Code of Conduct

Acting responsibly, in an ethically correct and lawful manner is just as important to the success of BARTEC as our innovative force, technical performance, quality standards and customer orientation. The reputation which we have established with a great deal of dedication in relation to our customers, shareholders, business partners and in public can easily be damaged by individual legal violations.

Our common objective is to further strengthen BARTEC’s position as number 1 in the field of industrial safety technology. For that reason all of us are required to behave in a responsible manner and to act in accordance with the law. This Code of Conduct defines the ethical and legal framework within which we act. It sets out the fundamental principles of our conduct within the BARTEC Group and in our relations with business partners and the public. It presents the principles of our corporate actions and is an expression of our corporate values.

Acting responsibly means acting lawfully just as much as it means acting ethically. These principles of conduct constitute the binding benchmark for the actions of all staff. Our principles of conduct do not relieve anyone from their personal responsibility. However, we ask all employees to request advice and help when faced with decisions on ethical or legal issues or if they become aware of forms of conduct in their work environment they consider difficult or concerning. Only transactions that meet this standard are BARTEC business transactions. The Compliance Office acts as the bridge between law, conscience and culture.

Our Code of Conduct serves as guidelines for conduct that complies with and exemplifies the corporate culture of the BARTEC Group. It is based on safety, integrity, respect and sustainability. Above all, the binding principles of conduct serve to protect our employees, managers and the organisations behind them. In everyday business the Code of Conduct is designed to help find the correct and appropriate answers to the ethical and legal questions that arise during strategic considerations and decision-making processes. All members of staff are called upon to apply the principles of conduct every day at the BARTEC Group.

Working with customers, suppliers and business partners
Our business relations with customers, suppliers and business partners are determined by ethical conduct. We conduct our business in a manner that is open, honest and ethically responsible. Our action is always characterised by fairness, good faith and integrity. We say what we mean and do what we say. We expect the same from all employees and from everyone we do business with.
No conflicts of interest
We maintain no relations with customers, suppliers or competitors that might influence our decisions on behalf of BARTEC. Actual or potential conflicts of interest must be avoided.
Our employees avoid conflicts between their private interests and those of the company. We do not allow our decisions to be swayed by private interests or personal relationships. Business relationships are based on objective criteria such as price, quality or the existence of fair cooperation arising from past collaboration. Business relations from which purely personal material or other benefits may be derived shall not influence the signing of a contract or the continuation or termination of a business relationship. BARTEC welcomes any voluntary work by its employees as long as it is compatible with their obligations towards BARTEC in accordance with their employment contract.
When expressing a private opinion in public, employees may not create the impression that this represents the position of the Company. If an employee faces an actual or potential conflict of interest, he must promptly notify his line manager and/or the Compliance Office so that the conflict can be jointly resolved.
No dependencies
We take our decisions freely and independently, without allowing the development of dependencies. We do not accept preferential treatment by suppliers, service providers or customers. Material or moral dependencies must not play any part in our dealings with business partners.
We reject any kind of “you scratch my back and I’ll scratch yours” business policy. We only accept invitations from business partners to events or business dinners when these have a demonstrable business purpose. The invitation must be proportionate to this business partner, and must not go beyond common hospitality.
Gifts from business partners must be within legal limits and be appropriate in terms of type and extent. Invitations from business partners to events of a predominantly private character are permitted in approved exceptional cases if the principal costs of the event are borne by BARTEC or by the employee himself.
Fair competition
We are committed to fairness in competition. Only with fair competition the market can develop freely. Every employee of the BARTEC Group is obliged to be aware of and to comply with the rules of fair competition.
Wherever BARTEC operates, the Company adheres to antitrust and trade laws, laws on pricing, competition and consumer protection. During their business activities with customers, suppliers and competitors, employees of the BARTEC Group must at all times act within the limits permitted by law. This means they may neither engage in price fixing, nor come to secret agreements about production, supply or the sharing of markets. Employees of the BARTEC Group may not participate in unfair trading practices.
We do not tolerate illegal agreements with competitors. Even the appearance of improper agreements with other market participants must be avoided. If in doubt, the Compliance Office must be consulted.
No corruption or bribery
We are committed to integrity in our business and social activities. Decisions about business dealings with our business partners are based exclusively on facts that can be objectively evaluated, such as quality, price and performance. They will not be promoted by gifts, donations, bribery or corruption. The principles of honesty and integrity must be complied with in all business and social activities and at all times.
Relationship management is part of business success. It is conducted neither in legal grey areas nor using inadmissible means. Employees of BARTEC do not accept bribery directly or indirectly, nor do they make any such offers themselves. Bribery in business transactions and towards public officials is a criminal offence. When dealing with government offices or authorities, no payments or benefits are promised or granted in order to influence the decisions made by public servants or other office holders in favour of BARTEC.
We do not make any gifts for the purpose of inappropriately influencing our position in the market. We do not accept any gifts intended to influence the awarding of contracts. Gifts or benefits which may influence business decisions are impermissible and must neither be offered, granted, requested, nor accepted. This also applies if they might merely create the appearance of impropriety, and, in particular, to the initiation of contracts and the conclusion of business deals.
As a responsible member of society, the BARTEC Group makes donations of money and donations in kind for educational, cultural, social and sports purposes. Donations must always be transparent. The recipient of the donation and the purpose must be known and clear.
Donations to individuals, organisations operating for profit and organisations pursuing a purpose without tax privileges, as well as donations to private accounts and donations that damage the reputation of the BARTEC Group are prohibited.
Political donations are precluded; this applies equally to individuals, parties or other political organisations.
The BARTEC Group can make contributions in the form of money or in kind to an event organised by a third party. Where the provided services are connected to counter-performance in the form of advertising or customer loyalty measures, this is referred to as sponsorship. Sponsorship requires a written agreement, a serious business purpose, an appropriate ratio between benefit and equivalent value and complete transparency.
The executive management of the BARTEC Group makes all decisions about donations and sponsorships that go beyond local and temporary activities or minor donations.
No violation of market limitations
We respect all national and international customs legislation as well as exports, antiterrorism, and embargoes.
All employees are obliged to adhere to the limitations of and bans on export and domestic trading with specific goods, services or technologies. The trade bans and restrictions relating to international embargoes and the international fight against terrorism, which may also affect capital and payment transactions, must be strictly observed. National (German) and European export control provisions determine our actions.
If doubts persist about whether the use or distribution of our products is permissible, a decision must be made by the Compliance Office together with the executive management.
Guaranteeing product safety and product quality

