Code of Business Ethics - extract
"We are convinced that the conservation and safeguarding of our corporate culture is indispensable for our way into the future." (preface of the board of directors, excerpt)
KWS commits to the adherence of principles of business ethics and to the compliance of the international regulatory framework. For this purpose, the Code of Business Ethics was implemented, valid from July 1st, 2007. As to important special issues such as anti-trust law, insider law, anti-corruption regulations, signature regulations it will be supplemented by separate KWS guidelines.
The Code of Business Ethics and the KWS guidelines are valid without exception for all employees of the KWS group, the adherence will be audited regularly.
Protection of Confidential Information
Additional Responsibilties of Supervisiors and Managers
Principles
By the present Code of Business Ethics, the KWS group declares itself committed to comply with the laws. Integrity and ethical business conduct are the foundation of our business.
The Code of Business Ethics informs about responsibilities and key ethics issues.
All staff members of the KWS Group are obliged to comply with the Code of Business Ethics. KWS also expects its business partners to act ethically and in a manner consistent with this Code.
To follow the law at all times is of major importance for KWS staff. All KWS employees are obliged to follow the rules of the Code of Business Ethics every time.
All KWS employees have to raise compliance concerns by contacting
• supervisor, or
• Compliance Officer, or
• Compliance-Hotline
Follow the law at all times: Remember that any infringement may lead to substantial damages and is not in the interest of the company.
Understand the principles of the Code of Business Ethics and apply them in your job every day. Whenever you have questions about the application of this Code of Business Ethics, seek assistance from your supervisor, the Compliance Office, or other KWS resources.
Act loyal towards KWS - raise any Business Ethics concern you might have.
We commit ourselves to fair play in competition and to fairness in contracts with our business partners.
Anti-competitive conduct may seriously damage the company's assets as well as the company's reputation. Therefore, anything which could be taken as a sign of such misbehaviour has to be avoided.
Follow all relevant international trade control regulations, e. g. licensing, shipping documentation, duty requirements, import/ export documentation, and reporting and record retention requirements of all countries in which you conduct business.
Watch out for embargoes against countries as well as against Specially Designated Nationals. Watch out for sanction programs that prohibit any transaction with certain designated individuals and organizations, such as terrorist organizations or other criminals.
Understand which party to an international trade transaction is responsible for the accuracy of trade documentation and ensure that KWS has properly discharged its obligations in the transaction.
Anti-Corruption Regulations
The KWS staff members are obliged to respect the anti-corruption regulations in each country.
Never give, offer or authorize the offer of anything of value to employees or representatives of a customer, supplier or government official, to obtain any advantage.
Never give, offer or authorize the offer of a business courtesy (such as a gift, contribution or entertainment) in circumstances that would create an appearance of impropriety.
Keep insider information confidential.
Do not use insider information for purposes of buying or selling KWS shares, or for recommending third persons to do so.
Do not disclose confidential information to anyone outside the Company without the express written approval of the respective responsible head of department.
Disclose confidential information to other employees only for legitimate business purposes (need-to-know basis).
Handle all confidential information with care to avoid inadvertent or careless disclosure
Follow all company policies and directives relating to the environment and the health and safety of our customers and employees.
Avoid unsafe activities and conditions, including blocking fire exits, improper shelving of inventory and obstructing aisles.
Immediately report any suspected violations of environmental law or health and safety.
Violation of the Code of Business Ethics will lead to disciplinary action.
Any false report knowingly made, will also be subject to disciplinary action.
Additional Responsibilities of Supervisiors and Managers
Lead by example and train your employees to be ethical in all dealings and to avoid even the appearance of unethical conduct.
Never cover up or ignore a violation of the Code of Business Ethics; in doubt contact your superior or the Compliance Officer for assistance.
Encourage employees to raise compliance issues and ensure open communication in your department to ask questions concerning compliance matters.
