Stichling Hahn Hilbrich GmbH | Code of Conduct
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Stichling Hahn Hilbrich GmbH

Our code of conduct describes the principles, guidelines and values of Stichling Hahn Hilbrich which determine the business behavior of our company and what all Employees and Managing Directors have to be familiar with. The code gives orientation for the fundamental ethical and legal duties of all staff members of Stichling Hahn Hilbrich. It supports the goals of the Management of strengthening the ethical standards throughout the company and promoting a working environment that consists of integrity, respect and fair behavior.

1. Application and Scope of Validity
This Code is binding and applies to all staff members of SHH. Any persons, who work for, represent or serve as advisors to Stichling Hahn Hilbrich, will be responsible for familiarizing themselves with and adhering to this Code of Conduct. This responsibility also extends to persons, who are entrusted with important duties or Management work in areas where important information is communicated and exchanged with customers, suppliers and the financial sector. Any person, who in performing his work for our company becomes exposed to special situations not governed by the Code, is obligated to confer with a superior regarding such matter. As a general law, no action may be taken which could infringe valid or impair the public image of SHH or an employee.

2. Lawful Conduct
A fundamental requirement with respect to any action taken in the interests of Stichling Hahn Hilbrich is that such action constitutes lawful conduct. As a company of adjusters with long history and tradition, we endeavor to conduct our national and international business affairs in accordance with the applicable laws, rules and regulations and with high ethical standards. Quality management is an integrated component of our processes and operating procedures.

3. Antitrust Law and Competition
We are convinced that the interests of all persons are best served by preserving fair competition. As an internationally operating company, we seek to engage in our business actively, competently and ethically. In all markets in which we do business, we seek to comply with the applicable laws regarding anti-trust, competition and restraints of competition and not to get any unfair advantages over customers, suppliers and competitors. It is a fundamental principle of our Company that our Employees act in accordance with the respective competition law that is applicable for the business activity of SHH. Our Employees are therefore prohibited from entering into any transactions which restrain competition, from colluding with competitors to partition markets or customers or from entering into price and boycott arrangements.

4. Granting and Accepting Benefits
We operate a fair, honest and legally conforming business policy, which does not countenance corruption or bribery. Our Employees are therefore prohibited from offering or accepting any gifts or privileges, which might impair the objectivity of business decisions during the initiation, award or execution of an order. Gifts may be accepted or granted only if they are generally a customary business practice and are viewed as merely a courtesy or a favour in the relevant region (e.g., flowers, calendars, other promotional gifts). At no time may monetary gifts be accepted or made. Business dinners and entertainment may be accepted and offered, if they are related to the normal course of business and the expenditures are reasonable. Benefits or gratuities, which are bestowed on government decision-makers with the intent of accelerating the administrative procedures and acquiring unlawful competitive advantages, are prohibited. Any acceptance or grant of a benefit must be notified to a superior. Presents become the property of the company and will be used for company purposes. The management will decide about the utilization of the presents.

5. Fair Working Conditions and Conduct in the Workplace
Stichling Hahn Hilbrich is a socially responsible Employer and views its Employees as its greatest strength. SHH seeks to create a work environment that appreciates the diversity and value of different international cultures. SHH seeks to contribute through a human resource policy tied to professionalism and values. We fully expect a friendly, respectful and fair interaction between colleagues, employees and third parties. We do not tolerate any form of discrimination and harassment based on nationality, culture, religion, national origin, sex, sexual orientation and age. We do not tolerate any drug abuse at the workplace. Anyone who requires assistance or consultation in this regard may in confidence contact the Management or our Management Assistant. Alcohol in small quantities may be consumed only on special occasions. This must be done in a responsible manner and with the consent of superiors. Any threats or acts of violence such as physical intimidation are prohibited.

6. Information and Data Protection
Information is one of the most valuable assets of Stichling Hahn Hilbrich. Transparent and effective dissemination of information is a key to the company‘s success. A significant share of Stichling Hahn Hilbrich GmbH business information is, however, confidential or legally protected, which means that confidentiality must be preserved, unless a publication of the information was approved by SHH or is required by law or regulation. Any author or recipient of information must act accordingly. These rules apply specifically to intellectual property such as trade secrets, patents, trademarks and copyrights. Intellectual property also includes business, marketing and service plans: engineering and manufacturing know-how, drafts, databases, business working papers, salary information and any other unpublished financial data and reports. SHH shall carefully use and confidentially handle any and all personal information about Employees, customers, business partners and suppliers. Protection of this information is extremely important and must be carried out with the greatest degree of care in order to continue safeguarding the trust and confidence of the persons affected. Personal data may be collected, processed and used only upon express authorization. Such data may not be disclosed to third parties. SHH shall create the necessary standards to guarantee an appropriate degree of know-how- and information protection.

7. Safety and Security
SHH places the highest priority on securing the safety of its employees, customers, visitors, images, tangible assets, know-how and data. With the help of the relevant professionals, SHH shall provide sustainable processes, strategies and standards in the various areas of health, safety, security and IT. All Employees are obligated to work together with great care to promote this safety and security. The extensive use of modern IT technology also harbors a risk of data loss, data theft or that data may be overwritten unknowingly. To minimize this risk, the greatest degree of care must be exercised whenever modern methods of communication are used. SHH’s internal email and internet policy as well as its password guidelines must be observed. The appropriate standards will be continuously evaluated together with the responsible IT-Coordinator and will be adapted with regards to changing conditions.

8. Compliance and responsibility
The Board of Directors as well as all Employees must comply with the requirements set forth in this Code of Conduct. Violations of the Code must be disclosed to the Board of Directors. Violations of this Code will have consequences. In serious cases, these consequences could involve labor law repercussions, disciplinary action, civil litigation or criminal prosecution. Each amendment to or rescission of this Code requires a resolution and will be published in accordance with what is required by law.

9. Compliance Committee Policy
The Board of Directors are obliged to be absolutely discreet and will use the highest ethical policy while investigating and processing cases. They will examine the incidents through conversations and consultations and take the necessary measures. Offences against the Code shall have appropriate consequences. Irregularities shall be remedied and inadequate processes shall be changed. Personal misbehavior associated to the Code can lead to legal consequences based on labor law. There can be legal consequences based on civil and criminal law as well.