
- Use our resources wisely and carefully.
- Dispose of waste materials that cannot be avoided or recycled in a responsible manner.
- Avoid general wastage (such as paper when printing).
- Constantly try to optimise workflows & processes and improve on mistakes.
My self-monitoring…
- Do I always think about how I’m using resources (such as conserving energy by not leaving the printer and the lights on when leaving work, or forwarding emails instead of printing them)?
- Do I separate waste materials (e.g., foil and cardboard) to make recycling easier?
- Do I kindly point out how others can conserve resources (such as periodic ventilation rather than constantly having the window open)?
3. DEALING WITH BUSINESS PARTNERS
AND THIRD PARTIES
3.1 Fair competition and avoiding tax evasion
We commit to dealing with our business partners and third parties fairly. We support fair and undistorted competition by adhering to anti-competition and cartel law. We refrain from fixing prices and conditions and from entering into agreements about strategies. Furthermore, we do not participate in market division or any anti-competitive boycotts. It is important to be careful about and sensitive to staying on-topic in all meetings with business partners and competitors, as these can quickly become questionable with regard to anti-competition and cartel law. We expect our employees, managers and business partners to fulfil their fiscal obligations. Knowingly facilitating tax evasion is not permitted or encouraged.
Our requirements…
- Do not enter into any agreements with competitors (reg. price information or market strategies).
- Do not share or exchange any information relevant to competition with our competitors.
- Do not enter into any agreements regarding tenders or bids.
- Do not organise any boycotts of specific customers or suppliers.
- Distance ourselves from competition-sensitive topics if they come up & report this to our supervisors.
- Inform our manager if we’re unclear about the lawfulness of a process/witness anti-competitive processes.
My self-monitoring…
- Have I been confronted with competition-sensitive topics? How did I react?
- Do I know how I would act if competition-sensitive topics are brought up?
3.2 Trade control
We adhere to the statutory provisions which prohibit or restrict the import and export of goods or regulate the provision of services and financial transactions.
3.3 Dialogue with retailers and business partners
We always behave fairly and honourably towards our retailers and business partners. We always treat our partners’ commercial information, trade secrets or similar as confidential and store documents properly. We take note of expectations and wishes in order to guarantee good collaboration with our retailers and business partners.
Our requirements…
- We inform our superiors if business partners don’t act acc. to agreements, contracts, rules or laws.
- We treat our business partners and third parties with respect and dignity.
- We adhere to agreements, contracts, rules and laws as we expect from our business partners.
- We respond in a legally compliant and fair manner in the event of negative anomalies.
My self-monitoring…
- Do I always try to get the best out of a collaboration with a business partner (good business relationships)?
- Do I always fairly and reliably represent company group and adhere to the appropriate etiquette?
- Do I always make my decisions in a neutral, impartial manner and consider the rules of politeness?
- Do I openly comment on discrepancies or grievances, or do I pass these on to my manager?
4. ANTI-CORRUPTION MEASURES AND
AVOIDING CONFLICTS OF INTEREST
4.1 Corruption and bribery
We support national and international efforts to prevent competition being influenced or distorted by bribery and reject any corrupt behaviour that damages the company.
No employees are permitted to exploit the business connections of the company group for their own benefit or that of a third party, or to exploit the company group to the detriment of the company.
We undertake to not give or accept any unpermitted private advantages (such as money, items or services) or provide or accept entertainment or hospitality which could influence our decisions in business transactions.
BMI - Publikationen - Praktische Hilfestellungen für Antikorruptionsmaßnahmen (bund.de)
4.2 Donations and sponsorships
We only make donations - voluntary contributions made without expecting anything in return - and provide sponsorships in accordance with the respective legal system and in compliance with our internal regulations. Donations we make are transparent and verifiable. Our sponsoring activities support culture, education, science and sport.
Our requirements…
- Contributions may only be made or accepted if this complies with local laws.
- Avoid even creating an impression that influence is potentially being exerted and do not give any third parties cause to suspect influence is being exerted.
- All contributions must be transparent and documented.
- If we are socially involved with donations or sponsorships, this is never connected to business decisions.
- Pay particular attention to avoiding contributions when dealing with public officials.
- Do not accept any gifts, invitations or other contributions which influence a business decision and grant a personal, private or business advantage.
- If there is any doubt, decline any gifts, invitations or other contributions in a friendly manner.
- When making important decisions, always use the four-eye-principle.
My self-monitoring…
- Do I know what I would do if I received an invitation, a gift or a contribution? Which policies must I adhere to regarding this?
- Do I always document my decisions in business transactions in a transparent and traceable manner?
- Have I ever been in a situation where I was offered money, gifts or favours in the context of a business decision?
- Do I take a stand if I suspect corruption and do I know who I should contact?
4.3 Conflicts of interest
It is important to us that our employees are not in a conflict of interest between their private interests and those of the company when they are working. Their decisions should only be made on the basis of objective criteria. All situations where a conflict of interest could arise must be therefore avoided or immediately reported to a manager.
Our requirements…
- First think for ourselves whether there is a conflict of interest or whether it could lead to one.
- Think whether we could solve the conflict of interest on our own. If this is not the case, speak to our manager and collectively seek a solution.
- Inform our manager and HR of any secondary employment.
- In our free time, solve any conflicts of interest in social, political and cultural situations carefully.
- Do not use any documents or information for personal use that are only accessible to us.
My self-monitoring…
- Do I know how to avoid conflicts of interest and how to act in these situations?
- Do I know what situations can give rise to a conflict of interest?
Examples of conflicts of interest:
. Relatives or friends working for the same company (different management levels).
