CODE OF CONDUCT Our principles for business
COMMITMENT Dear Employees, Rheinmetall International Engineering GmbH is an international company. Corporate social responsibility towards employees, customers, business partners, investors and the public is of great importance to us. We act in strict accordance with the law at all sites and at all times, respect fundamental ethical values and pursue sustainable practices. Each of us who acts for the company or on its behalf accepts responsibility for this, whether as an employee, consultant or independent commercial agent. These principles for business form the basis of our corporate culture. Observing these principles is essential to the success of the company. They are based in essence on the following fundamental values: Fairness in dealing with employees and business partners Authenticity in terms of compliance of employees conduct with these basic principles Professionalism as regards a high level of knowledge and skills for the benefit of employees and business partners Entrepreneurship in terms of discovery and responsible use of business opportunities We live and breathe these values in dealing with each other on a dayto-day basis and in working with business partners and third parties. Please therefore familiarise yourself with the content of these principles for business. They are binding in particular in those areas where you are required to take responsibility for your own actions. Reliability of statements issued by the company to employees and business partners Steffen Jungclaus Chief Executive Officer Rheinmetall International Engineering GmbH 2
Objectives This code of conduct Our principles for business forms a joint framework for Rheinmetall International Engineering GmbH and its subsidiaries (hereinafter also referred to as RIE ), within which we are committed to achieving our corporate objectives. A business strategy focused on ethical standards and the personal integrity of all employees are essential for the credibility and high public regard of RIE. Every employee must be familiar with and observe the relevant laws and regulations, including these basic principles. Any breach of these may result in consequences under labour law, ultimately leading to termination of employment. Principle of good corporate governance Good corporate governance protects the legitimate interests of the company and its owners. The management structure selected for this purpose, consisting of responsible managers under the supervision of the shareholders meeting, is also used to provide optimum support for business operations. Corporate social responsibility RIE is conscious of its responsibility towards employees, customers and business partners as well as towards society and the principles that underpin it. RIE and its employees respect the personal dignity of each individual and do not tolerate any discrimination in the company s global operations. Discrimination based on gender, ethnic origin, disability, age, sexual orientation, religion or ideology is not tolerated by RIE. RIE is thus committed to human rights and international standards to protect employees. RIE is conscious of the scarcity of resources and focuses on the principles of sustainability. These include a responsible approach to the environment and occupational health and safety measures that ensure the physical and psychological well-being of employees. 3
Compliance with the law and internal regulations RIE s commercial success is based on strict compliance with the law and with the regulations for employees laid down by RIE. This is the only way to ensure fair, correct and legally compliant conduct in business dealings with customers, suppliers and other parties. The exact provisions are defined in detail in the RIE directive on conduct in business dealings and other directives binding on all employees. All employees must use the intranet to keep themselves up to date on the directives. Ban on corruption and benefits to third parties Using corruptive means in any form to achieve commercial purposes is prohibited. Corruption occurs primarily in the form of bribery of office holders such as civil servants and accepting and granting undue advantages among non-office holders. Corruption leads to incorrect business and economic decisions that hinder progress and innovation and distort competition. Corruption in its various forms is penalised by law in Germany and almost every country in the world. Good business relationships with customers, suppliers and competitors are a prerequisite for commercial success. Maintaining these business relationships must not exceed the boundaries of unfair influence at any time no employee may offer business partners, their employees or third parties inadmissible advantages or procure these. No employee may demand or accept inadmissible advantages. Benefits, for example in the form of gifts, invitations for food and drink, events, donations and sponsorship, that may be capable of influencing partners business decisions may be interpreted as corruption. Even the impression of potential influence must be avoided. Collaboration with business partners RIE has introduced an internationally recognised process for collaboration with specific business partners and the risks associated with this that is adapted to the company and is used for monitoring, approving and documenting these third parties and applies to RIE globally. All RIE employees must perform this business partner compliance screening before commissioning/contracting such third parties. Fair competition and procurement Freedom of competition is a precious economic commodity and is protected in Germany and most countries throughout the world by strict competition and antitrust laws. In particular, agreements and agreed practices between competitors that are intended to prevent or restrict competition or bring this about are prohibited. Nor is it permitted to abuse a dominant market position. Any agreement with competitors of RIE that could be relevant to competition between RIE and those companies is prohibited. It is not permitted to give preference to a supplier or service provider without objective justification that can be substantiated. Clear provisions within the scope of applicable legislation are laid down for awarding contracts. 4
Export control and prohibition on money laundering RIE ensures compliance with all provisions for exporting goods, services and information in line with the applicable statutory export control provisions. RIE also ensures compliance with the statutory bans on money laundering in place in most states. Conflicts of interest RIE employees are obliged, under the terms of their contract of employment, to safeguard the interests of RIE, maintain confidentiality regarding the company s affairs and not compete with RIE. In the course of their work, employees must not enter into a conflict between the interests of RIE and their own. If such a conflict is possible, employees must notify their superior about this. Protection of company assets and specific information RIE employees are entrusted with the company s assets in the course of their work. Every employee is responsible for careful handling of the company s assets and protecting these. Similarly, employees protect the company s confidential information within the scope of applicable laws and taking into account statutory or regulatory duties of disclosure. In particular, employees observe the applicable statutory and company regulations on protecting personal data and on data and information security. Consultation and opportunities for reporting If employees have doubts about whether particular conduct complies with these principles for business, or they suspect the existence of an irregularity, they are required to make this known. They can either report the matter internally to the compliance department or externally to an ombudsman. The relevant contact details can be found on the RIE intranet. All employees are expressly required to use one of these options to report irregularities. No employee who makes a report should have anything to fear as a result. 5
To ensure our documents are easy to read and understand, we dispense with using both genders as a general rule, but this is not intended to be discriminatory in any way. RHEINMETALL INTERNATIONAL ENGINEERING GMBH Compliance Department Industriestrasse 13 65366 Geisenheim Germany Tel.: +49. 6722.501.375 Fax: +49. 6722.501.531 E-Mail: compliance@rheinmetall-ie.com