CODE OF CONDUCT. Engineering the Future since MAN Group

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1 CODE OF CONDUCT Engineering the Future since MAN Group

2 Please read this Code of Conduct thoroughly. It will support you in your day-to-day work. Version: 1.0 Applicable as of: January 1, 2011

3 CONTENT Foreword Introduction 9 2 MAN fulfills its corporate responsibility. 15 Human rights 16 Equal opportunity and non-discrimination 18 Donations, sponsoring and charity 20 Lobbying 22 Environmental protection 24 Product safety 26 Safety in the workplace 28 3 MAN conducts transparent business relationships.. 31 Conflicts of interest 31 Gifts, hospitality and invitations 34 Prohibition of corruption 36 States as customers and dealing with authorities 38 Consultants and agents 40

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5 CONTENT 4 MAN operates in a fair and free market Fair competition 44 Fair purchasing 48 Export control 50 Prohibition of money laundering 52 Capital market 56 Prohibition of insider trading 58 5 MAN protects data, business secrets and company assets.. 61 Data protection 62 Protection of know-how, patents, trade and business secrets 64 IT security 66 Handling company assets 68 Communication and advertising 70 Contact... 72

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7 FOREWORD Dear Employees, MAN is a global enterprise that is steeped in tradition and operates in many areas of business. Being this kind of a company means we have a responsibility as a corporation to our customers, our employees, our investors and the public. This corporate responsibility includes compliance with the laws in force everywhere and at all times as well as respecting ethical values and acting sustainably. We all have to live up to this responsibility this includes the Management Board and managers as well as each and every employee. This Code of Conduct is intended to help us all fulfill this responsibility. It clearly defines our corporate values: We aim to be reliable, innovative, dynamic and open. The Code of Conduct prescribes binding guidelines for areas in which we should pay particular attention to acting responsibly. It describes how to handle critical situations in our everyday business using examples. The Code of Conduct is the very heart of our corporate culture. For this reason, we would ask you to familiarize yourself with this Code of Conduct and follow it in your day-to-day work. Dr. Georg Pachta-Reyhofen Chief Executive Officer MAN SE

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9 1 INTRODUCTION MAN s success essentially depends on all its employees in other words the Management Board, managers and each individual staff member respecting the MAN values of being reliable, innovative, open and dynamic everywhere and at all times in their daily actions as well as systematically putting them into practice. This Code of Conduct helps MAN employees to put these corporate values into practice by highlighting potential areas of risk and conflict, prescribing specific guidelines of conduct for these areas and explaining them using examples of particular cases. The guidelines contained in this Code of Conduct are combined under four basic rules: MAN fulfills its corporate responsibility (pages 15 to 29) MAN conducts transparent business relationships (pages 31 to 42) MAN operates in a fair and free market (pages 43 to 59) MAN protects data, business secrets and company assets (pages 61 to 71) 9

10 INTRODUCTION The Code of Conduct cannot answer all the questions we may encounter in our everyday work, which is why it is supplemented by group policies and agreements in employment contracts. It also goes without saying that every MAN employee must comply with legal regulations. Failure to observe the Code of Conduct can lead to considerable damage, not only to our Company, but also to our employees and our business partners. That is why the Code of Conduct is binding for all MAN employees. Violations of the Code of Conduct will not be tolerated. Anyone who violates the Code of Conduct must expect consequences, which depending on the seriousness of the violation can range from action under labor law or claims for damages under civil law through penalties under criminal law. If you are unsure whether your conduct is in accordance with the Code of Conduct guidelines in individual cases, you should ask yourself the following questions: 10

11 Is my conduct in line with MAN s corporate values and my own ethical values? Is my conduct free of any conflicts of interest? Is my conduct legal and is it in accordance with MAN s group policies? Can I take responsibility for my conduct in good conscience? How would my conduct look if it were reported in a newspaper would it pass the newspaper test? 11

