Guidelines for ethical business conduct

Philipp Eckelmann

+49 611 7103-0



Code of Conduct Eckelmann Group

All employees of the Eckelmann Group and all Group companies, hereinafter referred to as the Eckelmann Group, as well as the members of the Executive Board of the Eckelmann Group are bound by the provisions of this Code of Conduct. It sets out the values, principles and courses of action that determine the business practices of the Eckelmann Group. The objective of the company's management is compliance with ethical standards, the protection and preservation of the environment for future generations, the careful use of resources and the creation of a working environment that promotes integrity and fair conduct. This is also in line with our corporate values of respect, fairness, trust and sustainability. A strict business policy that complies with the law and remains true to the principles serves the long-term interests of the company.

Conduct in the business environment

Compliance with laws and rights

The Eckelmann Group is obligated to observe the applicable laws and other relevant regulations at home and abroad in all business decisions and actions. Each employee1 is personally responsible for compliance with the law in his area of responsibility. The Eckelmann Group always acts conscientiously with regard to the economy, society and the environment. Therefore, the Eckelmann Group endeavours at all times to protect fair competition in all markets in which it operates by complying with applicable laws on cartel prohibitions, competition and restrictions of competition. Unfair advantages to customers, suppliers or competitors must be avoided. Integrity and honesty promote fair competition, also in relation to our customers and suppliers.

1 The generic collective terms mentioned, including employees, always include all genders.

Avoiding conflicts of interest

The Eckelmann Group expects loyalty to the company from its employees.
All employees must avoid situations in which their personal or financial interests are in conflict with those of the Eckelmann Group. They are therefore particularly prohibited from acquiring participating interests in competitors, suppliers or customers, or entering into business relationships with them in a private capacity, insofar as this may result in a conflict of interest. Conflict situations must not compromise the interests of the Eckelmann Group.

Such conflicts of interest could arise in many situations: For example, no employee is allowed to accept benefits2 – in any form whatsoever – that could reasonably be expected to influence business decisions or transactions of the Eckelmann Group. Invitations must remain within the limits of normal business hospitality. Employees should not use their position in the Eckelmann Group to gain direct or indirect advantages for themselves by accessing confidential information. All employees are obligated to promote the legitimate interests of the Eckelmann Group to the greatest extent possible. Competitive situations with the company must be avoided.

Any actual or potential conflict of interest must be reported immediately before it arises, or at the latest when it exists, and discussed with the relevant supervisors.

2 Example: gifts and invitations. The acceptance of money is always prohibited.

Prohibition ofThe Eckelmann Group is against corruption and bribery. Conduct where business takes place with unfair means will not be tolerated Employees of Eckelmann Group may not offer business partners any privileges or receive or accept any such privi

The Eckelmann Group is opposed to corruption and bribery. Negotiations in which transactions are made using illicit means will not be tolerated. Employees of Eckelmann Group may not offer business partners any favours, or receive or accept the same from them, which could lead to a compromise of an objective and fair business decision or even give the appearance of such compromise.

In case of doubt, the anti-corruption officer of the company is to be consulted.

Conduct in foreign trade and transactions

The Eckelmann Group complies with all of the export control and customs regulations that are applicable in the countries where it does business. The company has set up a comprehensive, electronically supported export control system for this purpose and made its use mandatory. In order to comply with this undertaking, all employees involved in the import and export of goods, services, technology (including technical data) or software (programs, licence keys) are required to comply with applicable economic sanctions, export control and import laws and regulations, as well as all regulatory frameworks and processes related to their business activities.

Every employee is required to inform the person responsible for exports in the company in the case of suspicion that a possible business relationship or delivery contradicts this intention.

Conduct within the society

Sustainable protection of the environment

The Eckelmann Group is aware of the scarcity of resources and the responsibility to future generations.

