ETHICAL BUSINESS CODE OF CONDUCT AT PLEUGER INDUSTRIES GMBH

Preamble

All employees are bound by the provisions of this Code of Conduct. It sets out the values, principles and actions that determine Pleuger Industries GmbH’s entrepreneurial actions. The goal Pleuger’s management is to comply with ethical standards and to establish a working atmosphere that encourages integrity, respect and fair behavior. A strictly law and principle-abiding business policy serves the company’s long-term interests.

This code of conduct has been adopted by the management of Pleuger Industries GmbH and approved by the owner.

Compliance with laws and other regulations at home and abroad

In all business decisions and actions, Pleuger Industries GmbH endeavors to observe the applicable laws and other relevant regulations at home and abroad. Integrity and honesty promote fair competition, also in relation to our customers and suppliers.

Company Management Commitment

Pleuger Industries GmbH sees itself obliged to act economically, socially and environmentally consciously. Pleuger Industries GmbH therefore strives to conduct its business in a competent and ethical manner and to protect fair competition in all markets in which it works by complying with applicable laws on prohibitions of cartels, competition and restrictions of competition. Unfair advantages, rival customers, suppliers or competitors are to be avoided.

Conflicts of Interest

Pleuger Industries GmbH expects its employees to be loyal to the company.

All employees must avoid situations in which their personal or financial interests’ conflict with those of Pleuger Industries GmbH. Therefore, engaging with competitors, vendors or clients or entering into company interactions with them in a personal setting is particularly forbidden if this could result in a conflict of interest. Conflict circumstances must not affect the interests of Pleuger Industries GmbH. 
Such conflicts of interest can arise in many situations: For example, no employee may accept benefits - in any form whatsoever – that can be presumed from a reasonable point of view to influence business decisions or transactions of Pleuger Industries GmbH. Invitations must stay within ordinary company hospitality boundaries. Employees should not achieve direct and/or indirect benefits by accessing confidential data because of their role at Pleuger Industries GmbH. It is the responsibility of all employees to promote as far as possible the legitimate interests of Pleuger Industries GmbH. Any competitive situation with the company must be avoided.

Any actual or potential conflict of interest must be reported and discussed with the relevant superiors.

Prohibition of corruption

Pleuger Industries GmbH is against corruption and bribery. We will not tolerate behavior in which unfair means are used to conduct business. Pleuger Industries GmbH's employees must not offer, receive or accept any benefits from business partners that might impair an objective and fair business decision or even create such an appearance.

Fair working conditions

All Pleuger Industries GmbH employees are responsible for ensuring a secure and healthy environment. Therefore, safety regulations and procedures must be strictly observed.
As a socially responsible employer, Pleuger Industries GmbH regards its employees as a great asset. It demands great commitment from its employees and in return, shares its business success with them. 
The personnel policy of Pleuger Industries GmbH's helps to give every employee the chance to develop both professionally and personally. Open exchange of opinions, criticism and ideas are encouraged.
Pleuger Industries GmbH condemns illegal discrimination or harassment of any kind.

Dealing with internal knowledge

All Pleuger Industries GmbH employees are required to guarantee rapid and exchange of information within the company. Information shall be transmitted properly and fully to the proper areas, unless priority interests occur in outstanding cases, in specific due to confidentiality commitments. Relevant knowledge may not be illegally withheld, falsified or transmitted selectively.

Dishonest reporting within the company or to external organizations or persons is strictly prohibited. All financial statements and annual reports, business papers and accounts of Pleuger Industries GmbH must present business transactions and books accurately and comply with the legal requirements as well as the accounting principles and internal accounting procedures of Pleuger Industries GmbH.

Dealing with assets

All Pleuger Industries GmbH employees are responsible for the proper and cautious handling of the assets of the company. Each worker is required to safeguard Pleuger Industries GmbH's assets from loss, harm, misuse, theft, misuse or destruction. Each worker has the obligation to immediately inform his superior of any use of assets contrary to the above.

Confidentiality and data protection

Much of Pleuger Industries GmbH's business information is confidential or legally protected, so a secrecy requirement exists. This does not apply if Pleuger Industries GmbH has authorized a publication of the information or is mandatory due to laws or regulations. 

Particularly, the duty of confidentiality refers to intellectual property. This includes trade secrets, patents, trademarks and copyrights, but also business and marketing plans, drafts, business papers, salary information, and all other unpublished financial data and reports. 

Pleuger Industries GmbH uses and treats all personal information about employees, clients, business partners and suppliers as well as other third parties in complete accordance with data protection laws. This data must be protected with the utmost care.

Implementation and monitoring

The rules contained in this Code of Conduct are a key component of Pleuger Industries GmbH’s corporate culture. Uniform adherence to these values is essential. Every employee is responsible for this.
If an employee has concerns or complaints about the points listed in this Code of Conduct or is aware of any breach of the Code of Conduct contained therein, we encourage him to report immediately for clarification to his superior or the department of HR. This can also be done anonymously or in a confidential manner.  If an employee is not satisfied with the result of the clarification, the concern or complaint may be submitted not only to the supervisor, but also to the management board or the works council. Pleuger Industries GmbH does not allow reprisals under this Code of Conduct for complaints made in good faith.

Responsibility

All employees of Pleuger Industries GmbH are bound by the rules of this code of conduct. Violations of this Code of Conduct have consequences. This can result in the termination of the employment relationship in severe cases.