The SPITZKE Group

The SPITZKE code of conduct

Scope

The Code of Conduct applies to all companies in the SPITZKE Group. If national law contains stricter provisions than the basic principles defined here, national law takes priority. The Code of Conduct applies to all employees in the SPITZKE Group including the managing directors and members of the SPITZKE Management Board and all other managers. The managing directors, the members of SPITZKE's Management Board and all other managers also have a role model function with regard to compliance with the Code of Conduct. They are required to work towards ensuring its compliance within their area of responsibility.

Any existing rights of veto provided by the articles of association or procedural rules are not affected by the Code of Conduct.

Basic principle
The Code of Conduct applies to all employees in the SPITZKE Group. The management and managers have a particularly important responsibility with regard to their role model function and implementation of the standards of conduct within the Group. Breaches of this Code of Conduct and relevant corporate principles will not be tolerated; particularly high standards are set for our managers.
Integrity
Our employees undertake to comply with our underlying, deep-anchored corporate principles. In particular, they will note and comply with all valid laws and regulations. Our employees must not allow the integrity of the SPITZKE Group to be questioned or endangered.
Confidentiality
Our employees maintain confidentiality about any business transactions they acquire knowledge about or that are entrusted to them, not only during their employment but also after they have left the Group. They shall not use it either personally or in any dishonest way.
Image and reputation
SPITZKE attaches great importance to its image and reputation on the market, among its customers, competitors and business partners. SPITZKE's reputation is determined significantly by the conduct of its employees. Each employee is therefore obliged to consider the effects of their actions on SPITZKE's reputation.
Tolerance and respect
SPITZKE has set itself the goal of providing its employees with a working environment in which each employee can feel respected and valued. Therefore, all actions and conduct are banned that individuals or certain groups of people find humiliating, intimidating or threatening. SPITZKE expects all employees not to pass on or display any material that can cause offence. This includes, among other things, pieces of clothing that have a symbolic or denominational character or bear lettering that endangers the climate within the company.
Human rights and working conditions
SPITZKE respects recognised human rights and work standards.
Protection from harassment
SPITZKE protects its employees from physical punishment and from physical, sexual, psychological or verbal harassment or abuse.
Freedom of speech
SPITZKE grants and respects freedom of speech and freedom of expression.
Ban on child and forced labour
SPITZKE rejects any form of child or forced labour. The ban on child and forced labour is adhered to strictly.
Ban on discrimination
SPITZKE promotes equal opportunities and does not tolerate any discrimination of or by its employees.
Freedom of assembly
SPITZKE recognises its employees’ freedom of assembly and respects this right in the spirit of the liberal fundamental order.
Health and safety at work management
SPITZKE attaches the greatest importance to protecting the environment and the health of its employees and tries to provide its employees with a safe working environment at all times. The occupational safety and environmental management system implemented throughout the Group ensures compliance with legislation, regulations and standards. Every supervisor has the duty to instruct, support and supervise his fellow employees appropriately. Every employee must contribute to compliance with standards and legislation through his own conduct.
Data protection
SPITZKE adheres strictly to the legal data protection requirements. Personal data is only processed insofar as this is allowed within the scope of the relevant laws and corporate guidelines. All personal data is protected against unauthorised access. Infringements must be reported to the data protection officer immediately.
Responsibility to society
SPITZKE considers its responsibility to society not only to consist of high-quality maintenance and provision of safe and efficient as well as environmentally compatible rail infrastructure but also and in particular in the sustainable securing and creation of seasonally independent jobs. In addition, we support clubs, artists and local communities in the regions in which our branches are based. Furthermore, we consider personnel development not only to be a corporate task and responsibility but also in terms of social policy.
Sustainability
All our objectives are inherently aimed at achieving sustainability. As an owner-managed company we are interested in the long-term, growth-orientated organisation of the company. We do not make short-term decisions without concern for sustainability. We are interested in long-term cooperation based on trust, not only with our customers but also with our employees. We also expect sustainability from our services and work, which in a global economy subjected to increasingly rapid developments, should have long-term durability due to their high quality standard.
Protection of the company
Our employees fulfil the tasks assigned to them during their work conscientiously and to the best of their ability, safeguarding the interests of the company in every respect and dedicating all their working efforts to the company. In particular, they treat materials, tools, machines and other operating equipment with care.
Compliance
SPITZKE has a compliance system, which is used to ensure strict compliance with all legal standards, guidelines, directives and rules. Any breach against this Code of Conduct should be reported to the compliance team. This can also be done anonymously through the ombudsman.
Corruption
SPITZKE is actively committed to fighting corruption and unfair competition and considers this to be part of its responsibility to society.
Fair competition
SPITZKE acquires contracts and orders solely in fair competition. Price and quantity-fixing arrangements or sham offers are just as unworthy of consideration as false invoicing or billing and anti-competitive agreements with clients, suppliers and competitors. Contracts and orders are acquired neither by offering nor granting direct or indirect, unauthorised or unlawful benefits. We actively oppose corruption in any form whatsoever. Agreements and coordinated conduct, which cause or are intended at achieving the prevention or impairment of competition are prohibited. In the event of contacts with competitors, no information may be exchanged, which allows conclusions to be drawn regarding the current or future market behaviour of SPITZKE or its competitors.
Prevention of conflicts of interest
It is important to SPITZKE that its employees are not drawn into conflicts of interest in the performance of their work. Every employee is required to inform his supervisor without delay concerning a possible conflict between professional and private interests.
Invitations and gifts
Invitations and gifts may only be extended or accepted within the scope of the valid internal rules. The following rules always apply to the treatment of financial or other forms gifts and invitations:
The treatment of financial and other forms of gifts, and of invitations and other special favours is determined by the principles of fidelity to the law, responsibility and fairness. A general rule for fairness is that acceptance must not be concealed by the recipient and the recipient must not regard himself as coming under an obligation. Supervisors and colleagues can learn of any actions unconditionally. We do not tolerate any gray zones, but instead illuminate them through documentation and transparency. Giving or receiving bribes or kickbacks is not acceptable under any circumstances.
In concrete terms, financial and other forms of gifts to contract awarders should be understood to mean anything that the recipient obtains in connection with a business relationship for which fair market value is not paid. Such gifts are fair and permissible within the scope of general customer care and advertising for our Group. The opposite applies when they are deemed to constitute unlawful or unfair influence on the objective decision-making process and result in obligations or dependencies.
Gifts beyond the scope of token gifts of low value given to office-holders must be discussed with the competent person responsible for implementation from the compliance organisation or the CCO; the same applies to cases where doubt exists as to whether the recipient is an office holder.
The rules that apply for financial and other forms of gifts to our suppliers are the same as those that apply with respect to our contract awarders. Group employees are forbidden in all cases from accepting gifts that are connected directly or indirectly with their employment and that result in an obligation or dependency. We accept only courtesy gifts in line with common business practices that are of insignificant material or solely symbolic value.
Donations and sponsoring activities
Transparency of donation and sponsoring activities must be ensured. Donations must be made voluntarily and not be associated with a request for something in return, and they must comply with the valid laws and local regulations. Financial gifts and other benefits of monetary value bestowed on political parties, candidates or persons holding political offices can only be made on the basis of a decision by the management board. No unlawful gifts of a material or immaterial nature of any kind can be given.
Compliance with the Code of Conduct
Any breach of the above-named principles can result in criminal and liability proceedings as well as employment consequences.
Follow us
Facebook Xing LinkedIn Instagram
Contact

Legal Department
Katharina Schnoor
 

Phone+49 33701 901-127
Fax+49 33701 901-186
Emailrecht@spitzke.com

Google+