Fair market conduct
We are fair and responsible market participant and adheres to its contractual obligations.
We also expect the same from its suppliers and business partners and especially expects
them to observe the basic principles that follow.
Free competition
We comply with the antitrust legislation in force. In
particular, we do not enter into any anti-competitive agreements with competitors,
suppliers, or customers. If we are in a dominant position on the market, we do not abuse
this position.
Export control
We make sure that they comply with all applicable legal provisions for importing and exporting goods, services, and information.
Money laundering
We only conduct business relationships with business partners of whose integrity they are convinced. We ensure that the applicable legal money laundering provisions are not breached.
Business information
We publish business information and report on our business activities truthfully and in line with the laws in force.
Protection of data, business secrets and company assets
Confidential data, business secrets, and company assets have to be protected. We expect suppliers and business partners to especially observe the basic principles that follow.
Data protection
We observe all laws in force to protect the personal data of employees, customers, suppliers, and other parties concerned.
Protection of know-how, patents, trade and business secrets
We respect the know-how, patents, trade and business secrets of us and third parties and do not pass such information on to third parties without the express prior written consent of us or in a way that is otherwise inadmissible.
Handling company assets
We respect our tangible and intangible assets and do not use them for unfair or non-business purposes. We ensure that our employees as well as any third parties they commission in the business relationship (such as subcontractors or representatives) neither damage nor misuse our assets, i.e. use these assets contrary to our interests.
Security of the international supply chain
We have to ensure that the business premises and the loading and shipping areas where products for our customers are produced, stored, prepared, loaded and transported, are protected against unauthorized access within a safe and secure supply chain, and that all employed staff is reliable.
Anti-Corruption
We force a culture of integrity and ensure strict compliance with anti-bribery and
anti-corruption laws across all jurisdictions where we operate.
All employees, directors, and members of our company must comply with this and its
associated procedures, even if local laws permit behaviours that this Policy prohibits.
Anything of Value: Includes, but is not limited to, money, gifts, meals, entertainment,
sponsorships, donations, job opportunities, goods, or properties.
Bribery: The offer, promise, payment, or granting of Anything of Value to improperly induce
Corruption: Dishonest, unethical, or illegal conduct by someone in a position of authority,
often involving an Improper Advantage to gain personal or business benefits.
Facilitation Payments: Payments made to expedite or secure routine governmental actions by a Government Official.
Improper Advantage: A benefit that a company or individual is not entitled to, often obtained through bribery or corrupt practices.
Third Parties: Any individual, company, or entity doing business with us. including suppliers, clients, business partners, and recipients of socioenvironmental investments.
Principles:
We are committed to conducting business with the highest standards of integrity and ethics. Corruption is illegal, unethical, and incompatible with our values.
We have zero tolerance for bribery and corruption in any form. All activities must comply with applicable anti-corruption laws.
Prohibitions:
Bribery: Employees and administrators are prohibited from giving, promising, offering, or authorizing payments or Anything of Value private person to obtain an Improper Advantage.
Facilitation Payments: These are strictly prohibited and must not be made by any employee or administrator.
Cash Gifts: It is forbidden to give cash gifts or cash equivalents, such as gift cards, Gifts, Meals, any Entertainment to Any private persons.
Political Contributions: Employees and administrators must not make political donations or contributions on behalf of our company, including donations to political parties, candidates, or campaigns.
Third Parties: Employees and administrators must not use third parties to carry out activities that we prohibited from performing directly.
Due Diligence: Perform appropriate Anti-Corruption Due Diligence on third parties and business acquisitions to identify potential risks.
Red Flags: Be vigilant for any Red Flags that may indicate potential corruption risks and report any concerns.
Recordkeeping: Maintain accurate and transparent records of all our business transactions.
Cooperation: Employees and administrators must fully cooperate with investigations and maintain confidentiality.
Training: Corporate Integrity will conduct periodic anti-corruption training, which is mandatory for all employees.
General Manager will maintain the Anti-Corruption Policy, overseeing Corporate Integrity, and reports directly to the Board as needed.
Consequences Management and Responsibilities:
Violations: Any violation of this Policy will result in disciplinary actions, which may include dismissal.
Legal Penalties: Violations of anti-corruption laws can lead to civil or criminal penalties.
Termination of Third-Party Relationships: we may terminate a relationship with any third party found to be in violation of this Policy.
Reporting: Employees, administrators, and third parties must report any suspicious activity or potential violations immediately through the Whistleblower Channel.
(See whistleblowing policy)