Code of Conduct

Applicable Law

aconium GmbH undertakes to comply with and implement all laws and regulations applicable in Germany, irrespective of any resulting economic disadvantages. It expects the same from its business partners. All managers are instructed to know the basic rules and regulations in their area so that they can pass on their knowledge to the employees of aconium GmbH.

Human Rights

Compliance with the globally applicable regulations for the protection of human rights is a matter of course for aconium GmbH. All forms of modern slavery, human trafficking and child labor are consistently rejected.

Communication

aconium GmbH stands for open and honest communication. Employees may also approach their superiors or the management with critical issues. We believe that working together in a spirit of trust means that misconduct can be identified at an early stage, corrected and even avoided in the future. Our managers are required to encourage employees to speak openly at all times.

Transparent Production

aconium GmbH attaches great importance to comprehensible, established processes. In our own interest as well as in the interest of our business partners and customers, we strive for the greatest possible transparency. To this end, it is essential that all processes are documented at all times.

Chinese Walls

aconium GmbH supports a large number of different projects. These assignments are strictly separated from one another. To this end, we work with a role-authorization concept. The various departments of aconium GmbH are separated from each other in such a way that the different objectives can neither lead to conflicts of interest nor can an exchange of confidential information take place.

Consideration

aconium GmbH attaches great importance to trust and respect. Maximum productivity, competitiveness, innovation, creativity and efficiency can only be achieved through respectful cooperation. All employees should treat each other with courtesy and mutual respect. Harassment, any form of unwanted physical contact, bullying and intimidation are strictly prohibited by aconium GmbH and may have consequences under labor law.

Diversity

aconium GmbH selects its employees solely on the basis of their qualifications and skills. All employees are offered the same opportunities. Discrimination based on gender, age, disability, sexual orientation, pregnancy, parenthood, marital status, religion, ideology, ethical or national affiliation, skin color, political views or social background is rejected without exception. aconium GmbH stands for diversity, promotes tolerance and is committed to inclusion.

Employee Representative

The employees of aconium GmbH have founded a works council. The aim is to achieve a fair balance between the different interests. The aim is to achieve an open, trusting and constructive dialog.

Working Conditions

aconium GmbH complies with the statutory provisions to ensure fair working conditions. Particular importance is attached to the regulations on remuneration, working hours and the protection of privacy. In addition, aconium GmbH promotes the compatibility of work and family life through flexible working time models.

Occupational Health and Safety

aconium GmbH promotes a healthy and hazard-free working environment. The laws and regulations on health and safety in the workplace are complied with. All managers must ensure that appropriate procedures and protective measures are in place to ensure health and safety in the workplace.

Protection of Intellectual Property

Intellectual property is a right to an intangible asset. It is protected by law and/or as a trade secret. Reproduction therefore requires mandatory permission. Every employee is instructed to protect the intellectual property of aconium GmbH from attacks by third parties or loss. The intellectual property of others must be respected.

Confidentiality

Trade and business secrets of aconium GmbH or its business partners are treated as strictly confidential by aconium GmbH or its employees and may not be disclosed to third parties. They may also not be used for the employees’ own private purposes.

Insider Trading

Insider information is defined as specific information about circumstances that are not publicly known and which, if they become known, could significantly influence the price of securities or similar financial instruments. Insider trading is a criminal offense in Germany, as it impairs the functioning of the capital market. aconium GmbH expressly rejects insider trading and explicitly instructs its employees not to use insider knowledge for personal gain or for the benefit of aconium GmbH or third parties.

Accounting and Bookkeeping

All business transactions, assets and liabilities are recorded and fully documented. The company’s business transactions and documents must be correct and proper. Any form of balance sheet manipulation is prohibited by aconium GmbH.

Money Laundering Prevention

Money laundering occurs when money or other assets originating directly or indirectly from criminal acts are brought into the legal economic cycle. All employees are called upon to report any unusual financial transactions.

Terrorist Financing

Terrorist financing occurs when funds or other resources are made available for terrorist offenses or to support terrorist groups. All employees are required to report suspicious transactions.

Donations

aconium GmbH always makes donations in its own name. No services in return are expected. There is complete documentation of the recipient, the purpose of the donation and confirmation of the donation. No direct or indirect donations are made to public bodies, political organizations, parties or individual politicians.

Political Representation of Interests

aconium GmbH refrains from exerting unfair influence on politics and legislation and complies with the legal regulations on lobbying.

