Our way of doing business is characterised by integrity

Preamble

All employees of OSTSEESTAAL GmbH & Co. KG are obliged to comply with the provisions of this Code of Conduct. It lays down the values, principles and procedures for the entrepreneurial and operational activities of OSTSEESTAAL GmbH & Co. KG. The aim of the management is to maintain ethical standards and create a working environment that ensures and develops integrity, respect and fair conduct. A business policy that complies with the law and principles serves the long-term interests of the company and its stakeholders such as customers, employees and suppliers.  This Code of Conduct was approved by the management of OSTSEESTAAL GmbH & Co. KG and approved by the shareholders.

Compliance with laws and other regulations at home and abroad

In all business decisions and actions OSTSEESTAAL GmbH & Co. KG must observe the applicable laws and other relevant regulations in Germany and abroad. Integrity and honesty shall ensure fair competition in the relationship with our customers and suppliers.

Commitment of management

The OSTSEESTAAL GmbH & Co. KG regards it as its unrestricted duty to act in an economically, socially and environmentally conscious manner. All employees of OSTSEESTAAL GmbH & Co. KG are therefore required to conduct their business competently and ethically and to protect fair competition in all markets in which we operate by complying with the applicable laws on prohibition of cartels, competition and other restrictions on competition. Unfair advantages vis-à-vis customers, suppliers or competitors must be avoided as a matter of principle.

Conflicts of interests

The OSTSEESTAAL GmbH & Co. KG expects loyalty to the company from its employees. All employees must avoid situations in which their personal or financial interests come into conflict with those of OSTSEESTAAL GmbH & Co. In particular, it is therefore forbidden to participate in the companies of competitors, suppliers or customers or to enter into business relationships with them in a private environment if this could lead to a conflict of interest. As such, conflict situations should not harm the interests of OSTSEESTAAL GmbH & Co. KG should not be affected. Such conflicts of interest can occur in many situations: For example, no employee may accept benefits - in whatever form - that can reasonably be expected to be used to influence business decisions or transactions of OSTSEESTAAL GmbH & Co. KG business decisions or transactions. Invitations must be within the bounds of normal business hospitality. Employees should not change their position at OSTSEESTAAL GmbH & Co. KG for their own benefit by direct or indirect access to confidential information. All employees are obliged to protect the legitimate interests of OSTSEESTAAL GmbH & Co. KG without restriction. Possible competitive situations with the company must be avoided. Any actual or potential conflict of interest must be reported and discussed with the responsible manager.

Prohibition of corruption

The OSTSEESTAAL GmbH & Co. KG does not tolerate corruption and bribery. Behaviour in which business is to be conducted using unfair means will not be accepted. The employees of OSTSEESTAAL GmbH & Co. KG may not offer or accept any unfair advantages from business partners if these could impair an objective and fair business decision. All employees are required to inform the management about any efforts by third parties.

Fair working conditions

All employees of OSTSEESTAAL GmbH & Co. KG are obliged to orient their actions towards a safe and healthy environment. All legal safety regulations and their adequate implementation in corresponding company rules must therefore be strictly adhered to. This also applies in principle to the observance of rules of third parties, insofar as the fulfilment of contracts and the provision of services makes this necessary. In these cases, the rules of third parties supplement the company's own rules. As a socially responsible employer, OSTSEE-STAAL GmbH & Co. KG regards its employees as very valuable and bears a high level of responsibility within the framework of its duty of care. It demands great commitment from its employees and in return shares the business success with them. The personnel policy of OSTSEESTAAL GmbH & Co. KG contributes to offering every employee the opportunity for professional and personal development. The open exchange of opinions, criticism and ideas is encouraged. The OSTSEESTAAL GmbH & Co. KG condemns illegal discrimination or harassment of any kind.

Handling of internal knowledge

All employees of OSTSEESTAAL GmbH & Co. KG are obliged to ensure a fast and smooth exchange of information within the company. The information must be passed on correctly and completely to the departments/employees designated for this purpose, especially in the case of overriding interests due to confidentiality obligations. Relevant knowledge may not be unlawfully withheld, falsified or selectively passed on.  Dishonest reporting within the company or to external organizations or persons is strictly prohibited. All annual financial statements and annual reports, business papers and books of OSTSEESTAAL GmbH & Co. KG must correctly reflect the business transactions and records and must comply with the statutory provisions and the applicable principles of internal accounting of OSTSEESTAAL GmbH & Co. KG. and its shareholders.

Dealing with assets

All employees of OSTSEESTAAL GmbH & Co. KG are responsible for the proper and careful handling of company property. Every employee is obliged to safeguard the property of OSTSEESTAAL GmbH & Co. KG from loss, damage, misuse, theft, embezzlement or destruction. This also applies in principle and without restriction to the property of third parties. Every employee is obliged to inform the management immediately of any use of assets to the contrary.

Confidentiality and data protection

A substantial part of the business information of OSTSEESTAAL GmbH & Co. KG is confidential or legally protected, so that a duty of confidentiality exists. This does not apply if the information has been obtained from OSTSEESTAAL GmbH & Co. KG or if it is mandatory to publish such information due to laws or regulations. The obligation to maintain secrecy applies in particular to intellectual property. This includes trade secrets, patents, trademarks and copyrights, but also business and marketing plans, drafts, business papers, salary data and all other unpublished financial data and reports. All personal information about employees, customers, business partners, suppliers and other third parties who are employed by OSTSEESTAAL GmbH & Co. KG is used carefully and treated confidentially in accordance with the data protection regulations. This also applies in principle to information from third parties if a confidentiality agreement has been concluded. The protection of this information is carried out with the utmost care.

Implementation and monitoring

The rules contained in this Code of Conduct are a central component of the corporate culture of OSTSEESTAAL GmbH & Co. KG. Compliance with these principles is indispensable. Every employee is responsible for this. If an employee has reservations or complaints regarding the points listed in this Code of Conduct or if he/she is aware of possible violations, he/she must immediately ask his/her superior for clarification. This can also be done anonymously or confidentially. If an employee is not satisfied with the clarification, he or she may submit the concern or complaint not only to his or her superior but also to the management. The OSTSEESTAAL GmbH & Co. KG does not permit reprisals based on complaints made in good faith within the framework of this Code of Conduct. The OSTSEESTAAL GmbH & Co. KG. will regularly update this Code of Conduct if this is necessary due to changed business circumstances or legislation.

Responsibility

All employees and members of the management of OSTSEESTAAL GmbH & Co. KG are obliged to observe the rules of this Code of Conduct. Violations of this Code of Conduct will lead to consequences.  In serious cases this can lead to the termination of the contractual relationship.

cited date: 04.2020