We have zero tolerance for corruption, anti-competitive practices and other violations of applicable law. But compliance means more to us than just adhering to laws and internal regulations on paper; it forms the basis of all our decisions and activities and is the key to integrity. For this reason, issues such as environmental protection, sustainability and transparency also play a crucial role for us.
- 1.0 Law and Responsibility
All employees must comply with applicable laws, regulations, and internal policies in their work environment. Violations of the law as well as violations of internal regulations must be avoided at all costs. 595° Solutions expects all employees to protect and promote the reputation of the company in public. In the case of private statements made by employees in public, it must be ensured that they do not give the impression that they are comments that originate from the company.
- 2.0 Product Quality and Security
595° Solutions products are manufactured under the strict observance of our quality specifications. We achieve maximum product safety through an optimal quality management system and a consistent zero-defect strategy. All legal and internal rules on product safety are to be strictly adhered to as an expression of our comprehensive product responsibility. Employees have no hesitation by informing the relevant specialist departments about safety concerns, so that everything necessary to protect our customers can be arranged.
- 3.0 Competition Law and Cartel Law
595° Solutions pursues its corporate goals in compliance with the rules of free and fair competition. Therefore, compliance with all national and international legal requirements of competition and antitrust law is a fundamental principle of our actions at all levels of the company. Employees may not participate in any antitrust-illegal behaviour. This means in detail:
- 3.1 Behaviour against Competitors
Employees may not enter into antitrust agreements with competitors or coordinate their conduct on the market with competitors. The unilateral disclosure of sensitive or strategic information to competitors, such as all types of pricing information (net prices, gross prices, price lists, etc.), price increases, capacity utilisation, new orders, future projects may already lead to an antitrust violation.
Antitrust law prohibits any restriction of competition, that is, all measures aimed at reducing the risks of free and unhindered competition. It prohibits, for example, the reconciliation of prices, the division of markets (by customers or territories) and the determination of market shares of each competitor.
- 3.2 Behaviour to Customers and Suppliers
Prohibition, also in relation to customers and suppliers are agreements that restrict the competitive freedom of action.
These include, in particular, restrictions on the freedom of customers to specify delivery conditions or prices independently. Certain forms of exclusive supply, customer restrictions, exclusivity, non-compete or use restrictions may also be prohibited.
- 3.3 Membership in Associations and Participation in Branch Meetings
Membership in associations and business associations is often useful, sometimes even essential. Nevertheless, this involves the risk of violating antitrust rules. Frequently, competitors of 595° Solutions are also represented there, so that market information can be exchanged under antitrust law. The same applies to participation at industry meetings.
Employees may only attend events that have legitimate purposes. Should there be an inadmissible exchange of information between other companies during an event, employees clearly have to dissociate themselves from this exchange of information by protesting, having their protest recorded and immediately leaving the relevant event.
- 3.4 Behaviour in Dominant Position
For certain product groups, 595° Solutions can be regarded as dominant from the point of view of antitrust law and in such a case is subject to special antitrust rules. In the case of a dominant position, the legal requirements, in particular antitrust law, must be adhered to.
A dominant company behaves anticompetitive especially if it misuses its market power. Such abuse may involve unequivocal unequal treatment of customers, refusal to supply or the granting of loyalty discounts.
- 4.0 Foreign Trade
In our international activities, we observe all the rules of foreign trade, tax and customs law of those countries in which we do business. Each employee must comply with these inspection requirements when purchasing, manufacturing or placing products on the market. Export controls generally apply not only to the supply of goods, but also to the provision of services or the transfer of technology.
All employees entrusted with the import and export of goods and other cross-border transactions must comply with applicable trade control laws. In accordance with the applicable regulations, it must always be ensured that any necessary regulatory approvals are obtained. Also, the war weapon control laws are to be kept.
- 5.0 Corruption Prevention
595° Solutions is committed to high ethical standards in business transactions. Unfair practices of employees and business partners will not be tolerated.
- 5.1 No Acceptance or granting unfavourable Advantages in Relation to Business Partners
No unfair advantages may be demanded, accepted, offered or granted.
Benefits or any kind of non-eligible benefits which objectively improve the economic, legal or personal situation of the beneficiary. This can include not only cash payments, but also any kind of gifts, invitations to events and other perks in the private sector. Benefits may also be considered as benefits paid to related parties, such as spouses, life partners, friends or relatives.
Unfairness is an advantage when taking into account all the circumstances and circumstances prevailing in the individual case, in particular the reason for accepting or granting an advantage and the personal status of the beneficiary, is not customary and appropriate. This is the case, for example, if an advantage is to influence business decisions.
The acceptance or granting of gifts or other comparable benefits is permitted provided that they do not exceed 15 euros and that they are not unfair advantages.
Acceptance or invitations to business meals or events are permitted provided they are reasonable, clearly business-related and are not unfair advantages.