Protecting our environment and preserving it for future generations as well as the careful use of resources are - among others - equally important and decisive corporate objectives. The following are important for us:

  • We attach importance to compliance with regulations (e.g. Federal Immission Control Act, Closed Substance Cycle and Waste Management Act, Water Resources Act), continue to develop, improve and have voluntarily participated in the flexible environmental consulting programme ÖKOPROFIT of the state capital Wiesbaden for several years.
  • By carefully using resources, we save costs and reduce the burden on the environment. In doing so, we carefully comply with all legal regulations.
  • We see environmental responsibility towards our customers as very important and support them with high-quality technical and ecologically sensible solutions.
  • We inform, motivate and encourage our employees in the environmentally conscious and economic use of resources.
  • We expect active support from our suppliers in the search for resource-saving solutions.
  • We continuously collect and evaluate data about emissions, waste, as well as raw material and energy consumption.
  • Our responsibility for the environment does not end with the production and sale of our products. Wherever we can still obtain the components and repair is reasonably possible, we offer to repair defective components, regardless of the age of the components. Likewise, we take back components at the end of their life cycle (WEEE reg. no. DE 12052799).

Handling assets

All employees of the Eckelmann Group are responsible for the proper, considerate and careful handling of company property as well as that provided by third parties. Each employee is obligated to protect these against loss, damage, misuse, theft, embezzlement or destruction. Every employee is obligated to inform his/her supervisor immediately about any use of assets contrary to the above.

Donations, sponsoring and charity

The Eckelmann Group is an active member of society and is involved in various ways. We make donations of money and goods in the following areas: charity, science and research, education, sport and culture. Donations and sponsoring activities are only authorised within the framework of a transparent approval process. No financial contributions are made to political parties at home or abroad, to organisations affiliated with or similar to political parties, to individual elected representatives or to candidates for political office.

Conduct regarding employees and colleagues

Fair working conditions

All employees of the Eckelmann Group as well as employees of subcontractors working on behalf of the Eckelmann Group must ensure a safe and healthy environment. By strictly complying with safety regulations and practices, the Eckelmann Group endeavours to completely eliminate occupational accidents.

As a socially responsible employer, the Eckelmann Group considers its employees to be of great value. The shared success is based on their high degree of commitment. The human resources policy of the Eckelmann Group contributes by offering every employee the opportunity of professional and personal development. The free exchange of opinions, criticism and ideas is encouraged. The Eckelmann Group complies with human rights principles within its sphere of influence and expressly condemns all forms of child and forced labour.

The Eckelmann Group rejects unlawful discrimination, harassment, disadvantages, disparagement or preferential treatment of employees or business partners on the basis of their ethnic origin, gender, age, sexual identity and orientation, religion, political opinion, disability or ideology.

If in doubt, please consult the Equal Opportunities Officer.



Handling of information and the protection of company property

Handling internal knowledge

All employees of the Eckelmann Group are obligated to ensure a fast and smooth exchange of information within the company, taking into account the principle "We work for each other". Information must be properly and completely passed on to the departments concerned, unless there are priority interests, particularly due to confidentiality obligations in exceptional cases. Relevant knowledge must not be unlawfully withheld, falsified or selectively passed on.

Before handing over sensitive data / knowledge to service partners and vicarious agents, this must be secured by contractual regulations.

Confidentiality and data protection

A major part of the business information of the Eckelmann Group is confidential or legally protected so that there is an obligation to maintain confidentiality. This does not apply if a publication of the information has been authorised by the Eckelmann Group or is mandatory based on laws or regulations.

The confidentiality obligation particularly relates to intellectual property. This includes business secrets, patents, brands and copyrights as well as business and marketing plans, drafts, business papers, payroll data and all other unpublished financial data and reports.

All personal information about employees, customers, business partners and suppliers as well as other third parties will be used with care in the Eckelmann Group and treated as confidential, subject to full compliance with the data protection laws. The protection of this information must be implemented with the greatest care.


The rules contained in this Code of Conduct form a core part of the corporate culture of the Eckelmann Group. Uniform compliance with these principles is indispensable and expected by the Eckelmann Group. Every employee is responsible for this.

If an employee has concerns or complaints about any of the items listed in this Code of Conduct, or has knowledge of any possible breach of these, he/she should immediately report them to his/her supervisor for clarification. This can also be done anonymously or in a confidential manner.

If an employee is not satisfied with the resolution, he/she may also submit the concern or complaint anonymously or in person to a manager he/she trusts, the HR department, the Executive Board or one of the authorised representatives.

The Eckelmann Group does not permit reprisals based on complaints or other motives raised in good faith in the context of this Code of Conduct.