Code of Conduct
1. Fundamental principles
We expect the same basic understanding from our business partners. This is not intended to establish rights in favour of third parties.
2. Compliance with laws
We comply with the applicable laws and other legal provisions of the countries in which we operate. Where local laws and regulations are less restrictive, our actions are guided by the principles of this Code of Conduct. In cases where mandatory local law directly conflicts with the principles contained in this Code of Conduct, local law takes precedence. Nevertheless, we endeavour to comply with the provisions of this Code of Conduct.
3. Integrity and compliance
We have implemented appropriate compliance measures to ensure that the following areas are adequately addressed:
3.1 Corruption
We do not tolerate corruption, bribery or extortion; they prevent fair competition. In our business relationships, we neither promise, offer, grant, request or accept benefits that are intended, or could appear to be intended, to influence business decisions or secure any other improper advantage, nor do we allow such benefits to be promised to us. Particularly strict standards apply when dealing with persons who are subject to specific criminal or liability provisions (e.g. public officials).
3.2 Fair competition
We act in accordance with national and international competition and antitrust law and do not engage in price fixing, market sharing, customer allocation, market allocation or bid rigging.
3.3 Prevention of money laundering
Money laundering is the process of introducing illegally obtained money or assets into the legitimate financial and economic system. We comply with our legal obligations to prevent money laundering and do not participate in transactions intended to conceal or integrate criminally or illegally acquired assets.
3.4 Protection of information and intellectual property
We protect confidential information and respect intellectual property. Technology and know-how must be transferred in a way that protects intellectual property rights, customer information, trade secrets and non-public information. We comply with applicable laws protecting trade secrets and treat our business partners’ confidential information accordingly.
3.5 Data protection
We process, store and protect personal data in accordance with legal requirements. Personal data is collected confidentially, transparently and only for lawful, previously specified purposes. We process personal data only where it is protected against loss, alteration and unauthorised use or disclosure by appropriate technical and organisational measures.
3.6 Export controls
We undertake to comply with the relevant export control regulations, in particular licensing requirements and prohibitions on exports and support, when transferring and exporting our goods.
3.7 Avoidance of conflicts of interest
We avoid internal and external conflicts of interest that could improperly influence business relationships. Where this cannot be achieved, we disclose such conflicts.
4. Health and safety
We protect the health of our employees by taking appropriate occupational health and safety measures (e.g. implementing an occupational health and safety management system) that adequately address the following areas:
- compliance with applicable laws and alignment with international standards relating to occupational health and safety;
- appropriate workplace design, safety regulations and provision of suitable personal protective equipment;
- implementation of preventive controls, emergency measures, an accident reporting system and other appropriate measures for continuous improvement;
- providing employees with access to sufficient drinking water and clean sanitary facilities.
We ensure that all our employees receive appropriate instruction.
5. Remuneration and working hours
Remuneration is based on applicable laws and, where applicable, binding collective agreements, supplemented by the relevant national minimum wage legislation.
Employees are clearly, comprehensively and regularly informed about the composition of their remuneration. We comply with applicable laws and international labour standards concerning maximum working hours and ensure that
- working hours, including overtime, do not exceed the applicable statutory maximum limits;
- where no such provisions exist, weekly working hours, including overtime, do not exceed 60 hours, even in exceptional cases;
- employees have at least one full day off per calendar week.
6. Respect for human rights
We respect and support internationally recognised human rights and
- respect the personal dignity, privacy and personal rights of every individual;
- protect and uphold the right to freedom of opinion and expression;
- do not tolerate unacceptable treatment of employees, such as physical or psychological abuse, sexual or personal harassment, or discrimination.
6.1 Prohibition of child labour
We do not tolerate child labour. We do not employ anyone under the age of 15 and require proof of age. In countries covered by the developing-country exception under ILO Convention No. 138, the minimum age may be reduced to 14. We do not employ anyone under the age of 18 for hazardous work as defined by ILO Convention No. 182.
6.2 Prohibition of forced labour
Forced labour, modern slavery and comparable practices that deprive people of their freedom are prohibited. All work must be voluntary, and employees must be able to terminate their employment relationship.
6.3 Freedom of association and collective bargaining
We respect employees’ rights to freedom of association and assembly and to collective bargaining, insofar as these rights are legally permitted and possible in the country in which we operate. Where this is not permitted, we seek appropriate solutions for our employees.
6.4 Promoting diversity and equal opportunities
We promote equal opportunities and do not tolerate discrimination. We treat all people equally, irrespective of gender, age, skin colour, ethnic origin, sexual identity or orientation, disability, religion, belief or other personal characteristics.
7. Environment, energy and climate protection
We act in accordance with applicable laws and are guided by international standards in order to minimise negative environmental impacts and continuously improve our environmental and climate protection activities. All employees are encouraged to be mindful of environmental protection, and appropriate training is provided.
We have implemented appropriate environmental protection measures (e.g. an environmental management system) that adequately address the following areas:
- setting objectives, defining and implementing measures, and continuously improving them;
- environmental aspects such as reducing CO2 emissions, increasing energy efficiency and using renewable energy, safeguarding water quality and reducing water consumption, safeguarding air quality, promoting resource efficiency, reducing waste and ensuring its proper disposal, and handling substances hazardous to people and the environment responsibly.
8. Conflict minerals
We take appropriate due diligence measures to avoid the use of conflict minerals in our products, thereby helping to prevent human rights violations, corruption and the financing of armed groups or similar activities.
9. Supply chain
We expect our suppliers to comply with the principles of this Code of Conduct or to apply equivalent codes of conduct. We also encourage them to enforce the provisions of this Code of Conduct within their own supply chains. We reserve the right to review our suppliers’ application of this Code of Conduct systematically and where circumstances warrant. Such reviews may take the form of questionnaires, assessments or audits.
If doubts about compliance with this Code of Conduct remain afterwards, the supplier will be asked to take appropriate corrective measures and report the matter to its responsible contact within our company. Where necessary, the business relationship will be terminated.
10. Consumer interests
Where consumer interests are concerned, we comply with consumer protection regulations and appropriate sales, marketing and information practices. We pay particular attention to groups requiring special protection (e.g. young people or pregnant women).
11. Implementation and enforcement
We make appropriate and reasonable efforts to implement, document and apply the principles and values described in this Code of Conduct on an ongoing basis. All employees are made aware of the contents of the Code of Conduct and receive appropriate training on relevant topics as required. Violations of the Code of Conduct are not tolerated and may result in consequences under employment law.
11.1 Communication
We communicate openly and encourage dialogue about the requirements of this Code of Conduct and its implementation with employees, customers, suppliers and other stakeholders.
11.2 Reporting violations
We provide our employees and business partners with access to a secure mechanism for confidentially reporting possible violations of the principles of this Code of Conduct.
If you wish to report a concern, please contact the following person directly or anonymously:
Mr Stoyko Notev
As managing partner, Mr Notev is available for all questions relating to the Code of Conduct and can be contacted by email (support@lamapoll.de) or by post (LamaPoll – Notev – Grünberger Str. 44 a – 10245 Berlin).
After a thorough market analysis, we chose LamaPoll. The reasons: a German company based in Berlin, German data protection law and German servers. Working with them has been completely smooth so far, both technically and organisationally. We are very satisfied and are happy to recommend LamaPoll.
