Code of Conduct
Guidelines for ethical and responsible behavior
1. IntroductionGraebener stands for the highest quality standards and binding values. Just as we do not compromise on the quality of our products, we also maintain the highest standards in our ethical conduct. Our actions are based on the applicable laws of the countries in which we operate. Therefore, all members of management, executives, and employees of Graebener (hereinafter referred to as "Employees") must comply with the laws that apply to them.
Our Code of Conduct is intended to supplement existing laws and provide guidance by explaining the ethical and legal framework for our business activities. It includes the basic principles for our conduct within the company, in our dealings with external business partners, and in public. The Code of Conduct does not prescribe specific conduct but serves as a guide. All executives are responsible for communicating the Code of Conduct to their Employees and ensuring compliance.
2. Respect und Inclusion
All Employees are expected to treat everyone with kindness and respect. This includes actively listening, acknowledging different perspectives, and engaging in constructive dialogue. At Graebener, we want to promote an inclusive environment where everyone feels welcome. Therefore, language and behaviors that exclude or disadvantage individuals based on their race, ethnicity, nationality, gender, sexual orientation, disability, age, religion, or other characteristics are strictly prohibited. In addition, any form of harassment, including but not limited to verbal abuse, threats, intimidation, inappropriate physical contact, unwelcome sexual attention, and discriminatory comments will not be tolerated. Violations of these principles will result in prompt and severe action.
Graebener Employees are encouraged to support each other and promote cooperation. Different opinions and experiences among colleagues should be valued, as working together often leads to better results.
3. Unrestricted Competition
Graebener is committed to free and unrestricted competition. All Employees are obligated to strictly comply with antitrust regulations and to contribute to maintaining the integrity and fairness of competition.
If an executive delegates a task to Employees, the executive's responsibility remains. Likewise, an executive's responsibility does not excuse Employees from their own responsibilities. Executives must ensure that no violations of law occur in their area of responsibility that could have been avoided by appropriate supervision. They must give clear instructions to their Employees and ensure that compliance with legal requirements is continuously monitored. For example, Employees may not discuss sensitive topics such as prices, production volumes, capacities, revenues, offers, profits, margins, costs, sales methods, or other competition-sensitive parameters with competing companies.
In addition, agreements with competing companies to refrain from competing, to limit business relationships with suppliers, to submit fictitious offers, to coordinate bids in competitive tenders, or to split customer groups, markets, territories, or production programs are strictly prohibited. Informal discussions or verbal "gentlemen's agreements" regarding competitive conduct are also not permitted. In addition to the provisions described herein, all Employees are bound by the confidentiality obligations contained in their employment contracts.
4. Anti-Corruption
Graebener requires all Employees and business partners to take unlimited and uncompromising action against any form of corruption. Violations of this obligation will not be tolerated and will result in disciplinary, contractual or legal action.
Offering or granting undue advantages (active corruption) as well as demanding or accepting such advantages (passive corruption) are strictly prohibited. If a violation is discovered, all Employees are expected to cooperate fully in order to promptly investigate and document the case of corruption.
5. Conflicts of Interest
All Employees are required to avoid conflicts between their personal interests and those of the company. Personal interests must be strictly separated from the company's interests to ensure that business decisions are never influenced by personal relationships or self-interest. Any potential conflict of interest must be reported immediately to the executive or through the whistleblower system (see Section 13).
Even the appearance of preferential treatment in business transactions with competitors, suppliers, service providers or other business partners due to personal relationships can harm Graebener and must therefore be avoided. Persons who are considered to have close personal relationships are in particular:
- Relatives of Employees;
- Persons who live in the same household as the Employees;
- Foundations for which Employees act as trustees and in which Employees or their spouses or children are involved as beneficiaries;
- Companies controlled by an Employee or by a person living in the same household as an Employee through investment, management, fiduciary relationship or otherwise.