12 INTRODUCTION If you can answer yes to all these questions, it is most likely that your conduct is in line with the guidelines that follow. If you are still uncertain about the answer to any one of these questions, you should contact your superior and/or the unit responsible and/or the compliance officer responsible and/or the Compliance Helpdesk (by ing or phoning +49 (0) ). 12

13 These contacts are available to you at all times and would be happy to advise you. If you identify a possible violation of the Code of Conduct, try to put an end to it. If this is impossible, notify one of the contacts mentioned on page 12. In case of particularly serious breaches of compliance, especially those related to white collar crime (e.g. acts of corruption), antitrust law and data privacy, you can also use the whistleblower portal. 13

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15 2 MAN FULFILLS ITS CORPOR ATE RESPONSIBILIT Y MAN s corporate responsibility means that observing and complying with the law is a matter of course. We have a duty to observe the law under which we operate in all business decisions that we take. Every MAN employee must be aware of his/her social responsibility, particularly the scarcity of resources, and ensure that our products and manufacturing processes are in line with the conditions for sustainable development. MAN s corporate responsibility specifically gives rise to the guidelines that follow. 15

16 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Human rights Background The Declaration of Human Rights adopted by the United Nations and the European Convention for the Protection of Human Rights and Fundamental Freedoms state what is required and expected of the international community when it comes to observing and respecting human rights. MAN guiding principles MAN believes in ethical conduct. The Company respects, protects and encourages all regulations in force to protect human rights as a fundamental and general requirement throughout the world. This not only applies to cooperation within the MAN Group, but also to the conduct of and towards external business partners. Your contribution As an MAN employee, you can also do your bit to respect human rights. Consider human rights a fundamental guideline when dealing with other people and be vigilant of human rights abuse happening around you. 16

17 If you are concerned about human rights abuse in your professional surroundings, try to prevent it and/or stop it. If this is impossible, notify your superior or any of the contacts mentioned on page 12. Example You are responsible for purchasing of specific goods at MAN that are bought in from abroad. You receive information that the company uses children in production or that employees are made to work in inhumane conditions (e.g. exposed to health-endangering risks). Do not ignore this information. Instead, clarify this. MAN must examine business relations with this company more closely and break them off, if necessary. 17

18 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Equal opportunity and non-discrimination Background Equal opportunities and non-discrimination are key cornerstones of fair, unprejudiced and open treatment. MAN encourages diversity and tolerance in order to achieve a maximum degree of productivity, creativity and efficiency. MAN guiding principles MAN offers men and women equal opportunities. MAN does not discriminate or tolerate discrimination on grounds of national or ethnic origin, race, sex, religion, views, age, disability, sexual orientation or any other characteristics protected by law. 18

19 Your contribution Observe the principles of equal opportunity and non-discrimination and encourage people around you to do the same. If you see the principles of equal opportunity and nondiscrimination being contravened, make the persons involved aware of their misconduct. If you are not in a position to influence the events directly, notify any of the contacts mentioned on page 12 or the human resources department of the incident. Example You find out from a colleague who is a friend of yours that an applicant in his department was rejected because he was thought to be homosexual, although he was the best candidate for the advertised job. Help to clarify whether the applicant was in fact not employed on the basis of his sexual preference by reporting the case to the human resources department responsible. 19

20 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Donations, sponsoring and charity Background MAN supports selected non-profit institutions and causes through cash donations and donations in kind as well as sponsoring measures. In order to avoid conflicts of interest and to ensure standard conduct within the MAN Group, the granting of donations and sponsoring measures is only permitted in accordance with the rules laid down in the Group Policy on handling donations and sponsoring measures. MAN guiding principles MAN does not grant any donations or sponsoring measures for political or religious causes. MAN does not grant any donations aimed at bringing about specific performance, decisions or considerations in return for such decisions. Donations and sponsoring measures are only granted in a transparent approval process at MAN. 20

