Code of Conduct
We embody our value system by setting out codes of conduct. They apply to all of our employees worldwide, both internally and externally. We treat each other with respect, treat our business partners fairly, continuously develop ourselves, and ensure that we use resources carefully. Of course, we comply with legal requirements everywhere. With our expertise and awareness, we are continuing our history as a leading manufacturer of system solutions for cabling and connection technology.
Customer-focused. Family-oriented. Innovative. Success-oriented. These are the values upon which LAPP is built. Our clear values have made us strong as a company, and as a family business, we know that it is only through our joint efforts – through teamwork within our company and with our business partners – that we will be successful. And the basis for this is our values. If we align our behaviour with these values every day, if we treat each other and our business partners fairly and with respect, we will perpetuate LAPP's success story as a leading manufacturer of system solutions for cabling and connection technology. In this Code of Conduct, we try to describe more precisely what our values mean for our day-to-day work. We hope that this will be of help to you.
Board of Lapp Holding SE
Preamble
1. Lawful conduct
We advocate the principle of legality in all acts, measures, contracts, and other transactions of LAPP. We endorse the principle of acting solely within the confines of the law, regardless of whether LAPP derives any benefit from this. All our employees are personally responsible for adhering to the law within their own field of work.
It is forbidden to induce third parties to act unlawfully or knowingly to contribute to any such unlawful acts. Acting in contravention of the law is not in the company’s interest and may result in prosecution, damages, or lost orders.
2. Avoiding conflicts of interest
Business and private interests should always be strictly separated. A conflict of interest may occur if employees take measures or have personal interests that could collide with their work for LAPP. In this event, harm can only be prevented through open communication and full transparency. If there is any uncertainty as to whether a given situation might create a conflict of interest, it should be discussed with the employee’s superior.
a. Secondary activities
Secondary activities are only permissible with the prior written consent of the company. Consent will be granted if there is no risk of any negative impact on work performance. Employees will only be permitted to invest in or carry out secondary activities for competing firms, suppliers or customers if they have prior written approval from the respective local subsidiary. Decisions will be taken on a case-by-case basis.
b. Business relationships
Transactions with companies, in which an employee, their spouse or partner, or close family member holds an interest or serves in a senior position, and where the employee is able to influence the business relationship and a conflict of interest could occur, may only be entered into with the prior written consent of the respective local subsidiary.
c. Engaging business partners for private purposes
Employees may only engage a business partner of LAPP for private purposes with the prior written consent of the respective local subsidiary if their work entails direct involvement in the awarding or settlement of orders, and there is consequently a potential for a conflict of interest. This provision does not apply to goods and services that are generally available.
3. Dealing with information
Information and the processing of information are key elements and critical to the success of each and every business activity. When dealing with information, particular attention should be paid to precision and accuracy, the relevant degree of confidentiality, and data protection.
a. Reporting
All our records, reports and statements must be accurate and truthful. The generally accepted accounting principles should be adhered to. The creation of records, files and the like, for which confidential information belonging to the company is used, is permitted only if this directly serves the interests of LAPP and all data protection standards are complied with.
b. Confidentiality
Confidential information belonging to the company must be kept secret.
c. Data protection and information security
Data protection cannot be delegated and is ultimately the responsibility of the relevant management team. Our focus here is particularly on complying with the principles of legality, purpose limitation, data avoidance and minimisation, and transparency. We aim to process data accurately, in good faith, and to limit its storage, while ensuring the integrity and confidentiality of data. We hold ourselves properly accountable for this, for upholding the rights of data subjects, and for all other provisions of respective data protection legislation.
When developing and processing all (IT-supported) business processes, the right to privacy and to a private life must be protected and information security guaranteed, on the basis of and in compliance with the applicable statutory requirements regarding data protection and IT and data security. If, in connection with business processes, personal data (pertaining to customers, suppliers, employees or other affected persons) is collected, processed and/or transmitted, LAPP will observe the European data protection regulations within the EU (European Union) and the EEA (European Economic Area).
4. Conduct toward business partners and third parties
When dealing with business partners (customers, suppliers, service providers, etc.) and state officials, a clear line must be drawn between the usual scope of a business relationship and private interests. Business relations with our business partners are defined by ethical conduct. LAPP observes the rules of fair competition and supports all efforts to enforce a free market and open competition, both nationally and internationally. LAPP will therefore not pursue any contract that can only be acquired by violating the relevant laws.
a. Agreements, cartels, and waivers of competition
All employees have a duty to observe the rules of fair competition as defined by applicable law. In particular, it is not permitted to demarcate sales areas or divide up customers with a competitor, nor may there be any agreements or exchanges of information with competitors concerning prices/price components, supply relations and the conditions governing them, production capacities, or bidding approaches. The same applies to the exchange of information concerning market strategies and investment strategies. This prohibition applies not only to written agreements, but also to oral agreements or tacit collusion (conscious parallel behaviour).