Graebener is committed to fair working conditions and compliance with all relevant labor and employment laws. Discrimination, harassment or offensive behavior will not be tolerated. Health and safety are also fundamental components of the business practices. All Employees are required to observe health and safety precautions, to comply with relevant regulations, rules and work instructions, and to wear appropriate protective equipment where required by law.
Graebener is fully committed to internationally recognized human rights and strictly rejects any form of child labor. Graebener's business partners are expected to make the same commitment to ensure that child labor is not tolerated at any stage of the value chain.
7. Environmental Protection
Graebener complies with all applicable environmental laws, standards and regulations and pursues proactive, long-term environmental strategies to prevent environmental damage and continuously improve its environmental performance. Graebener recognizes the importance of environmental protection and product safety - not only for the company's reputation, but also for the safety of customers and future generations. Graebener therefore ensures that environmental standards are met and environmentally harmful practices are avoided, especially when selecting suppliers.
8. Confidentiality
Confidential information about the company must always be protected. All documents and information relating to internal matters must be kept strictly confidential. This confidential information includes all non-public strategic, financial, technical, and business data of the company and our business partners. It is not permitted to discuss current or future events, projects, technical details, or other confidential information with third parties or to allow third parties access to such information.
All Employees should be aware that confidentiality can also be breached unintentionally. Therefore, special caution is required, especially in public transportation such as trains, buses, and airplanes. All external persons who are given access to confidential information must sign a non-disclosure agreement in advance.
9. Privacy and IT Security
The handling of personal data is subject to specific data protection legislation. The collection, storage, processing, and use of personal data generally requires the consent of the person concerned or a legal basis. Graebener implements technical and organizational measures to protect the personal data of its Employees, customers, business partners and other third parties from manipulation, loss, destruction, and unauthorized access.
Employees who use IT systems must pay particular attention to data confidentiality. All documents and (electronic) data carriers must be stored securely, especially if they contain sensitive data on Employees or confidential information. Computers must be password-protected and screen-locked to prevent unauthorized access when leaving the workstation. Copies or duplicates of data may only be made for business purposes and must be stored securely. Access to information that is not related to one's own responsibilities at Graebener is not permitted. The confidentiality of postal correspondence and telecommunications must be ensured at all times.
10. Documentation
All business transactions must be fully, accurately, truthfully, and promptly documented. All Employees must ensure the accuracy and reliability of the company's records, accounts, and reports in accordance with established procedures, principles of proper accounting and appropriate accounting systems, controls and audits. This obligation to provide truthful documentation also applies to travel and expense reports.
11. Company Property and Intellectual Property Rights
Employees entrusted with company property are responsible for its careful use, protection, and management, whether material or immaterial. This includes intellectual property that results from Graebener's daily efforts to provide innovative solutions of the highest quality to its business partners. Such ideas can be protected through official registrations with authorities such as the Patent Office. If necessary, these ideas must also be protected as confidential trade secrets. Reproduction, publication, or use of this intellectual property without the consent of Graebener's management is not permitted and may be illegal. The intellectual property of third parties must also be respected. Any use of third-party rights requires a valid license agreement.
Expenses and financing should be handled with due diligence. All Employees are required to avoid damage, unnecessary costs, and other disadvantages, and not to misuse or abuse any company property.
12. Compliance with Import and Export Laws
Graebener operates globally and must comply with a variety of import and export laws. Import laws require the accurate declaration of all imported goods and the payment of appropriate duties and taxes. Export laws may restrict the use, (re-)export, release or transfer of goods, technologies, software, and similar products. Therefore, applicable export control and trade regulations must be observed in all processes of affected departments.
13. Reporting Violations
Circumstances that indicate a violation of law, the Code of Conduct or other internal policies must be reported immediately. Employees may report such incidents through the Whistleblower System (hinweis@graebener.com). Each report will be thoroughly investigated, ensuring that only those members of the legal department and management who are necessary to process the report and who are not personally involved will have access to the information. All information and documents received are kept confidential within the limits of the law. Retaliation against Employees who make a report in good faith will not be tolerated. However, the intentional making of false allegations will be considered a violation of the Code of Conduct.