Along with the Group Strategy and Corporate Governance Principles, our Code of Conduct sets out rules for how our employees are to conduct themselves with integrity. It is reviewed both at regular intervals and if a concrete need arises and is approved by the Executive Board. The Code of Conduct is also accepted by our employees as part of their employment contract and hence has binding effect. It makes clear that active and passive bribery are not tolerated and further makes specific reference to the prohibition of money laundering and the prohibition of other criminal acts.
There are also specific rules of conduct, for example in the form of instructions for the avoidance and disclosure of conflicts of interest, for the granting and acceptance of benefits, gifts and invitations, for the arrangement of donations and sponsorships as well as with respect to sideline activities and involvement in other companies and business transactions. The Code of Conduct is thus intended to help our employees cope with challenges in their daily work. We consider integrity in dealings with our stakeholders to be the foundation of a successful enterprise. Both in our strategic planning and in day-to-day business, we therefore aspire to live up to the highest ethical and legal standards when it comes to the demeanour, actions and behaviour of every one of us.
As a listed company, we also emphasise to our employees the necessity of observing rules on insider trading and we specify blocking periods during which shares may not be traded. The consequences of non-compliance and the control mechanisms are explained during training activities.