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Legal Compliance Code

Legal Compliance Code for Employees of AuDaCon AG

Credibility and success of our company are directly related to the individual integrity and honesty of all our employees. Therefore all employees are obliged to act in a manner that no personal dependencies or commitments may arise. The managing board will not tolerate under no circumstances any corrupt practises.

An employee infringes these principles inter alia, in case he or she

- offers, promises or grants  a client, supplier, service provider or its personnel a benefit for a privileged placement of order or supply or approves such behaviour;

- vice versa demands, accepts a promise of or receives a benefit for himself or herself for the privileged placement of order or supply of a client, supplier service provider or its personnel;

- at the expense of the employer procures unjustified advantages for himself or herself or third persons.

Guiding Principles for Employees

1.    Handling of clients, suppliers, service providers inter alia

-      The company will not allow that an advantage for the benefit of the company is caused by bribery, fraud, economic espionage, theft, coercion inter alia.

-      Any attempts of clients, suppliers or service providers to manipulate employees in their decisions will not be tolerated; such attempts must be notified to the superior. Employees, who allow clients, suppliers or service providers to manipulate them dishonestly, will be – regardless of consequences under criminal law – called to account by disciplinary or employment law measures.

2.    Handling of gifts

- Gifts will not be accepted on principle.

-This applies for monetary and non-monetary gifts. Monetary gifts are sums in any form and currency. Non-monetary gifts are any articles of worth, which may not be regarded as giveaways. Travels, services, admission tickets for sports, music or other cultural events, bonuses and rebates shall be regarded as gifts.

- Giveaways shall be arranged in a manner that their acceptance does not bring the beneficiary into a compulsory dependency. They shall follow the principle to avoid any appearance of dishonesty of incorrectness of donor or beneficiary. In this connection a maximum of 5 EUR shall be implied. In case of doubt the decision of a superior shall be obtained.

-In case gifts may be accepted in accordance with the superior, such gifts will be gathered within the company and be raffled once in a year under all employees.

- Whether a gift may be kept personally on special occasions, will be decided in a case of doubt by the managing board, in case the managing board is involved in person, by the supervisory board.

- Consignments to private addresses are also subject to these principles, in particular the notification requirements.

Notification Requirements of Employees

The managing board is obliged to prohibit any form of corruption. The board expects that the employees respect their notification requirements regarding corrupt practices. Every employee bears joint responsibility, in case he or she is aware of corrupt practices and does not report.

Complying with these notification requirements shall do no harm to any employee. Therefore all notifications by employees shall be treated as strictly confidential.

Monitoring

Human experience shows that organizationalprinciples can only be successful, when they are accompanied by a correspondent monitoring. This will take place in the shape of adequate supervision and plausibility checks.

Enforcing Measures

In case of a violation of these compliance principles or statutory rules the necessary organizational, disciplinary and legal measures shall be taken to – regardless of consequences under criminal law – adequately counter the detected violations. This may – depending on the severity of the violation – even result in the loss of the job.