Code of conduct

For fair interaction with each other
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Respect and integrity

Human dignity, respect for personal rights and privacy are of utmost importance to us. We respect the different cultural, ethical and religious backgrounds and are committed to the principle of equality, regardless of age, disability, skin colour, sexual identity, gender and ideology.
We do not tolerate any discrimination on the basis of these characteristics, nor any sexual harassment or other personal attacks on individuals.
We make business decisions on the basis of factual and economic arguments and not for other, unobjective motives.
Information that supports or encourages racial hatred, the glorification of violence or other criminal offences, or has content that is sexually offensive against the respective cultural background, may not be distributed or accessed within our company.
Honesty and honesty in our conduct towards our business partners and our employees is a matter of course for us.

REPUTATION, LEADERSHIP, RESPONSIBILITY

The reputation of our company is of particular importance to us. Illegal actions or unfair practices damage this reputation. Every employee is requested to respect and promote the reputation of SHE Solution in Germany and every other country.
The management is responsible for ensuring that no violations of the law occur in the company that could have been prevented by appropriate supervision and organization. It is also ultimately responsible for the delegation of individual tasks.
The duties of the management include

  1. Selection of employees according to personal and professional qualifications and suitability, whereby the duty of care increases with the importance of the task that the employee is to perform.
  2. Instructions to employees are given in a precise, complete and binding manner, especially with regard to compliance with legal regulations
  3. Objectives are set clearly, ambitiously, realistically and communicated precisely. Continuous monitoring of compliance with legal requirements and internal guidelines
  4. A clear and unambiguous communication between the management and the employees.
  5. The promotion of the development of employees
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COMPETITION AND ANTITRUST LAW

It is one of the fundamental principles of SHE Solution that all employees act in accordance with the applicable competition law. Fair competition is a prerequisite for free market development for the benefit of the common good. Every employee is obliged to observe the rules of fair competition.
Assessments under antitrust law can be difficult due to different legal norms. We are therefore guided by the following principles:

  1. No agreements or concerted practices with competitors regarding prices, price increases, terms or capacity, including profit, profit margins, costs, sales and marketing methods, or other competitive factors that determine or influence our conduct, with the aim or effect of preventing, restricting or distorting competition.
  2. Not to enter into agreements with competitors to refrain from competition, to restrict business relationships with suppliers, to submit sham bids in response to requests for proposals, or to divide customers, markets, territories or product portfolios. 
  3. Not to influence the resale prices or other business conditions of our customers or to attempt to prevent the export or import of the products we trade.
  4. No improper exchange of competition-sensitive information with competitors.
  5. Not to engage in industrial espionage, bribery, theft or the dissemination of knowingly false information about our competitors, their products or services.
Principles
In our dealings with business partners such as customers, suppliers and service providers and in particular with government institutions and their representatives, we will strictly separate the interests of the company or institutions and the private interests of the persons acting.
When granting gifts and other benefits, even the mere impression that these benefits could be understood as consideration for a certain behavior desired by SHE Solution must be strictly avoided. In particular, if the benefit is to be granted in a certain time context with negotiations on essential contracts, it must be questioned particularly critically and, in case of doubt, omitted.
No employee may offer, promise or grant, directly or indirectly, unjustified advantages to public officials or persons in the private sector in connection with business activities, or offer, promise or allow such advantages to be offered, promised or granted, or approve such advantages.
When hiring consultants, brokers or other business partners, our employees must ensure that 

  1. these third parties are committed to fighting corruption and are committed to doing so, 
  2. they carefully examine the reputation of these third parties,
  3. and the contracts with these third parties are agreed upon in such a way that the interests of the SHE Solution are protected in the best possible way.

DONATIONS AND SPONSORING
The SHE Solution does not make donations to political parties, to individuals, to for-profit organizations or organizations whose objectives contradict the principles of our corporate governance or damage our reputation.
As a responsible member of society, the SHE Solution makes monetary and material donations for education and science, sports, art and culture, and for social and humanitarian projects. The type and amount of donations are decided according to objective criteria and are made within the scope of our economic possibilities.
All donations must be transparent, i.e. the identity of the recipient and the planned use of the donation are known, the reason and purpose of the donation are legally justifiable. Donation-like payments, i.e. payments which appear to be remuneration for a service but which clearly exceed the value of the actual service, violate the transparency requirement and are prohibited.
Sponsorship contracts that offer advertising opportunities to the SHE Solution as well as contributions to industry associations or membership fees to organizations that serve business interests are decided according to the above principles.
All sponsoring must be transparent and is only carried out on the basis of written contracts that are based on a serious business purpose. It must be in reasonable proportion to the equivalent value of what the organiser is offering.

SUPPLIER RELATIONS
SHE Solution is committed to ethical and legal corporate governance and expects the same from its suppliers. The following basic principles must be observed by our suppliers:

  1. Compliance with applicable laws
  2. Corruption waiver
  3. Respect for human rights
  4. Prohibition of child labour
  5. Ensuring the health and safety of employees
  6. Promotion of environmental protection
In order to exclude corruption in our company, SHE Solution has issued an internal guideline to combat corruption in business transactions, which must be observed by all employees of the company.
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Conflicts of interest

All employees are obliged to make their business decisions in the best interests of SHE Solution. Conflicts of interest always exist when an employee pursues his or her own interests at the expense of the company.
The employee must report conflicts of interest to the management immediately. An employee may not have private orders carried out by companies with which he/she has business dealings within the scope of his/her activities, if this results in an advantage for him/her, in particular in the form of unreasonably high discounts.