Protection of Company Assets

The company assets are used by aconium GmbH for the intended business purpose. Misuse, illegal or unauthorized use, in particular for private purposes, is prohibited. All forms of fraud, whether at the expense of company assets or the assets of third parties, are strictly prohibited by aconium GmbH.

Conflicts of Interest

When making business decisions, every employee is required to check whether the decision is influenced by private interests. Private and business interests must be kept separate so that decisions can be made neutrally and rationally. aconium GmbH encourages its employees to discuss any potential conflicts of interest with their line manager. These agreements must be documented.

Relationships with Business Partners

aconium GmbH sees itself as a reliable and legally compliant business partner. We want to meet the challenges of today and always find the best solution for our customers. Managers are encouraged to familiarize their employees with the contractual obligations towards our contractual partners.

Dealing with Political Institutions and Authorities

Special care must be taken when dealing with political institutions and authorities. Stricter requirements often apply to these business relationships. Honesty and transparency as well as compliance with applicable law should be a matter of course in every action we take.

Competition

aconium GmbH stands for fair and undistorted competition in the interests of all market participants. This is a key prerequisite of the social market economy. To protect this competition, aconium GmbH naturally complies with the relevant legal requirements.

Product Safety

aconium GmbH sees itself as a service provider for its customers. It attaches great importance to a trusting, productive and long-term customer relationship. We aim to offer our customers the highest level of quality with our products and services.

Information on Products and Services

aconium GmbH always makes truthful statements with regard to its products and services. We are of the opinion that untrue statements can jeopardize existing business relationships. Therefore, to protect the good reputation of aconium GmbH, untrue statements must be refrained from.

Data Protection

aconium GmbH ensures confidentiality when collecting, storing, processing or transferring personal data of employees, customers or other third parties. We act in accordance with the principle of data minimization and encrypt or delete data whenever possible. All employees receive data protection training. Those employees who handle personal data also receive advice and support from the relevant department.

Use and Security of IT Systems

aconium GmbH takes appropriate security precautions when handling sensitive data and protecting intellectual property through the use of IT systems. All employees receive regular training on information security. The IT resources available at the workplace belong to aconium GmbH and are company property. It is prohibited to use them for private purposes. Employees of aconium GmbH are required to protect the security of IT systems against internal and external misuse.

Ambassador of the Company

aconium GmbH respects the right to freedom of expression. Employees of aconium GmbH act as representatives of the company in public. Managers are role models for all employees. All employees are aware that behavior that damages the company’s reputation must be avoided. The good reputation of the company is decisive for the economic success of aconium GmbH.

Reporting Violations

Violations of the law or breaches of the Code of Conduct must be reported. Line managers should pave the way for this and be approachable alongside the Compliance Manager. Irrespective of this, the statutory reporting obligations must be complied with, particularly when serious criminal offenses are observed.

Internal Early Warning System / Risk Communication

aconium GmbH has implemented a whistleblower system through which whistleblowers can report violations of national and EU law while maintaining the confidentiality of their identity or anonymously. The internal reporting channels enable the electronic, physical, written and verbal submission of reports. In order for the protection mechanisms of the Whistleblower Protection Act to be effective, whistleblowers must be convinced that they are telling the truth at the time they submit a report.

The submission of deliberately or intentionally false information, facts or accusations is considered an abuse of the whistleblower system and may result in consequences under employment law (warning, dismissal) as well as criminal liability and claims for damages under civil law.

Prohibition of Corruption

aconium GmbH vehemently rejects any form of corruption. Our employees receive annual training on corruption prevention. All employees are aware that gifts or other benefits are only permitted if they are customary in business, of low value, ethically unobjectionable and not related to a consideration. No employee may demand gifts or other benefits from business partners.

Acceptance of Gifts

Professional activities may not be used to obtain private benefits. All employees are prohibited from accepting gifts. This does not apply to low-value gifts where refusal would be socially inappropriate due to local customs. Company decisions must not be influenced by this. Under no circumstances are cash, vouchers or similar items to be accepted. In the case of invitations to meals, the limits of customary business hospitality must be checked. If the invitation serves to unduly influence business decisions, it must be declined.

Making Gifts to Third Parties

aconium GmbH instructs its employees not to distribute gifts and invitations to third parties. This does not apply to the usual occasional and promotional gifts and invitations that are in line with custom and courtesy in a country. In cases of doubt, employees can contact their superiors.

Climate Protection

aconium GmbH is committed to sustainable environmental and climate protection. When developing new products and the services we provide, we ensure that the impact on the environment and climate is kept to a minimum. A climate protection officer has been appointed to support us in improving our environmental performance. Every employee is encouraged to act in an environmentally conscious manner.