All employees are fundamentally responsible for ensuring that customers have confidence in the safety and quality of our products. The safety of products and/or processes is our number one priority. We select our suppliers according to the safety of their products and compliance with quality standards.

We have developed professional product safety guidelines and programmes that are based on solid scientific principles, practical operating procedures, the latest technologies, employee training and customer information.

The products we sell not only meet statutory requirements and industrial standards/guidelines, but usually exceed them. Every employee is responsible for product safety. Our aim is to meet the expectations of our customers at all times.

Protection of company assets
The material and intellectual property of the BARTEC Group must be protected from loss, theft and misuse. The value of our company is based on the ideas and the inventiveness of the people who actively promote the success of the BARTEC Group and have done so in the past. Successful knowledge management has continued to pass on this added value from generation to generation. Inventions, patents, names and other expertise are extremely valuable in this respect, as are our trademarks. We protect these intangible assets, as they are of considerable economic significance to the future of our enterprise.
We undertake to respect the material and intellectual property of third parties and reject illegal ways of acquiring information. Company secrets include all information which is not publicly accessible and which is very important to the BARTEC Group or its competitors, as well as any information which only the company possesses.
Non-disclosure
We take great care to protect confidential information. Company secrets and knowledge about future developments must not be passed to third parties, let alone be published, without legal safeguards. Confidential information includes documents, facts, data and knowledge concerning profit figures, new products, ideas for research and development, business or marketing strategies, customer insider information, personnel matters, investments and holdings, manufacturing processes and internal guidelines and procedures. No employee may misuse the intellectual property of the BARTEC Group for his own purposes. All employees are called upon to protect data against unauthorised access by third parties and to avoid opportunities for third parties to access business documents. IT security, data security, and data protection are top priorities for us.
Property and equipment of the Company
We respect the property and equipment of the Company and treat them with care. The financial assets and funds of the BARTEC Group may not be used for unlawful purposes.

Production areas, laboratories, offices and workstations must always be kept clean and tidy. We use the equipment made available to us by the Company, e.g. telephones, company cars and computers, in accordance with the local guidelines of the BARTEC Group.
Computers provided to employees by the Company, as well as the data stored on computers, are the property of the BARTEC Group. The inappropriate use of computers is not permitted. Personal use should be proportionate and kept to a minimum.

