Compliance Code of Conduct & Whistleblower System

Preamble

The passion for innovative transport solutions has been driving us for 65 years. With a clear goal – we want to build vehicles that are precisely tailored to our customers' needs, meet the highest quality standards and ensure an impressive performance in practical everyday use. In order to achieve this goal, we work in compliance with the law at all levels of our corporate hierarchy. In this context, the persons involved, i.e. managing directors, executives and all employees, bear responsibility for their actions with the Code of Conduct as a framework, combining the demand to comply with the law and regulations with the special integrity requirements.

Corporate Governance

Böckmann Fahrzeugwerke GmbH complies with all legal and statutory regulations governing the management and supervision of the company.

Business Relations

We deal with all business partners of Böckmann Fahrzeugwerke GmbH on a basis of equality and fairness. The private interests and personal benefits of employees do not influence corporate decisions.

We strongly oppose any form of corrupt behaviour. Employees of Böckmann Fahrzeugwerke GmbH are not permitted to offer, promise or grant any advantages to decision-makers of our business partners or any persons in the public sector in order to secure any favourable decisions or actions in return. Böckmann Fahrzeugwerke GmbH does not accept, tolerate or tacitly condone bribery in any form.

Likewise, the employees of Böckmann Fahrzeugwerke GmbH do not allow themselves to be promised or offered any advantages, do not accept any advantages or demand any personal benefits for themselves or a third party.

Böckmann Fahrzeugwerke GmbH maintains international business relations for the import and export of goods, products and services. We support free world trade and comply with embargoes and applicable import and export control regulations by monitoring the sanctions list.

Böckmann Fahrzeugwerke GmbH maintains confidential and fair business relationships with its suppliers and, in turn, expects to be treated with the same respect and integrity by its suppliers.

We are committed to fair competition in all our business relationships and ensure that no anticompetitive agreements are made with competitors, customers or suppliers regarding prices, market or territorial divisions. Böckmann Fahrzeugwerke GmbH does not disseminate false information about competitors' products or services, nor does it seek competitive advantages in any other unfair or abusive manner.

Böckmann Fahrzeugwerke GmbH promotes and supports education, science, culture and sports with financial and in-kind donations. Donations are not made to gain any business benefits. Payments to individuals or to private accounts are not permitted. Political contributions and donations are only granted to the legally permissible degree within the framework of the law.

Böckmann Fahrzeugwerke GmbH takes all necessary measures to prevent money laundering within its sphere of influence.

Other Conflicts of Interest

The interests of the managing directors, executives and employees of Böckmann Fahrzeugwerke GmbH do not conflict with the interests of Böckmann Fahrzeugwerke GmbH, especially with regard to secondary activities for competitors.

Equity stakes of employees of Böckmann Fahrzeugwerke GmbH in the businesses of competitors or business partners that enable corporate influence are not in the interest of Böckmann Fahrzeugwerke GmbH.

Gifts and Other Benefits

In general, suppliers and service providers are requested not to give any gifts or other benefits, such as invitations, to the employees of Böckmann Fahrzeugwerke GmbH. If it is not possible to avoid these, employees are permitted to accept personal gifts or other benefits from third parties up to a value of EUR 5.00. If the value exceeds EUR 5.00, gifts or other benefits must be surrendered to management. These will be included in an internal raffle in which all employees can participate.

Company Property

The private use of company property is only permitted if allowed by legal and / or company regulations or company practice.

Information and Data

Data security is of utmost importance to Böckmann Fahrzeugwerke GmbH. We therefore protect company, customer, business partner and employee data against illegitimate access, unauthorised and improper use and loss by appropriate technical and organisational means to the extent permitted within the scope of the law. The confidentiality of information and business documents is supported by an appropriate IT rights concept. The employees of Böckmann Fahrzeugwerke GmbH strictly comply with the applicable data protection regulations and respect and observe the rights of the persons whose data they collect, process and use.

All employees of Böckmann Fahrzeugwerke GmbH are obliged to protect the interests of the company. Information is only communicated by authorised employees to authorised recipients (internal and external).

Behavioural Requirements

Böckmann Fahrzeugwerke GmbH and its employees unequivocally oppose any form of bullying, i.e. the systematic hostility, harassment or discrimination of employees against each other or by their superiors.

Böckmann Fahrzeugwerke GmbH expects all its managing directors, executive and employees to act in accordance with this Code of Conduct. Violations of legal regulations and internal guidelines can have serious consequences, not only for the individual personally, but also for Böckmann Fahrzeugwerke GmbH. Deliberate misconduct will therefore not be tolerated; violations will be strictly sanctioned and without regard to the position and standing of the respective person.

It should therefore be possible to report and violations without fear of negative consequences. Böckmann Fahrzeugwerke GmbH creates the necessary space for this by means of its open and fear-free corporate culture and a working atmosphere based on mutual appreciation, respectful interaction and goodwill.

The whistleblower system of Böckmann Fahrzeugwerke GmbH enables reporting of violations of legal regulations and/or rules of the Code of Conduct and thereby contributes to their detection. Böckmann Fahrzeugwerke GmbH has set up several reporting channels to find out about serious violations in the company in good time and to be able to follow up on submitted information appropriately. Both employees of Böckmann Fahrzeugwerke GmbH and outsiders can use these to provide information on potential bribery offences, fraud, violations of antitrust law, violations of the Money Laundering Regulations or violations of accounting regulations, for example. Informers should submit their reports to the best of their knowledge and belief. However, anyone who recklessly or knowingly makes false, unjustified accusations and allegations must expect the appropriate consequences. Employees should first consider contacting their manager personally.

Please note that our whistleblower system is not intended for complaints.

Contact for submitting information:

By email:      compliance@boeckmann.com 

By letter:       - Mark letter as confidential - 

                        Böckmann Fahrzeugwerke GmbH
                        Compliance                                                                                                                                                            Siehefeld 5
                        D-49688 Lastrup