1.   Preamble

The compliance principles shall inform the employees and the legal representatives of CONSULECTRA in a proper way about applicable laws and corporate guidelines and sensibilize them for the legal risks at everyday work. The code of ethics includes laws and other rules that are specifically relevant for our company and offers guide. It defines as commitment to a law conforming and ethical conduct in our company the standard for a responsible behaviour with our business partners and the public but also for the interaction between our employees.  
Compliance means a conduct in compliance with law and rules. Our employees and legal representatives are committed to comply with the applicable laws and corporate rules in their professional activities.  
These principles shall be a help for the daily work and support our employees to prevent from misconduct.
The employees and the legal representatives of CONSULECTRA are bound to the regulations of these compliance principles. They define the values, policies and behaviour that are determinative to conduct the business. The commitment of the legal representatives is to comply with the ethical standards and to create a work environment that promotes honesty, integrity, respect and fairness. A business policy in strict compliance with laws and principles subserves long-term corporate interests.


2.   Compliance of laws and other conditions home and abroad

CONSULECTRA complies in all decisions and actions in relation with their business with the applicable laws and other essential conditions home and abroad. Integrity and sincerity support a fair competition, also in concern of the relationship between customer and supplier.
As any violation of the applicable laws or regulations can result in severe consequences such as prosecution, indemnification or  reputation slur, all legal representatives and all employees of  CONSULECTRA are obliged to know the basic laws, regulations and internal corporate rules, that are relevant for their range of responsibility and to respect them. Comprehensive knowledge is demanded especially by the executive personnel who with regard to their function or position have a special responsibility to ensure the compliance principles. It is the duty of CONSULECTRA to act economically, socially and eco-friendly. It is therefore indispensable to conduct business competently and ethically, to protect fair competition in all markets we are active by respecting the laws to be applied in concern of bans on cartels, competition and competition restrictions. Unfair advantages against customers, suppliers or competitors must be avoided. Some countries, branches or markets may have special regulations. Such regulations are principally to be considered. In case of doubt, an external legal adviser shall be called in. 

3.   Fair competition

We are committed to fair competition and respect the laws and regulations. The anti-trust law wants to protect the unsophisticated competition on the market.
In most countries agreements with competitors, suppliers and customers risking fair competition are prohibited. These include and concern price-fixing agreements, customer splitting between competitors, and other unfair methods. Even the exchange of sensible data such as prices, price items, price-forming factors, disposition of quantities and fields of sale may mean a violation of the anti-trust law without having consciously coordinated a market behaviour.


4.   Conflicts of interest

We expect our legal representatives and employees to be loyal towards the company.
Any situation where personal or financial interests may create a conflict with those of  CONSULECTRA is to be avoided. It is therefore especially forbidden to participate in competitors, suppliers or customers or to enter business relations with them privately, as far as it may create a conflict of interest.  No situations of conflict may affect the interests of CONSULECTRA.
Such conflicts of interest may arise in many situations. It is not allowed to take any advantage whatsoever which - with a reasonable view - might influence business decisions and transactions. Invitations are to be kept within the limits of usual hospitality in business.  Nobody may due to his position personally take advantage directly and/or indirectly by accessing confidential data. It is the duty of everybody to support the legitime interest of CONSULECTRA as far as possible. Any situation of competition is to be avoided.
Every real or potential conflict of interest is to be reported and discussed with the concerning superiors/compliance managers.


5.   Anti-corruption

CONSULECTRA condemns any form of corruption and bribery.
Business relations to governmental institutions are often subject to particularly strong requirements. Our contact with governments and authorities is always conducted with integrity and transparency and in compliance with applicable law. An office holder holds a public office at an authority or is elsewhere engaged in a public administration. Office holders in many countries are subject to strong regulations. In some countries like Germany the allowance of any personal advantage whatsoever is forbidden, even if of little value.
Any kind of corruption and corruptibility is forbidden. Acting with unfair methods is not tolerated. It is not allowed to offer business partners payments, nor to accept such payments, which affect the objective and fair decision for the business or give the appearance of it.
Gifts provided on the occasion of invitations or promotion events to support business relations or to present products or services are allowed to a reasonable extent. Such gifts may however only be accepted or allowed for a justified business purpose, not for the service for having taken unfair advantage or allowing advantage. The gift shall be within an adequate value and not exceed the limits of a reasonable business relationship nor exceed receivers’s living standard.
Demands or offers for sponsoring or donations for charity should be treated with care. An extensive documentation has to prove that it is no hidden bribery.


6.   Work safety and protection

As employer CONSULECTRA has a social responsibility and values their employees.  We do not tolerate any kind of discrimination, harassment or intimidation and treat our employees with respect and dignity.
CONSULECTRA is responsible for a safe and healthy working environment. Safety regulations are therefore strictly to be respected.


7.   Data protection and trade secrets

CONSULECTRA is committed to ensure a smooth data exchange within the company. Data have to be communicated correctly and completely to the departments concerned, excepted are prevailing interests due to secrecy. Relevant information may not be withdrawn illegally, falsified or selectively transmitted.
Dishonest reporting within the company or to organsations or persons outside the company is strictly forbidden. All annual accounts and annual reports, business papers and books have to clearly represent the business operations and transactions and comply with the legal requirements and accounting principles and the RWTÜV Group Accounting Guideline. 
A large part of the business data is confidential or copyrighted, implying secrecy. This does not apply if the disclosure of the data is forced by law or regulations. The confidentiality agreement especially concerns intellectual property. It is including trade secrets, patents, brands and copyrights, but also business and marketing layouts, salary data and all other, undisclosed financial data and reports. All personal data about employees, customers, business partners and suppliers and third are carefully used and confidentially treated in full compliance with the data protection laws. The protection of such data requires highest diligence. 
The collecting, storing and processing of personal data of employees, customers or third are treated with utmost care and strict secrecy in full compliance with applicable laws and regulations.
Employees having to treat with personal data are specially instructed and supported by the corporate data protection manager.


8.   Warranty of our services

Our customers are our partners. Long-time relationships with our customers support our business success. We are therefore committed to offer our customers optimum services of highest quality. Our services may neither be defective nor of bad quality that may damage health or property.
The adherence to a large number of national and international standards and guidelines has become nowadays prerequisite for the lawful marketing of a product or service. Preventive or damage-limiting legal measures like quality assurance agreements,  agreements of recourse within the suppliers ‘chain or the implementation of measures with the already existing duty of market monitoring, help to minimize the risks of warranty.


9.   Corporate taxes

We are explicitly committed to completely fullfull our tax liabilities. We reject any kind of fiscal abuse and avoid legally inadmissible constellations.


10. Handling of property assets

All employees and legal representatives are responsible for the orderly handling with property assets and obliged to protect same against loss, damage, misuse, theft, defalcation and destruction.


11. Compliance violations and sanctions

The legal representatives and employees are committed to the rules of this code of ethics. Violations shall have consequences. In serious cases of violation the employment can be cancelled. Cases of criminal offence can be accused.  In case of damage to the company, indemnification can be demanded.


12. Compliance manager

Compliance manager of CONSULECTRA is:
Mr. Torsten Brinker
  +49 40 27899-230

13. Report

Suspected misconduct or violations of these compliance requirements detected internally or externally are to be reported at the external integrity manager of the RWTÜV group.  
The external integrity manager in the RWTÜV group can be contacted by E-Mail under integrity(at)tuvit.de