In all cases of doubt, the Compliance Officer must always be involved immediately.
- 5.2 Carrying third Parties and Investment Decisions
When commissioning third parties (for example, consultants, brokers, sponsors, agents or other intermediaries) who work for 595° Solutions in business dealings, care must be taken to ensure that they do not display unfair business practices.
In particular, third parties may not be used by employees to circumvent the above-mentioned regulations.
- 5.3 Behaviour towards Suppliers
Suppliers are to be selected on the basis of objective considerations - such as prices, quality, performance. Relationships with them are based on trust and honesty. Offers are examined fairly and unbiased, personal and unobjective reasons are not taken into account in the decision-making.
- 6.0 Donations and Sponsor Activities
Donations and sponsorship activities must be transparent and comprehensible, they must not be abused for unlawful purposes. In particular, under the guise of donations and sponsorship activities, no unfair advantage may be conferred on third parties.
The allocation of substantial donations requires the approval of the management. A donation is essential in this sense, if the value limit of 5,000 euros is exceeded. Donations to individuals and to private accounts are generally prohibited.
In the case of sponsorship activities, the amount of the benefits must be commensurate with the advantages associated with the sponsoring activity, in particular the expected advertising impact.
- 7.0 Correct Reporting and Handling of Cash Payments
Any form of corporate communications intended for publication must be lawful and comply with international standards. In particular, annual reports must comply with the principles of proper accounting and financial reporting, so that data collection and other records are always complete, accurate, timely and systemic.
The acceptance of cash payments is prohibited. Significant cash payments require the approval of the management. A cash payment approval is essential, if the value limit of 15,000 euros is exceeded.
- 8.0 Confidentiality
Company and business secrets and all other confidential information that employees learn in the course of fulfilling their duties must be kept secret. Such information shall be protected in a suitable manner from the view of third parties and non-involved employees. This applies in particular to information about suppliers, customers, employees, business partners and other third parties as well as for internal company information. The obligation to maintain secrecy also applies after termination of the employment relationship.
- 9.0 Data Protection and Security
The protection of personal data and the right to informational self-determination are important concerns for 595° Solutions. The use of personal data in business dealings with privacy protection and the security of all business data. Personal data as well as all business data must be protected against unauthorised access by applying suitable technical measures.
- 10.0 Conflict of Interest
The business interests of 595° Solutions and private interests must be strictly separated. Situations in which private interests conflict with those of 595° Solutions should be avoided. Any conflicts of interest arising from the work of an employee in relation to a 595° Solutions company shall be communicated by the employee to the company via the respective supervisor or the compliance officer.
All transactions between 595° Solutions, on the one hand, and employees and related parties, on the other hand, must comply with industry-standard guidelines. Essential business requires the approval of the management. A business is essential therefore, if the value limit of 1,000 euros is exceeded.
Even decisions take by Personnel could create conflicts of interest. Decisions of this regard must ensure that they are not influenced by private interests or personal relationships.
No employee may pursue professional activities that run counter to the interests of 595° Solutions. This excludes an activity for a competitor of 595° Solutions.
- 11.0 Ownership and Company Organisations
All employees are responsible for the preservation and proper use of company property. 595° Solutions property may only be used for private purposes to a “certain extent” and may only be removed for professional purposes from the premises of the company.
- 12.0 Health, Work and Environmental Protection
595° Solutions sees it as a central task to model technical progress in harmony with the environment so to avoid hazards to people in their environment. This requires compliance with all applicable health, work and environmental protection requirements and compliance with all other internal health, safety and environmental protection guidelines.
- 13.0 Assistance for Employees
If any issues of interpretation or legal uncertainty exist in connection with the matters addressed in this Business Code and in the event of violations, employees may contact their supervisor or the Compliance Officer for clarification. Communications from employees will be kept confidential if requested by the employee.
- 14.0 Monitoring and Purposes of Infringements
In compliance with this Business Code, the management and executives of the 595° Solutions Group have a special responsibility. They have to adequately ensure that they are within their area of responsibility.
No violations of legal regulations, internal guidelines or this Business Code have occurred, which could have been prevented or made more difficult by the proper fulfilments of the supervisory and organisational duties.
Any violations are detected, tracked and remedied.
However, this does not relieve employees of their own responsibility. Every single employee must stand up for his personal behaviour.
Compliance with this business code is checked by regular audits.
595° Solutions reserves the right to take employment measures in case of violations of legal regulations, internal regulations or this Business Code.
- 15.0 Compliance Organisation and Compliance Manager
595° Solutions attaches great importance to an effective and transparent compliance organisation. For this purpose was Verena Beege appointed as Compliance Officer. Ms. Beege reports directly to senior management in all compliance matters and will report regularly on the compliance organisation and implementation practices of these policies. In all cases of doubt regarding this guideline, the Compliance Officer should seek advice from management.
Telefon: +49 911 9662-283