21 Your contribution Only grant donations or sponsoring measures in line with the rules stipulated in the Group Policy on handling donations and sponsoring measures. Example An acquaintance of yours is a respected local politician. Since the local elections are coming up soon, he asks you, a successful MAN employee, for a cash donation from MAN for the election campaign. Donations may only be granted after going through the approval process provided for in the Group Policy on handling donations and sponsoring measures. The donation cannot be approved in this specific case since MAN does not make politically motivated donations. 21

22 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Lobbying Background Politics and legislators exert an influence on business processes. MAN s involvement in commercial trade means that it also affects society. It can specifically bring its interests into decision-making processes, like those for legislation plans, through interest groups. 22

23 MAN guiding principles MAN lobbies centrally, openly and transparently. MAN obeys the law in all countries in which the Company lobbies. Dishonestly influencing policymakers and government is to be avoided without fail. Your contribution Do not lobby as an MAN employee without this being agreed and do not attempt to influence political decisions on behalf of MAN. Example An acquaintance of yours is a member of the parliament. You know that a legislation proposal that is important for MAN is currently being discussed in the parliament and contemplate the idea of contacting your acquaintance to explain MAN s interests in connection with this legislation proposal. Do not approach your acquaintance about the issue. Lobbying at MAN is only coordinated centrally and conducted openly and transparently. The right point of contact for such lobbying action is MAN SE s Corporate Communications department. 23

24 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Environmental protection Background Protecting the environment and the climate are two of the biggest challenges of our time. For years, MAN has been continuously working on reducing emissions and fuel consumption as well as improving production methods to cut the consumption of energy and raw materials as much as possible. MAN guiding principles MAN takes responsibility when it comes to environmental protection concerns. Every employee must also bear protection of the environment in mind in his/her work. MAN also provides information about its commitment to the environment online. Information on environmental protection and sustainability can be found in MAN s CR Strategy Report on the Company website at 24

25 Your contribution Conserve resources and energy. Ensure that you deal with by-products and waste from production in an eco-friendly manner. See to it that raw materials, products and waste are managed, transported and disposed of safely. Example You notice that a can with paint or solvents is leaking a small amount of liquid that is seeping into the ground. Do not rely on somebody else reporting it. Inform an employee responsible of the problem. 25

26 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Product safety Background Countless people come into contact with our products on a daily basis. MAN and the MAN Group s employees are responsible for ruling out any risks or dangers to health and safety that could arise when handling them to the extent possible. 26

27 MAN guiding principles MAN complies with all legal and technical requirements and standards for product safety. Your contribution Do not make any compromises when it comes to product safety. Ensure that suitable measures can be taken in good time in the case of any safety concerns even recalling the product if necessary. Example A customer reports technical problems with a product to you. You are sure that the reason behind this is a mistake on the customer s part when operating the product but cannot rule manufacturing or construction defects out. Clarify the matter. It must be ensured that MAN will solve a problem for which it is responsible. Even customer mistakes when operating may require MAN to respond (e.g. by modifying operating instructions or user training). Consult your superior or the contact responsible for product safety in such cases. 27

28 M A N FULFILLS ITS CORPORATE RESPONSIBILITY Safety in the workplace Background Safety in the workplace serves to prevent industrial accidents, occupational illnesses or work-related health risks. This includes safety and occupational health measures as well as health protection. MAN guiding principles MAN s employees have a right to a safe and healthy working environment. MAN complies with all legal and technical requirements and standards for safety in the workplace. Your contribution Do not compromise when it comes to safety in the workplace. Remember that safety in the workplace affects not only you, but also your colleagues. 28

29 Example You notice that the fire alarms in your workplace have not been checked by the due date. You assume that they are regularly checked by the people responsible. Do not rely on this dangerous fact being reported by another person. A fire not being identified and extinguished in time because of a defect fire alarm could have drastic consequences in an emergency. Inform the people responsible so that this safety risk can be eliminated. 29

