The trust of our customers and our employees is an important prerequisite for our business success. Honesty, credibility and legally impeccable behaviour are the guiding principles of our actions. We want to protect our employees from misconduct and take proactive measures to avoid risks. As we are a company with an international presence, these principles apply to all employees of HMF Smart Solutions GmbH (HMF) worldwide.
This Code of Conduct sets out our guidelines, the handling of company information and resources and legal aspects.
Laws & regulations
We comply with the laws and regulations of the individual countries as well as HMF’s internal guidelines. Violations of these requirements are not trivial, but serious offences that damage the entire company. Every single employee contributes to HMF’s reputation, which we want to maintain and strengthen through our joint endeavours.
All people have equal rights
Therefore, there is no excuse for discrimination or harassment in the workplace, whether based on age, disability, origin, gender, political views, trade union activities, race, religion or sexual orientation.
Every opinion and every experience is valuable. We therefore promote a learning culture in which everyone’s right to openly express their opinion is valued and everyone is encouraged to do so.
We respect internationally recognised human rights in our business activities and are never complicit in human rights abuses.
Fair and open-minded behaviour
We promote fair and open-minded behaviour towards each other and towards our business partners, with the aim of providing our customers with the best possible advice and service.
Integrity
An important key to the company’s success is the personal honesty and reliability of all HMF employees and representatives. This requires compliance with our Code of Conduct and respect for other corporate cultures, especially when dealing with our customers.
Ecologically responsible, socially and environmentally conscious behaviour
HMF is aware of its responsibility with regard to environmental protection. All company employees must therefore ask themselves the following questions: What impact does my behaviour have on the environment? How can I avoid unnecessary pollution?
Health and safety are valuable assets. We therefore attach great importance to the protection of all employees, customers, partners and other persons affected by the company’s business activities.
HMF ensures that its processes, technologies and products fulfil current industry and environmental standards. This is also guaranteed by our quality management programme.
Dealing with conflicts of interest
Secondary employment or financial interests of our employees in other companies must not conflict with the interests of HMF.
Dealing with proprietary information
Confidential information
Information and expertise are one of HMF’s valuable resources. The open and efficient flow of information within the company is important for our success.
However, much of the company’s business information is confidential and must be treated accordingly. This includes, for example, trade secrets, copyrights, business agreements, marketing and service schedules, engineering and production-related technical know-how, designs, databases, business papers, personal data and all unpublished financial data and reports.
Communication with journalists and the media
Press releases and other HMF publications must be complete, honest, accurate, up-to-date and understandable. Information for the general public may only be released by authorised employees.
Handling business documents and reports
Annual financial statements, annual reports, business transactions and activities must fulfil legal requirements and accounting principles as well as comply with the company’s internal accounting methods. This applies to electronic data as well as printed formats.
Handling of the company’s assets
Donations & sponsorships
Donations and sponsorships are only permitted within the framework of the applicable laws and in accordance with internal guidelines. The Chief Executive Officer of HMF decides on donations and contributions to political parties.
Protection of the company’s assets and property
Assets, equipment, business documents, labour resources and other material or intellectual property of HMF may not be used for private purposes or passed on to third parties if such activities are contrary to the interests of HMF. Nor may our employees be used for non-company purposes.
Unlawful activities
Criminal offences
Corruption and bribery are not tolerated by HMF.
Employees must not be involved in unlawful activities in the workplace or tolerate unlawful activities associated with HMF. This also applies to violations of fair competition and tax laws.
We carefully select business partners (agents, intermediaries, authorised representatives and consultants) in accordance with this policy.
Acceptance of gifts & benefits
Gifts and benefits from business partners are normal business practice up to a certain level. However, gifts and benefits that exceed this generally accepted level lead to conflicts of interest and jeopardise HMF’s good reputation.
The acceptance of gifts and benefits is subject to the limits stipulated by tax legislation. The current limit is €40 including VAT.
Gifts and donations that exceed this limit but cannot be refused in the interests of good business relations must be donated to charitable organisations. Exceptions require the approval of the Chief Executive Officer of HMF.
Invitations to appropriate business meals may always be accepted.
Invitations to events such as concerts, theatre performances, sports and evening events as well as some seminars and conferences do not always focus on business matters. If the event is primarily for leisure, each employee must critically ask themselves whether their participation is compatible with normal business practice – which normally requires that the host is present, that participation is not repeated several times and that the costs of travel and accommodation are not borne by the business partner from whom the invitation originates. The employee’s line manager must always be informed.
Gifts & benefits to third parties
Invitations to leisure events and other benefits may never be issued or offered with the intention of gaining dishonest business advantages. This also applies if such an impression could arise.
Gifts and invitations to leisure events must not contradict standard or local business practice. Employees who wish to give gifts or extend invitations to leisure events should therefore first familiarise themselves with the relevant standards and rules. Any acceptance of benefits must be transparent.
Invitations and gifts may only be sent to the recipient’s business address.
Benefits or gifts that exceed the normal limit and invitations to events or business meals that exceed the normal limit may not be offered without the approval of the line manager.
Gifts & benefits to representatives of public institutions
Office holders, representatives of public organisations, government representatives, civil servants and politicians are obliged to act in the public interest. Therefore, they may not be offered gifts or benefits, either directly or indirectly, or invited to events that could jeopardise their independence.
Exceptions to this rule are gifts or invitations that show due respect for public or political office. However, gifts and invitations of this nature may only be presented or extended by or on behalf of the Chief Executive Officer of HMF.
Export and import control
HMF strictly adheres to all national and international embargo, export and import regulations. Under no circumstances will HMF violate or tolerate violations of such regulations, including prohibited shipments via third countries.
When selecting our business partners, we strictly adhere to the restrictions imposed by anti-terrorism lists.
Fair competition in the selection of suppliers
Suppliers and service providers are selected according to objective and comprehensible criteria. Where possible, orders are placed on the basis of competing offers.
Data protection and data security regulations
We protect our customer, partner and employee-related data and comply with the statutory and internally agreed data protection guidelines and regulations.
Consequences of violations
In serious cases, government authorities and courts can impose fines not only on HMF, but also on the employees concerned. Even prison sentences are conceivable. In addition, the company’s licence to operate could be revoked.
Violations that constitute a breach of the obligations set out in an employment contract may result in disciplinary action, up to and including dismissal of the employee concerned. The employee could also be liable for damages.
Whistleblower system
At HMF, not only the entire team, but also former colleagues, customers, suppliers and third parties have the opportunity and the right to raise any violations or suspected violations of our Code of Conduct or applicable laws. The direct manager is available as a contact person for this purpose. There is also the option of reporting such cases via our whistleblower system on the HMF website.
Anyone who, based on solid evidence and in good faith, is convinced that a violation of the law or the Code of Conduct has occurred or may occur and decides to report this situation to HMF can be sure that they will not suffer any disadvantages. In each individual case, HMF will, if necessary, take measures to protect the person making the report from any disadvantages. To the extent possible and legally permissible, HMF will ensure the confidentiality of the identity of persons who report violations or suspected violations in accordance with these guidelines and of those who assist in the investigation of such cases.
Assumption of responsibility
We can achieve the goals associated with this Code of Conduct if all the people concerned play their part. Each individual employee is therefore personally called upon to implement the guidelines described here.
If you become aware of non-compliant behaviour, please inform the contact person (see chapter 7) or your line manager. In this way, you can help to prevent minor problems from becoming major problems.
In order to achieve our common goals, we also rely on the support of the employee representatives at HMF.
Contact person
Basic questions about the Code of Conduct can be directed to HMF’s Legal Counsel.
