Code
of
conduct

Code of Conduct

G BRANDED Code of Conduct

Corporate Governance: Principles of corporate management.

It is an integral element of organizational culture at G BRANDED to not only orientate our activities towards statutory regulations but also to take a committed approach in pursuing ethical standards. We treat our employees with respect and hold the environment in high esteem. Our employees are bound by the Codex standards as outlined below, intended to help them adhere to our rules, while proactively promoting our values.

The code described below is binding on each employee and is designed to help you abide by our rules and values.

If you have any questions or are unsure how to conduct yourself in specific cases, please feel free to contact your superior or us by email. Raphael Geisreiter, Managing Director

PRINCIPLES

Principles underpinning responsible and proper conduct

1. Adherence to the law

Law-abiding conduct takes the highest priority in our company. We comply with the law of the countries in which we are active. Unlawful activities are not an option, nor are they in the interest of our company – because it is both unethical and gravely detrimental to our reputation, and may entail prosecution, damage compensation and loss of orders. Employees who act unlawfully need to be aware that they themselves will face prosecution. Law-abiding conduct serves to protect our own workforce. Every employee is obliged to learn about the regulations applicable in their sphere of responsibility and comply with these. In cases of doubt, please consult your superior for clarification.

2. Bribery, corruption, gifts, donations

Bribery and corruption are unlawful and unethical. Both are associated with a high degree of risk for our employees and our company. Bribery and corruption represent an existential threat to our company and are not therefore an option. They are thus prohibited and we are prepared to accept loss of sales in upholding our values against this. We do not offer our business partners impermissible advantages, nor do we accept such in return. We regard corruption activities as the involvement of third parties/intermediaries, payment of bribes, kick-back payments and incentive donations, amongst other such things. We are restrained in giving and receiving gifts and other donations (such as invitations to meals or events). These should never be formulated in such way that their acceptance extends beyond the boundaries of the hospitality, manners and politeness customary in business.

3. Taxes and subsidies

The tax laws of each country are binding for us and must therefore be strictly followed. Each employee must be aware that tax offences entail prosecution; for both the company as well as for individual employees. The risk of being discovered in the event of tax offences is high owing to regular and meticulous audits by the tax authorities. Suspicious facts will quickly lead to the involvement of prosecuting authorities. If customers and suppliers are involved, control disclosures will be sent to the responsible tax authorities and vice versa.

4. Upholding fair competition

Competition can only function if it is free and fair. Concerted practices impede competition. We do not therefore restrict competition through collusion with our competitors. We abide by the laws for the protection of competition. Prohibitions are, in particular, the prior agreement of prices and conditions, the division of markets and regions, the allocation of customers and the coordinated collusion of offer, development or production strategies. Even the exchange of information with competitors, which may form the basis for concerted conduct (in particular regarding prices, costs, margins, conditions, customers, offers, product developments, manufacturing capacities), is impermissible. Violations against these prohibitions shall be pursued strictly by antitrust authorities and can lead to sanctions endangering the company’s existence.

5. International trade

G BRANDED benefits from cross-border trade to a great extent. It is in our own interest to safeguard this and follow its rules. We therefore observe existing import and export regulations, obtain requisite approvals and pay stipulated customs duties and taxes. We of course also pay attention to any economic sanctions that are in place, including import and export prohibitions. Compliance with these provisions is subject to regular inspections by the authorities. Violations shall entail considerable sanctions.

6. Property rights of third parties.

We treat our own property and that of other companies responsibly. We respect the integrity of our business partners. We protect and uphold intellectual property. Concepts, ideas and designs are also property and therefore protected by law. We respect the intellectual property of third parties and treat business secrets with due care. It must be ensured that confidential information does not fall into the hands of third parties. This also applies to confidential information that we receive from our business partners. If particular confidentiality is called for owing to special circumstances (e.g. sensitive development projects of customers or corporate purchases), we shall also uphold these requirements of our colleagues.

7. Data privacy

We use personal data of our employees and contractual partners only for purposes for which this data was provided and treat it confidentially. The laws enacted to protect personal data are followed unreservedly by G BRANDED.

8. Documentation of business transactions

Internal and external reports must be correct and complete so that the recipient is informed appropriately. In so doing, we ensure that the facts are presented in an objective manner. Documents that were required for ongoing or anticipated internal enquiries or official investigations must not be destroyed, removed or changed. We protect people and the environment.

9. Product safety

We attach the utmost importance to the quality and safety of our products and services. We monitor the quality of our products in the market and support customers in avoiding hazards.

10. Occupational safety

We ensure a safe working environment. Safety regulations must be strictly complied with and examined in regard to their effectiveness. Misunderstandings must be brought to light and remedied.

11. Environmental protection and conservation of resources

We are economical in our use of natural resources and strive towards economy for our products too. This applies in particular to water, whose quality is of special concern to us. The same applies to air purity and the responsible handling of chemicals. We avoid harmful effects on the environment. Compliance with the laws for protection of the environment is a matter of course for us.

12. Avoiding conflicts of interests

We separate business and private interests. Ancillary activities require prior consent from G BRANDED. This concerns, in particular, ancillary activities for competitors, customers or suppliers of G BRANDED or financial participations. If close family members are involved in such activities or participations, this must be indicated. Nor do we utilise our work at G BRANDED to gain private advantages. The commissioning of business partners for private purposes is to be avoided. Business partners may not be favoured out of private interest.

13. Respecting other cultures and views.

We are part of a global society. It is therefore a matter of course for us to respect other cultures and moral concepts. We treat everyone fairly, with respect and openness. We reject discrimination. Our views in the company are politically neutral.

14. Communication

Official statements on behalf of G BRANDED may only be made by authorised persons. Statements concerning the company shall be discussed and agreed with Management before publication. This code of conduct is binding for all employees of G BRANDED. It may be substantiated and supplemented by regulations specific to topics and countries or training measures. Our managers have particular responsibility. They are called upon to act in an exemplary manner in upholding the rules and values of G BRANDED described in this code. They represent the first point of contact for questions by employees regarding correct conduct. It is their task to ensure compliance with the code in their area of responsibility. Questions about the code or correct conduct in individual cases will gladly be answered by the relevant superior or Management at any time. Violations against this code shall not be tolerated and can result in loss of employment and/or consequences under criminal law.

Contact Person:

Raphael Geisreiter, Managing Director G BRANDED raphael.geisreiter@gbranded.com

Last Update

01.06.2020

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