COMPETITION WITH SHE SOLUTION
Employees are prohibited from running a company or working for a company that is in competition with the SHE Solution, in particular they may not engage in any activities that compete with the SHE Solution.
Significant financial interests of an employee or a close family member of an employee in a competitor, customer or supplier must be reported to the company in writing if a potential conflict of interest is apparent. Material interest is defined as any direct or indirect interest of 5% or more in the capital.

SECONDARY ACTIVITIES
Secondary employment is the exercise of a further activity as a member of the board of directors, managing director, as a member of a supervisory, administrative or advisory board, as an employee or in any other function with an external company.
The exercise of a secondary activity by an employee at a competitor, customer or supplier is not permitted. Furthermore, it requires the prior written consent of SHE Solution.

OTHER CONFLICTS OF INTEREST
Transactions with an employee or his close family members in the name and on behalf of SHE Solution are generally prohibited. In individual cases, however, they may be approved by the management.
Purchase, rent or lease of land, buildings or other assets of the SHE Solution by an employee or a close family member of an employee require the approval of the management. Country-specific tax regulations must be strictly adhered to. This applies accordingly to the sale, rental or lease of land, buildings or other assets to SHE Solution by an employee or a close family member of an employee.
The granting of loans to and the assumption of guarantees or sureties for an employee or a close family member of an employee by the SHE Solution are only possible in exceptional cases and require the approval of the management.

CONFIDENTIALITY
Confidential business information and trade secrets may not be disclosed to third parties, either during or after termination of employment, unless the employee is specifically authorised to do so by virtue of his or her position within the company.
The direct or indirect use of confidential business information during or after termination of employment for the personal benefit of the employee or third parties or to the detriment of SHE Solution is strictly prohibited.
All employees are obliged to actively secure confidential data against access by third parties (defense against industrial espionage) in accordance with the applicable guidelines.
The right of informational self-determination of employees and business partners must always be respected. A conscientious handling of personal data is part of respect for the privacy of the individual.

REPORT INTEGRITY
All documents, such as financial reports, accounting records, sales reports, receipts of expenditure and environmental and safety reports, must accurately, clearly and timely reflect the relevant facts and the nature of the transaction. We will not tolerate violations of accounting rules, balance sheet irregularities or improper documentation.

IT SECURITY
IT systems are regularly used and data processed in everyday business. This requires appropriate security measures (passwords, approved technologies and licensed software) to ensure the protection of intellectual property and personal data.
Disregarding necessary security measures can have serious consequences, such as loss of data, theft of personal data or violation of copyright. Because digital information can be distributed rapidly, easily duplicated and is virtually indestructible, SHE Solution pays close attention to the content of e-mails, attachments, downloaded files and stored voice messages.

 

PRIVACY
Personal data is only collected, processed or used by us to the extent necessary for specified, clear and legitimate purposes. In addition, personal data is stored securely and may only be transferred if the necessary precautions are taken.
A high standard of data quality and technical protection against unauthorised access must be guaranteed. The use of data must be transparent for those concerned, and their rights to information and, where appropriate, to object, block and delete data must be respected.
In some legal systems, such as in the EU, strict laws and regulations apply with regard to the storage and use of personal employee data and the data of third parties, such as customers or business partners.

INSIDERINFORMATION
Persons who have inside information relating to the SHE Solution or any other company, e.g. a customer or supplier, whose securities are traded on a stock exchange or are admitted to trading on an organised market, may not trade in securities or other financial instruments of such companies whose price depends directly or indirectly on the securities of such companies. Recommendations to third parties to trade in such securities or financial instruments are also prohibited.
Insider information is specific information about circumstances not publicly known which directly or indirectly affects one or more issuers of financial instruments or one or more financial instruments and which, if it becomes publicly known, is likely to have a significant influence on the stock exchange or market price of the relevant security or financial instrument of the company concerned. Such suitability exists if a prudent investor would take the information into account when making an investment decision.
Within the scope of this Code of Conduct, we expressly prohibit the use of insider information for the personal benefit of employees or for the benefit of third parties and the disclosure of insider information to third parties.

EXTERNAL COMMUNICATION
Official statements, in particular to the media, are only made at the SHE Solution through the persons expressly authorized to do so. In order to ensure a uniform appearance and the integrity of communication, our employees are obliged to forward inquiries from media, analysts and the like immediately to the management of the SHE Solution.

Ecological sustainability, occupational safety, ban on child labour

We strive for the responsible use and procurement of natural resources in the production and distribution of our products and services. Therefore, we pay attention to a responsible, ecological use of energy, water, materials and land.
A healthy and safe working environment for our employees is a matter of course for us. We therefore comply with the laws and regulations on health and safety at work and actively review and improve safety standards.
It is the responsibility of management to ensure that appropriate procedures and protective measures are in place to ensure health and safety in the workplace.
The employment of children under the age of 15 is prohibited at SHE Solution.
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SHE Solution
Bergmann GmbH & Co. KG
Im Sundernkamp 2
32130 Enger
Germany
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