b. Selection of business partners
Agreements with customers, suppliers, and service providers must be concluded solely in the interests of the company. All employees must comply with the company's internal control regulations (e.g. dual control). Suppliers must be selected solely on competitive merit, based on a comparison of the price, quality, performance and suitability of the products or services offered. In addition, we also expect our business partners to comply with the principles of this policy.
c. Bribery, corruption and other inducements
LAPP does not tolerate any form of corruption, bribery or other unlawful granting of benefits. Any attempts by suppliers or customers to exert an unfair influence on the decisions of LAPP employees must be reported to the managers responsible. An extremely restrictive approach must be taken with regard to accepting or offering gifts or invitations from/to business partners. The financial scope of these gifts or benefits must be assessed on the basis that it should not be necessary for the recipient to conceal their acceptance, and they should not make the recipient feel indebted. In case of doubt, approval should be obtained from the relevant superior.
Invitations from business partners to events of a generally social nature (e.g. sporting or cultural events) are permissible if they are in line with normal business practice, have no unreasonably high value, and are also proportionate to the normal standard of living of the people involved. If any doubt exists as to the appropriateness of gifts, donations, or invitations, the employee’s superior or the Compliance division should be consulted in advance.
d. Donations and sponsorship
LAPP companies make monetary donations and donations in kind in the fields of education, science, culture and social concerns. When making donations, LAPP takes care to ensure that the donation is transparent, i.e. its use and recipients are clearly traceable. Donations to individual people and payments to private accounts are not permitted.
LAPP's aim, when undertaking sponsorship activities, is to fulfil a social responsibility and promote the image of the company and its name recognition. Sponsorships are therefore transactions involving an exchange of benefits. In this respect, care should always be taken to ensure that the benefits given and received are always in proportion to each other.
Both donations and sponsorship activities must be approved by the local management team.
e. Behaviour in public
This also applies in particular to communications on social networks and on the internet.
All employees must pay due regard to the reputation of LAPP when performing their duties.
5. Quality, occupational safety, environmental protection and sustainability
"Success through quality" is one of the guiding principles of our business policy. In addition to complying with the statutory requirements, we make active efforts to constantly increase our contribution to the protection of the environment and to prevent our employees from being exposed to risks.
a. Quality
To meet the high standards of quality and safety that our customers expect of us, we invariably make any necessary improvements on a consistent, thorough, and long-term basis. If complaints arise despite our best efforts, we take action to remedy them in compliance with statutory provisions and contractual obligations, and with the clear priority of preventing injury or loss of life.
b. Occupational health and safety
It is the duty of all employees to avoid hazards to people and to the environment, and to use resources sparingly. Processes, sites and operating materials must comply with the applicable legal and internal requirements regarding occupational safety as well as the provisions on health and environmental protection and the prevention of fire. Health, safety at work, and decent working conditions are an important element of company policy.
The use of substances that are harmful to health in our products and production plants should be avoided.
c. Environmental protection and sustainability
We comply with the applicable environmental regulations and try to keep our impact on the environment as low as possible. We additionally endeavour to manage our business in a way that is sustainable and environmentally friendly, and to deal responsibly with all natural resources.
We also avoid using raw materials from conflict areas (conflict minerals). We aspire to reduce our negative impact on the environment to the amount that is technically and organisationally unavoidable. We also attach great importance to our suppliers, subcontractors, and other third parties complying with the environmental legislations when working for us.
6. Compliance as a management task, reporting irregularities and monitoring
This Code of Conduct is a central component of the LAPP values that we work by. It is vital that these values are observed uniformly throughout the Group – each employee is responsible for ensuring this.
a. Compliance as a management task
All LAPP managers must make certain that this Code of Conduct is observed within their area of responsibility and are responsible for ensuring that no breaches of the Code of Conduct or any statutory regulations – that could have been prevented or impeded through adequate supervision – occur within their area of responsibility. Managers are also obliged to inform employees of this Code of Conduct and its contents, and to familiarise them with it. They must additionally make it clear that breaches of the law are frowned upon and will have disciplinary consequences, regardless of the employee’s position in the company hierarchy.
Managers must always act as role models in this respect, and must act in accordance with the principles of acceptance, appreciation, and trust.
b. Reporting irregularities
All employees have the right to draw their managers' attention to circumstances appearing to indicate a breach of this Code of Conduct. This can also be done anonymously. Reports will be investigated and corrective measures taken where necessary.
c. Monitoring
Each company of LAPP is responsible for ensuring that the rules contained within this Code of Conduct as well as any other internal regulations within its area of responsibility are complied with. The Internal Audit department has an unrestricted right to obtain information and carry out audits, unless statutory regulations oppose this. When carrying out their audits, the Internal Audit department pays attention to compliance with the Code of Conduct and includes its regulations in its test criteria.