We act with integrity and respectability.

It is decisive for the success of our company that all of us – directors, managers and employees – conduct ourselves in a sincere, respectable and ethically correct way. This means we report and communicate in a truthful, comprehensive and timely manner, inside and outside the company.

We base our operations and decisions as a company on the generally accepted ethical values and compliance with applicable law, as well as integrity, sincerity and respect of human dignity.

Responsible governance and conduct is one of our minimum standards and we strive to develop our company values over the long term. We value resource conservation and protecting the environment and climate, as well as respect for human rights, equality and fair working conditions. We are dedicated to fighting discrimination and corruption.

We are proud of the diversity that our employees bring to our company. Together, we want to use the different perspectives that this diversity in gender, culture and religion brings, helping us to strengthen innovation and performance.

This Code of Conduct provides basic rules that must be observed by everybody in the company. Management in particular is tasked with its active implementation. Managers must act as role models and be committed to socially responsible and ecological corporate governance.

We also expect our suppliers to comply with our guiding values, and encourage them to do the same in their supply chains.

We will develop or adapt our Code of Conduct further as necessary.

Compliance with laws, regulations, rules and standards

In all business decisions, we are obliged to comply with the legal system we operate in.

All laws and regulations affecting our business areas must be complied with. This also applies to relevant laws and regulations of other countries when we do business there. In this context, we would like to focus on compliance with the following principles in particular.

We want to live in a society where diversity is valued and experienced positively by everyone, and where people are represented equally. We embrace diversity, actively advocate inclusion and create an environment that promotes everybody’s individuality in the interest of our company.

In our organisation, we attach great importance to diversity in identities, backgrounds and perspectives. We are proud of the diversity that our employees bring to our company. Together, we want to use it to strengthen innovation and performance. We guarantee the political, economic and social equality of women, and actively promote their empowerment so they can participate fully in economic life across all business areas in our company.

As a company, we are responsible for guaranteeing fair working conditions. We are committed to implementing these through treating our colleagues, employees, potential future employees, suppliers, customers and all other people with whom we do business in a fair and respectful way.

Discrimination for whatever reason is not permitted in our organisation. Everybody has the right to express their own opinion and to being treated respectfully. We have a policy of open dialogue that is characterised by tolerance and respect. This policy must be followed at all business levels and in all communication between and among management and employees. We provide fair working conditions and a comfortable working environment to all our employees. We acknowledge and respect the freedom of association as anchored in the German Basic Law (Grundgesetz).

Therefore, all employees have the right to freedom of association and the representation of their interests through elected representatives.

Working hours and remuneration

Our company complies with the legal provisions concerning maximum working hours, rest periods and annual leave. In the exceptional case of overtime work, the extra time will be remunerated separately or compensated by free time.

Environmental protection, sustainability, decarbonisation, air quality
and noise protection

We are convinced that sustainable management is the key to long-term success. Environmental law provides us with binding standards and we comply with all regulations and standards on environmental protection. When rendering our services, we follow an environmentally friendly and sustainable approach that includes the conservation, recycling and reuse of resources. By optimising our processes, we constantly strive to reduce energy consumption, air pollution and the consumption of other raw materials. We also work to reduce the emission of greenhouse gases.

By 2050, we plan to become a carbon-neutral company, in line with the goals of the European Green Deal. We increasingly use environmentally friendly and non-toxic products, use renewable energy sources and avoid unnecessary waste. We are working to reduce noise and ensure that noise emissions do not exceed the legally permissible levels.

Water and chemicals

We observe measures for protecting bodies of water and the groundwater and keeping them clean. In our daily work, we use as little water as possible and ensure no pollutants are released into bodies of water or the groundwater. In addition, we comply with the prescribed precautions when handling chemicals.

Even though chemicals do not usually play a role in our daily work, we will ensure to prevent potential spills, escapes or overflows of any chemicals under our responsibility. In the unlikely event of an incident, however, we will contact a competent authority, for example the fire department.

Biodiversity, land use, deforestation and animal welfare

Biodiversity describes a functioning and balanced environment. It is the result of the variety of the ecosystems, genetic diversity and the variety of animals, plants, fungi and micro-organisms. All our activities are in line with the protection of natural ecosystems, and focus on the preservation of forests by identifying and managing natural forests and other natural ecosystems.

This also includes the responsible use of the near-natural areas on our premises in terms of land use and deforestation, maintaining soil quality, and maintaining and protecting the diversity of species and animals. We observe the rules and regulations of animal welfare.

In our company, all relevant fire protection measures are in place and up to date, and we are committed to compliance with them. Ensuring that all employees and others in the company are adequately protected in the event of a fire is particularly important.

Honourable business conduct, fair competition and prevention of plagiarism

Honourable business conduct is a matter of course for us. We treat all our customers, suppliers, sales and business partners in a faithful and fair way, and refrain from any unfair activities that may harm competitors. The regulations of competition law are compulsory.

We only use lawful methods and processes when developing our products and services. This eliminates unauthorised counterfeiting and prevents the introduction of plagiarisms and counterfeit materials into deliverable products and services.

Anti-trust law

In the same way as we comply with the rules on unfair competition, we also observe the applicable anti-trust law. We are fully aware of the fact that violations of anti-trust law can render contracts ineffective and may lead to criminal convictions.

Ban of bribery, corruption and money laundering

Corruption is an international problem leading to enormous economic damage. Corruption poses a risk to fair competition, as it is not normally the best suppliers who receive contracts. As a responsible company, we take a clear stand on combating corruption. We expect the same of our business partners.

We do not tolerate any kind of bribery, corruption and/or blackmail. Moreover, we keep company and private interests strictly separated. Therefore, business relations and contacts must neither be used for personal nor any third party’s benefit. Furthermore, we do not support any business operations serving the purpose of money laundering.

Protection of information and data

It is the responsibility of every employee to protect proprietary knowledge and confidential information, such as business and financial data, marketing strategies and trade secrets. When collecting, storing, processing and transferring data belonging to employees, customers or third parties, we take utmost care and maintain strict confidentiality.

Business data and information may only be processed for the agreed business purpose and stored in the IT systems specifically intended for this purpose. The same applies to the collection, storage and processing of any personal data under the applicable data protection law.

In no way do we allow our private interests and personal considerations to influence our judgment when it comes to acting in the best interest of our company. Therefore, we avoid any activities or situations that could lead to a conflict between our personal and business interests. The management is responsible for installing procedures capable of identifying and regulating conflicts of interest. All members of staff are encouraged to identify and report potential conflicts of interest so that they can be resolved appropriately.

Export control and economic sanctions

We comply with all provisions concerning the import and export of goods, services and information.

Reporting violations and whistle-blower system

By signing this Code of Conduct, the management commits itself to comply with the principles set out in it, and to clearly communicate and enforce them inside and outside the company.

All employees are encouraged to embrace the Code of Conduct of the company, and to report concerns in good faith, confidentially and without fear of retaliation. We will not tolerate any form of retaliation, discrimination or disciplinary measures against anybody who has addressed in good faith reasonable concerns regarding an attempted or assumed misconduct or violation of any of the provisions of this Code of Conduct. Raised concerns and reported violations will be treated confidentially.

Violations can be reported using the installed whistle-blower system. There are three different channels to choose from:

• Call our whistle-blower hotline (www.lock-line.de)
• Contact our Compliance Ombudsman Uwe Schmidt
  Email: compliance-ombudsmann@fdtech.de
  Phone: +49 (0) 3731-7740800
• Send an email to our central Compliance Mailbox
  Email: compliance@fdtech.de

Our Compliance Manager is Karsten Schulze