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31 3 MAN CONDUCTS TRANSPARENT BUSINESS REL ATIONSHIPS Openness and transparency are key to creating credibility and trust in business practice. That is why MAN sets particularly great store by systematically implementing legal frameworks, intragroup policies and the Company s core values as well as communicating them clearly. This results in the guidelines that follow. Conflicts of interest Background A conflict of interest exists if the private interests of an MAN employee clash with MAN s interests or there is a possibility of this happening. If MAN employees pursue personal interests and do not disclose them or place their personal interests above those of the Company, this could damage MAN and question the Company s integrity and professionalism. 31

32 M A N CONDUCTS TR A NSPA RENT BUSINESS RELATIONSHIPS MAN guiding principles All MAN employees are bound by the Company s interests. MAN counts on all its employees taking decisions based solely on objective criteria and not allowing themselves to be guided by personal interests or relationships. Your contribution Remember that you can also find yourself in a conflict of interest. Inform your superior if you have connections to individuals or companies with whom MAN conducts business that could lead to conflicts of interest e.g. family relationships, partnerships, business partnerships or investments. Avoid the appearance of a conflict of interest and disclose any apparent or actual conflicts of interest to your superior. Example One of MAN s contracting parties often pays late. The employee responsible for the payments is a friend of yours and would therefore prefer it if you did nothing. 32

33 In some cases it may also be in MAN s interests to tolerate late payments. However, you must rule out in each case that this decision is influenced by personal interests and reasons. Do not decide on further course of action on your own for this reason. Inform your superior and agree on further course of action with him/her. 33

34 M A N CONDUCTS TR A NSPA RENT BUSINESS RELATIONSHIPS Gifts, hospitality and invitations Background Benefits in the form of gifts, hospitality and invitations are prevalent in business relationships. These benefits are considered legally permissible to look after customers and are not a cause for concern as long as they are within reason. However, if such benefits exceed what is reasonable and are misused to influence business partners, they may constitute corruption. MAN guiding principles MAN has issued clear rules on when benefits in the form of gifts, hospitality and invitations are appropriate in the Group Policy on handling gifts, hospitality and invitations to events, as well as the steps to be taken when accepting and granting benefits. Your contribution Familiarize yourself with the Group Policy on handling gifts, hospitality and invitations to events, and strictly abide by it. Check your conduct in connection with this to see whether there may be conflicts of interest or whether any can arise. 34

35 Example An MAN supplier s employee gives you a valuable birthday gift that you are not permitted to accept under the relevant policies. You are sure that this does not affect MAN s business relationships with the supplier since you are not one of the key decision makers. You are not permitted to disregard the group policies applicable under any circumstances. If you are concerned that rejecting the gift could be misconstrued, contact your superior and agree on a solution with him/her. 35

36 M A N CONDUCTS TR A NSPA RENT BUSINESS RELATIONSHIPS Prohibition of corruption Background Corruption is a serious problem in commercial trade. It produces decisions based on improper grounds and prevents progress and innovation as well as distorting competition and damaging the Company. Corruption is a criminal offense. It may incur fines for MAN and sanctions under criminal law for MAN employees involved. MAN guiding principles The quality of MAN s products is the key to the Company s success. MAN does not tolerate corruption. All MAN employees must only grant benefits to business partners, customers or other external third parties under the legally permissible conditions and in line with the rules laid down in the relevant group policies. 36

37 Your contribution Never accept a bribe directly or indirectly in any form. Never grant a bribe. Keep an eye out for any acts of corruption around you. If you receive any corruption-related tip-offs, inform the compliance officer responsible or one of the other contacts on page 12 immediately. Example You are responsible for sales in an MAN company and would like to outstrip this year s revenue target. You prepare a bid for a major contract that a potential customer has invited bids for. The decision maker responsible at the customer offers to influence award of the contract in MAN s favor. Question the offer. If there are any signs of corruption (e.g. the decision maker makes the influence offered dependent on improper aspects like a cash payment to him/her personally), you must reject the offer. Inform your superior or the compliance officer responsible immediately. 37