Reliable communication
Transparent, prompt, and reliable internal as well as external communication is an important part of our corporate culture. The misinformation of employees and colleagues, the public, the market and our customers is not acceptable to us.
Customers should receive access to the information needed to make a sensible business decision in a suitable manner. This may be by means of general written product information or through sales representatives, for example. BARTEC takes customer complaints very seriously and processes them promptly and fairly.
All information that is provided to the public is truthful. We aspire to faultless quality. Improper, ambiguous, incomplete, or ill-considered statements may be misinterpreted, misused, or taken out of context, thereby causing us considerable damage. For this reason communication via email and new media must also be conducted correctly.
As a matter of principle, information may only be provided to the public by authorised members of staff. Anybody who appears in public as a representative of BARTEC without authorisation acts as a private individual.
The Compliance Office must be consulted immediately in the case of enquiries by investigating authorities.
Transparent accounting
Important business processes are appropriately documented in the accounts. The systems deployed ensure that accounting information concerning business transactions is completely and correctly recorded. Keeping records and files that are complete, clear and understandable is therefore a matter of course for us. Records and files must be kept in such a way that auditors and financial authorities are able to follow the system used and the contents at any time. Our processes are transparent and structured such that they can always be continued by other employees. Legal or internal obligations to retain records must be met. Documents which relate to procedures of authorities or courts of law may not be destroyed. Any documentation must be formally correct and be consistent in terms of content so that it may also be shown to third parties when required.
Equality
We undertake to treat one another with respect. Our employees are the foundation of BARTEC’s success. To ensure that their strengths can fully develop, we create a work environment which encourages appreciation and promotes integrity.

We tolerate neither discrimination nor harassment. Performance and conduct in the spirit of teamwork are important to us, irrespective of age, origin, gender, or ethnic group. We judge the result of an individual’s work objectively, regardless of political commitment, religion, physical constitution or sexual identity. For this reason we do not tolerate defamation, intimidation, threats or assigning blame to others. Fairness, respect, team spirit, and forthrightness define our cooperation with line managers, colleagues and other employees. These principles also apply to our conduct towards external partners. We respect and promote employee rights and pursue a relationship with employees in a spirit of partnership aimed at finding solutions. We specifically promote cooperation between different divisions and countries. The decisive criteria for selecting and promoting our employees are performance, the ability to develop and the personal qualifications of each individual. We are committed to a culture of learning where objective feedback is desired and appreciated by all involved but where personal attacks are rejected.

No drugs and alcohol at work
We behave professionally and appropriately at all times. Our work requires clear thinking and often the ability to react quickly; the safety of fellow employees and consumers depends on this. Alcohol, drugs and taking excessive amounts of medication limit the performance of an employee. We follow strict workplace guidelines for smokers and for alcohol and drugs use.
Health and safety
The BARTEC Group encourages safety, health-conscious conduct to protect the lives and health of its employees, to safeguard its assets, to guarantee business continuity and to build public trust. All companies in the BARTEC Group undertake actions to provide a safe and productive work environment for their staff. Safety is particularly important in production areas, which therefore have their own safety regulations. Safety rules have been conceived for each workplace, and these must be followed. The companies in the BARTEC Group comply with all valid laws concerning health and safety; frequently they satisfy even more stringent criteria than those prescribed by law.
Human rights
We respect the principles of the Universal Declaration of Human Rights. We strongly condemn forced labour, child labour and all practices in which people are exploited or exposed to dangerous conditions.

We comply strictly with laws regulating the minimum age for employment and other employment conditions. The minimum age for employment at the BARTEC Group corresponds to the Convention of the International Labour Organisation and/or the age prescribed under local law if this is greater.

Environmentally friendly business practices
We are committed to sustainable entrepreneurship. We comply with laws and regulations governing environmental protection. We are committed to improving our environmental performance by supporting the transfer of expertise, best practice and technology. We go to great lengths to minimise the impact of our business activities on the environment. We achieve this objective through the economical use of energy and water resources, careful use of consumables in everyday working life, the monitoring of air pollution, limiting the use of packaging and by generating the minimum amount of waste.
Contribution to sustainable economic and social development
In addition to the parties in our supply chain, the focus of our social responsibilities is on all aspects affected by our business activities. Through interaction with the various parties (suppliers, customers, consumers, employees and the community) we ensure that the social activities of the BARTEC Group effectively support improvements (under consideration of local conditions) and are beneficial to both the enterprise and to the community. We compile data on environmental impact and performance, determine monitoring principles and regularly check the progress made. We expect our suppliers to systematically improve the social, environmental and ethical quality of their products and production, and support them in these endeavours.
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