. Having secondary employment without the consent of your employer.
. Using business information for personal use.
. Showing preferences for things in private which could have a negative impact on the company.
5. DATA PROTECTION AND DATA SECURITY
We only collect, process and use personal data to the extent this is required for the specified, explicit and legitimate purpose. We ensure that the usage of data is transparent for the data subjects and that data subjects’ rights of access and rectification are granted, plus, if applicable, their right to object to processing and to have data blocked or erased. We undertake to use an adequate level of protection to protect information processing. All components of information processing must be secured so that the confidentiality, integrity, availability and verifiability of the information to be protected is guaranteed and unauthorised internal and external usage is prevented.
Our requirements…
- Act in accordance with the German Federal Data Protection Act (BDSG) and the General Data Protection Regulation.
- Protect the data of our fellow human beings, employees, customers and business partners and respect their privacy.
- We employ a Data Protection Officer who follows and adheres to all legal requirements.
- Store all personal data carefully and make sure it is inaccessible to unauthorised parties.
My self-monitoring…
- Have I learnt which rules I must follow regarding data protection?
- Am I sure that personal data, data that has been transferred to me and other data is stored securely in my care?
- Do I respect the data protection/privacy of my colleagues?
Data protection examples:
. Leave documents on the printer face down.
. Documents are placed face down on my desk.
. Discussions with employees are held in separate rooms.
. Data subjects are always asked in advance whether information may be disclosed.
6. COMPANY PROPERTY AND
BUSINESS AND TRADE SECRETS
6.1 Company property
Company property and assets assist the company group in achieving the company objectives. Employees are expected to safeguard this property and assets. It is irrelevant whether these are tangible, intangible or financial assets. Working time and work results are also assets. Unless separate regulations permit private usage, employees may only use the company property of the company group for business purposes. Employees must handle the property of the company group with care and use the property as intended.
Our requirements…
- Protect all assets, company property and resources provided to us (e.g. laptop).
- Theft of company property/assets will be reported and not be tolerated.
- Unless otherwise agreed, equipment and services such as the Internet and email will only be used for business purposes.
- Damage, unnecessary costs and other losses must be avoided.
My self-monitoring…
- Have I knowingly ever used, or do I use company property, working time or information for private purposes?
- Am I careful with company property I've been provided with?
- Do I openly speak to colleagues if they are not careful with company property?
- Do I know what I should do if I discover a theft?
- Is the information provided in the expense reports I submit (such as travel expenses) correct?
6.2 Business and trade secrets
Employees are obligated to treat all business and trade secrets that they have been entrusted with during the course of their business activities or have otherwise became aware of as confidential, not make them accessible to unauthorised persons and not use them for unauthorised purposes. Business and trade secrets must not be disclosed to third parties and must only be used within the scope of agreements entered into with the respective third parties. We recognise the intellectual property of competitors and business partners.
Our requirements…
- Internal company know-how, annual reports, company reports, cost overviews as well as all information about customers, suppliers and employees must be treated as strictly confidential, unless this information is already in the public domain.
- We must have the consent of our manager and/or enter into a contract before providing information to third parties or business partners.
- We do not pass on confidential information that is only intended for a specific group of people to other groups of people, either internally or externally.
My self-monitoring…
- Have I informed myself about what falls under business and trade secrets?
- Do I or have I in the past disclosed private company information?
- Do I shared confidential info’s (intern/extern) that was only intended for a specif. group of people?
- Do I ensure that I deal with confidential information responsibly?
- Do I dispose of documents correctly and not leave them visibly lying around my desk?
7. EMPLOYEES
Each employee in the company is a part of a whole in their area. All tasks are connected with a view to achieving good results. The ability of the individual business areas to work together as a team is paramount to good cooperation and success at work. We support and promote constructive teamwork.
The company group expects all of its employees to concentrate on their work and to perform it properly and in a goal-oriented manner. All company group internal guidelines, policies and regulations must be adhered to and observed by all employees. Employees may face disciplinary action in the event of non-compliance.
Our requirements…
- We do not close our eyes to new opportunities and are open to new possibilities and changes.
- Our goal in the team is to enable good cooperation based on trust. We always act as role models for others and actively model the desired behaviour.
- As a manager, you enable your employees to take on responsibility within their area of competence and encourage them to make suggestions for improvement (empowerment).
- We live an open feedback culture for which we have established rules.
- We treat our colleagues fairly and speak openly if the other person's behaviour does not correspond to our code of conduct.
My self-monitoring…
- Am I receptive to changes?
- Do I behave in an exemplary manner and do I consciously model the desired behaviour?
8. SAFETY AT WORK & HEALTH PROTECTION
The company group is responsible for the health & safety of its employees. We ensure that all country-specific statutory occupational health & safety requirements are implemented in the workplace. We maintain and promote the health & safety of our employees and a productive work environment through various preventative and health promotion measures. Using any form of alcohol, drugs and other substances in conjunction with work will not be tolerated. All employees contribute to the promotion of health & safety and adhere to the occupational health & safety regulations.
Our requirements…
- Incidents and accidents are documented in accordance with the statutory requirements.
- Safety information, instruction manuals and internal regulations regarding operating machinery must be complied with at all times.
- Always wear the appropriate personal protective equipment in accordance with the work we are carrying out.
- All machinery (e.g. forklifts) must be inspected before each use to make sure it is safe to use and free of any faults.
My self-monitoring…
- Do I have the necessary training/knowledge to operate specialist machinery? (forklifts)
- Do I know what to do in the event of an accident? What is the procedure?
- Do I know where the first aid box, assembly points, fire extinguishers and fire exits are in the event of an emergency?