Compliance code of conduct
ESG Guidelines

ESG has prepared the “Compliance Code of Conduct” to live up to its responsibility of engaging in responsible and lawful conduct. All employees can inform themselves about the values, regulations and conduct crucial for ESG in this “Code of Conduct”. The Compliance Code of Conduct generally applies to ESG Elektroniksystem- und Logistik-GmbH (ESG) and in the ESG Group. Group companies can however bring their own code of conduct into force, as long as it does not contradict the principles listed here.

Principle of
responsible and lawful conduct

The Compliance Code of Conduct generally applies to ESG Elektroniksystem- und Logistik-GmbH (ESG) and in the ESG Group. Group companies can however bring their own code of conduct into force, as long as it does not contradict the principles listed here.

ESG’s business partners also must comply with the guidelines set out in the Code of Conduct. In order to cement this principle, ESG requests for business partners to comply with their own code of conduct with similar in content or a standard industry code or to commit themselves to compliance with the ESG Compliance Code of Conduct for Business Partners.

Compliance
management system

A compliance management system has been launched to ensure compliance with laws and guidelines within the company. The compliance management system (CMS) forms part of ESG’s “integrated management system” and therefore also the related ESG regulations.

A CMS refers to the organisational structure as well as all measures and methods established within the company in connection with compliance. The aim of the CMS is to recognise, assess and manage compliance risks and prevent violations of the law, and therefore sanctions imposed by the authorities or customers as well as the related damage this causes to both the company’s financial position and reputation so as to ensure the company’s success in the long term. Group companies shall be integrated in this compliance system taking into account the company-specific and legal requirements of the respective country.

Compliance
channels for communication and reporting
Compliance
organisation

The compliance organisation consists of the following persons and positions:

  • Management Board
  • Compliance Officer
  • Security Manager
     

In addition,

  • an ombudsman
     

has been set up for employees so that they can direct their questions as well as information to an external body outside of ESG’s organisation. All of these persons are available to answer questions regarding compliance and can be contacted with information on cases of non-compliance with legal requirements. The existing communication and reporting channels are supplemented by a whistleblowing hotline. This highly protected system allows employees and business partners to ask questions and provide notifications or tip-offs concerning serious compliance violations, if necessary also anonymously.

ESG’s compliance activities focus on preventive measures such as training, information and communication regarding all compliance-related topics within the company. The CMS also provides an opportunity to address questions or information on violations of the law in a suitable manner.

compliance
programme

Regular risk assessments are carried out to determine all compliance risks relevant to ESG. Organisational instructions (compliance rules) have been prepared for all material compliance risks included in the CMS and guidelines specified in the “Code of Conduct”. The organisational instructions constitute an important component of the CMS as they transform legal requirements into company rules for employees.

The compliance rules form an integral part of the regulations and are binding for all employees. Depending on their severity but regardless of their legal consequences, violations will incur disciplinary measures up to the termination of employment. The Internal Audit department primarily investigates and controls compliance matters. ESG employees have the opportunity to find out about the CMS in the company-wide WIKI (company information). They also must attend compulsory events in accordance with the existing training concept, which is based on the Code of Conduct. Business partners have to undergo regular integrity checks. In a structured process, questionnaires and references, database checks and comparisons with embargo lists are used to collect all information available to create a comprehensive profile of the business partner.

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