Principles on conduct toward business partners

“We have a responsibility to our customers and suppliers”

In competition for contracts, we rely on the quality and benefits of our products and services for our customers as well as on reasonable prices. We support national and international efforts to stop competition being affected or falsified by bribery. In our dealings with business partners (customers, suppliers, cooperation partners) and state institutions, we strictly differentiate between the interests of the company and the private interests of employees on both sides. All actions and (buying) decisions must be made independently of any extraneous considerations or personal interests. The respective valid legislation on corruption must be noted and observed. The following should be noted in particular:

1. Business crimes

It is forbidden to offer, promise, grant or approve any personal benefits of value in exchange for preferential treatment in business relations. Similarly, such personal benefits of value may neither be requested nor accepted in dealings with business partners. Schuler forbids its employees from accepting any promises of such benefits.

Schuler’s Board of Management and employees are not allowed to offer, promise, demand, grant or accept any gifts, payments, hospitality or services in their business dealings which are granted with the intention of influencing a business relationship in an improper manner or which threaten to jeopardize the professional independence of the business partner. This is generally not the case with gifts and invitations within the scope of normal business hospitality, customs or politeness. 

2. Crimes in connection with public officials

Anti-corruption laws forbid the granting of donations to domestic and foreign government officials, civil servants, political or military authorities, and representatives of international organizations (such as the United Nations and the World Bank) with the intention of receiving orders or other benefits for Schuler. The granting of personal benefits (especially of a monetary nature, such as payments and loans, including the granting of even small gifts) by Schuler and its employees to public officials (such as civil servants or employees in the public service) is not permitted.

Gifts, services, payments and loans granted by Schuler to political parties, committees, elected officials or candidates are only permitted if they comply with applicable laws and local regulations and were approved in advance by Schuler’s Board of Management.

3. Crimes in connection with export transactions

Both national and international, extraterritorial foreign trade and customs laws determine where and how Schuler is allowed to sell its products and technology or disclose information. In some cases, it is forbidden by law to do business with certain countries; in other cases, it is forbidden to export goods or transfer services and technologies without official permission. Customs laws require a detailed description, complete breakdown and accurate value indication of all goods to be exported.

Anti-boycott laws may prohibit participation in boycotts of other countries and limit the disclosure of information about business activities and persons. They may also specify that authorities must be informed about certain requests to disclose information or participate in boycotts.

These international trade laws are very complex. The consequences of violating these laws can be significant for the company and the persons involved and include fines and even imprisonment. For all questions regarding the application of these laws in an employee’s own area of responsibility, staff are encouraged to contact their respective Export Control or Customs Officers.

4. Offering and granting benefits

Benefits of all kind offered or granted by employees of Schuler Group GmbH to public officials or employees of private companies with the aim of receiving orders or unfair advantages for Schuler or any other persons are forbidden.

Courtesy gifts up to a certain limit which are in line with generally accepted business practices are to be handled in accordance with those binding laws applicable to us and the corresponding internal guidelines. In all situations, they should be chosen in such a way that the recipient is not required to conceal their acceptance and is not forced into any form of dependency.

Business and project-related travel expenses of public officials or non-officials are only reimbursed to a reasonable extent. The applicable regulations must be observed. Reimbursements must be granted in such a way that they do not have to be concealed by the recipient (“publicity test”).

5. Demanding and accepting benefits

Gifts from business partners correspond to a certain extent with generally accepted business practices. However, their acceptance may lead to conflicts of interest and jeopardize the good reputation of our company.

No employee may use his position or function within the company to demand, accept or procure personal benefits. The acceptance of occasional gifts of minor value is permitted. Gifts and other benefits for the employee or related persons in excess of the aforementioned limits must always be declined. In such cases, employees must inform their superiors about the gifts or other benefits offered to them.

6. Effect of this guideline on suppliers

Schuler agrees to inform its direct and indirect suppliers with regard to the principles of this Code of Conduct. Moreover, it shall encourage its suppliers to comply as far as possible with the content of this Code of Conduct and urge them to also observe its guidelines.

7. Additional guidelines

Schuler has issued binding guidelines on the acceptance and granting of gifts, as well as invitations for hospitality and entertainment. They provide detailed information with regard to appropriate gifts of minor or symbolic value, appropriate business meals and appropriate events of their own company and of their business partners (customers, suppliers). Should Schuler employees face a conflict of interest, or be uncertain as to whether a conflict of interest exists or could arise, they are obliged to contact the Compliance Officer for advice.