The following Code of Conduct regulates the behaviour of the employees of Noventiz GmbH, Noventiz Dual GmbH, Noventiz Digital GmbH and Noventiz GEE GmbH, hereinafter collectively referred to as Noventiz, towards each other, all business partners and the public.
All actions are based on the Basic Law, as well as the laws and regulations of the Federal Republic of Germany, EU directives that are directly applicable, international regulations such as sanctions that the Federal Republic of Germany has undertaken to implement, and any agreements that Noventiz has concluded with its contractual partners. This applies to all employees and bodies of Noventiz.
The basic ethical principles of Noventiz include integrity, credibility, transparency and the pursuit of excellence in all areas.
Noventiz provides services only and is therefore not affected by the German Supply Chain Act. However, Noventiz expects its business partners to be committed to the same or similar principles and to promote their implementation through their daily actions, as Noventiz does.
Noventiz respects the rules of fair competition and does not enter into any unlawful agreements. The same applies to participation in public and private tenders.
Noventiz takes a firm stance against giving bribes and avoids any impression that its business decisions could be influenced by corruption. Employees are not permitted to take advantage of their employer’s business relationships for their own benefit or for the benefit of their family or friends.
If an employee becomes aware of a matter that raises a suspicion of corruption or economic crime, he or she must seek advice or assistance in assessing the situation. The first point of contact is the line manager or, alternatively, the compliance officer. Employees can also make anonymous reports if they wish to remain anonymous.
Invitations to business meals or events that are consistent with normal business practices as established by case law may be accepted as long as they do not constitute improper preferential treatment – the same applies to gifts.
It is prohibited to pay any kind of bribe, even indirectly, to public officials or representatives of government institutions, regardless of the amount. It is not permitted to use consultants, agents or other intermediaries to circumvent this prohibition.
Contributions to political organisations, representatives or candidates may only be made in consultation with the management and in accordance with the applicable laws.
Donations must be transparent, voluntary, and must not be tied to the expectation of a quid pro quo.
In case of doubt, employees must first seek the advice of the management.
Noventiz does not tolerate any money laundering and instructs employees to comply fully with anti-money laundering laws. They are required to report suspicious payment methods and other transactions to the management or the compliance officer.
Honest, accurate and clear reporting and communication within Noventiz and to the public is of key importance. Noventiz documents its business activities and reports them to the competent authorities as required by law. All tax and customs declarations are made truthfully. Taxes and other fiscal charges are properly declared and paid. The legal requirements for export controls, as far as they apply to Noventiz, are complied with. Noventiz expects its business partners to support the achievement of these objectives through appropriate conduct.
In order to avoid conflicts of loyalty, all employees are required to report to their supervisor in case of any conflicts of personal or financial interest with Noventiz or its business partners. Employees may not manage, work for or have significant influence over a company that is a direct competitor of the Noventiz Group.
Buying, selling or recommending the buying or selling of assets on the basis of inside information is prohibited. Noventiz treats inside information as strictly confidential and does not pass it on to third parties. Inside information may only be disclosed to employees or consultants on a need-to-know basis, and is always subject to strict confidentiality. This obligation continues for three years after termination of employment.
In addition, data protection regulations, in particular data confidentiality and the GDPR must be complied with. Handling personal data, including – but not limited to – processing, storage, disclosure or publication, is prohibited unless it relates to a specific business task. This obligation shall survive the termination of employment with Noventiz.
- Principles of responsibility
Noventiz is aware of its social and ecological responsibilities. Noventiz respects human rights, opposes any form of forced or child labour, does not tolerate any discrimination and promotes equal opportunities for all employees. Workers’ rights are respected, as are occupational health and safety.
Treating the environment and resources responsibly is a key aspect of Noventiz’s corporate identity. All employees and the management should base their actions on this premise. The management lives by these values and sets an example for all employees.
Noventiz introduces this Code to its employees and makes it available to its business partners. Noventiz will take all necessary measures to implement the principles defined in this Code of Conduct. Noventiz undertakes to regularly review the effectiveness of this Code of Conduct and to make changes if necessary.
Employees who believe that changes to the Code are conducive to improving cooperation within Noventiz and between Noventiz and its business partners are encouraged to make suggestions – anonymously if desired – in accordance with the process described in Section II above.
If employees become aware of a violation of this Code of Conduct, they should report their observations to a compliance officer or to the management. Such a report may be made anonymously, if preferred. Reports will be treated confidentially, and, if the observations are based on misinterpretations, will not have a negative impact on the reporting employee – unless it is a false accusation based on intent or gross negligence.
Violations of this Code of Conduct and, in particular, of the legal principles contained therein, may result in sanctions under labour, liability or even criminal law.
The content of the Code will be reviewed regularly to ensure that it always remains up to date.
Cologne, 16 June 2023