38 M A N CONDUCTS TR A NSPA RENT BUSINESS RELATIONSHIPS States as customers and dealing with authorities Background Governments, authorities and other public institutions are key customers for MAN. Dealing with them often involves special statutory rules. Individual breaches have serious consequences and may bar MAN from public contract awards for good. MAN guiding principles MAN consistently complies with the particularly strict legal provisions that apply when dealing with governments, authorities and public institutions. 38

39 So-called facilitation payments may be requested under specific circumstances (such as payments to accelerate administration matters that are routinely encountered). However, this may easily be considered inadmissible influence. For this reason, MAN does not make any facilitation payments. Your contribution Be aware that particularly strict conditions apply when dealing with public contract awarders. Example You know that an authority is planning to solicit bids for a major contract. You consider phoning the authority employee responsible for the solicitation who you know from an old project and asking him to design the solicitation in such a way that it fits MAN to ensure that MAN secures the contract. Refrain from doing so without fail. This type of influencing would be illegal. 39

40 M A N CONDUCTS TR A NSPA RENT BUSINESS RELATIONSHIPS Consultants and agents Background When initiating and/or conducting its sales-based business dealings, the MAN Group commissions external consultants in some areas of the business who act in a sales support capacity in the interests of or by order of MAN in various ways. However, there is no guarantee that these consultants will follow the same high ethical principles of conduct that MAN itself does because they are not part of the Group. In order to rule out the risk of the remuneration paid by MAN being used as corruption funds insofar as possible, care must be taken when using consultants. Legal violations by these types of consultants can also damage MAN s reputation and even lead to the Company being liable to third parties as well as very high penalties. MAN guiding principles MAN only uses consultants in line with general statutory rules and the rules of the Group Policy on engaging business partners with an intermediary and/or representation function. This ensures that remuneration is only paid for consulting and agency services that are actually rendered and that the payments are commensurate with the performance rendered. 40

41 Your contribution Check the integrity of potential consultants and agents carefully before issuing instructions and executing payments and proceed in line with the Group Policy on engaging business partners with an intermediary and/or representation function. Ensure that the contracts for which you are responsible stand up to legal and business scrutiny, even with regard to comparable contracts with other agents. 41

42 M A N CONDUCTS TR A NSPA RENT BUSINESS RELATIONSHIPS Example MAN takes part in a public solicitation for bids. An agent approaches you and informs you that he can make sure that the contract will be awarded to MAN in exchange for an additional agency fee. You may be liable to prosecution if you approve the additional agency fee and the agent uses this fee as a bribe to ensure that MAN is awarded the contract. In order to rule out this risk, you must check the integrity of the agent using the rules laid down in the Group Policy on engaging business partners with an intermediary and/or representation function. 42

43 4 MAN OPERATES IN A FAIR AND FREE MARKET MAN operates as a fair and responsible competitor. This being the case, all MAN employees have to observe the guidelines that follow. 43

44 M A N OPER ATES IN A FAIR AND FREE MARKET Fair competition Background Fair and free competition is protected by competition and antitrust legislation in force. Complying with this legislation ensures that competition is not distorted which is in the interests of all consumers and for their benefit. Agreements and concerted practices between competitors intended to achieve or effect the prevention or restriction of competition are especially prohibited. Abusing a dominant position on the market is also inadmissible. Such abuse can, for example, take the form of treating customers differently for no objective reason (discrimination), refusal to supply, imposing unreasonable purchase/selling prices and conditions or tying arrangements for no objective reason for the additional performance demanded. Anti-competitive conduct not only has the potential to damage MAN s reputation considerably, but also to incur severe fines and penalties. 44

45 MAN guiding principles MAN s business is conducted solely on the basis of merit and market economy principles as well as free and open competition. We like to measure ourselves against our competitors, always abiding by rules and regulations as well as observing ethical principles. MAN employees do not enter into any anti-competitive agreements with competitors, suppliers or customers. If MAN is in a dominant position on a market, it does not abuse this position. Your contribution Ensure when in contact with competitors that no information is imparted or received that allow conclusions to be drawn about the informer s current or future business conduct. Avoid conversations with competitors about issues that are important among the competition. Examples of such issues are prices, pricing, business planning, stockpiled inventories or delivery times. 45

46 M A N OPER ATES IN A FAIR AND FREE MARKET Example You talk to a competitor s employee at a trade fair. After a while you notice that he is trying to coax information about MAN s business planning for the next fiscal year out of you. In return, he offers to divulge the same information about his company. Make it unequivocally clear to the competitor s employee immediately that you will not talk to him about such issues. This type of conversation in addition to the unauthorized disclosure of business secrets is a breach of the competition and antitrust legislation in force and could have drastic consequences for you personally and MAN as well as for the competitor. Inform the compliance officer responsible or one of the contacts mentioned on page 12 of this incident. 46

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48 M A N OPER ATES IN A FAIR AND FREE MARKET Fair purchasing Background MAN is bound by contract to a large number of suppliers and service providers in its business operations. They make it possible for MAN to supply its own customers with products and services. MAN s business success depends, among other things, on working with the most able suppliers and service providers. MAN guiding principles MAN carefully selects suppliers and service providers based on objective criteria. When purchasing products and services the purchasing departments responsible must be consulted as laid down in the relevant purchasing policies. Your contribution Do not favor a supplier or service provider one-sidedly with no objective reason. Avoid any conflict of interest (see also Conflicts of interest, page 31). 48

49 Do not purchase any products or services without first having looked at the market and alternative suppliers. Follow the group policies relevant in the Group and involve the purchasing department responsible at an early stage in the purchasing process. Example It comes to your attention that MAN would like to commission a supplier delivering poor quality at excessive prices as part of a major order while the quote from another supplier offering higher quality and better value for money is not to be taken into account. Notify one of the contacts listed on page 12 or the purchasing department responsible to ensure that the quote most cost-effective for MAN has a chance. 49

50 M A N OPER ATES IN A FAIR AND FREE MARKET Export control Background Export control restricts the foreign trade and payments of a country or an economic area for security reasons. Export control covers the cross-border exchange of goods and services with group companies as well as third parties. Export controls are intended to prevent the proliferation of weapons of mass destruction and the uncontrolled proliferation of arms. MAN guiding principles MAN complies with all provisions for importing and exporting goods, services and information. Your contribution In the case of decisions to import or export products, consciously examine whether this decision may fall under export control. Obtain advice in the event of any doubt, e.g. from the contacts listed on page 12 or the relevant legal department. 50

51 Example You receive a request from a potential customer wishing to place an order with MAN to supply products in a country that is in a state of war. Clarify the matter by asking the legal department about export restrictions that apply to the country to be supplied (e.g. a UN embargo) and do not conclude any contracts binding MAN to export to this country until the issue has been fully clarified. 51

52 M A N OPER ATES IN A FAIR AND FREE MARKET Prohibition of money laundering Background There are laws against money laundering in place in many countries. Money laundering occurs when funds or other assets originating directly or indirectly from criminal offenses are put into circulation in the legal economy, making them appear legal. Liability for money laundering does not require the person involved to be aware that money is being laundered through the legal transaction concerned or the transfer concerned. Inadvertent involvement in money laundering may be a reason for serious penalties for everyone involved. MAN guiding principles MAN carefully checks the identities of customers, service providers, consultants and other third parties with whom legal relationships are entered into. It is MAN s declared aim to only conduct business relationships with serious business partners operating in line with legal provisions and using funds from legitimate sources. Incoming payments must be assigned to the corresponding services and posted without delay. All cash flows transparently and openly. 52

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