Adherence to sound business ethics as a principle of action can be seen as a key factor in making a difference for our company and for society.
We integrate voluntary norms and standards into our daily business and are responsible for acting in a compliant manner and actively addressing misconduct.
By acting in accordance with the principles of our Code, we bring about positive change and help ensure that CARUSO provides an inclusive and respectful working environment where everyone feels safe and that he is heard.
We safeguard our business interests by protecting our assets and those of third parties, acting responsibly and maintaining values-based, long-term business relationships.
As a matter of principle, we are committed to fair and honest dealings with each other, our customers, suppliers, and other business partners.
Business ethics – cooperation with business partners
We expect our business partners to follow the guidelines of ethical business practices, to respect hu-man rights, and to comply with the ILO labour conventions, the principles of the UN Global Compact and the UN Guiding Principles on Business and Human Rights (↗Link).
We actively work to ensure that these principles are adhered to and implemented by our business partners in the value chain (i.e., suppliers, business partners). We expect them to comply with the above standards such as child labour, forced labour, discrimination, and freedom of association, etc.
Conflicts of interest
Conflicts of interest can arise, for example, if personal or one’s own monetary interests collide with the objectives of CARUSO or of business partners. If a conflict of interest cannot be eliminated, this may be the reason an office or activity cannot be conducted.
Individual decision-making situations in which the interests of the company conflict with personal interests must be reported immediately to superiors or management for clarification.
Typical examples of conflicts of interest are:
- Gainful secondary employment of employees. The responsible manager must be informed of such an activity before it begins. If such a conflict of interest exists, the secondary activity can be disallowed if it conflicts with the legitimate interests of the company.
- The acceptance of a mandate on the board of directors, supervisory board, advisory board or any other body at a corporate client or supplier – also applies to close relatives. Therefore, employees may only take on such tasks if they have been approved in advance.
- Participation in competitor companies.
- The hiring of a relative or partner, the promotion of such a hire or the assumption of a management position vis-à-vis a relative or partner.
- The hiring of a person by use of a political connection.
- A personal interest in a supplier, customer, or competitor, not based on official business, which influences decisions.
- Close relationship with senior management of a competitor or supplier.
- A substantial personal financial interest in a supplier or corporate client – also applies to close relatives.
If there is uncertainty as to whether a conflict of interest is material, the direct supervisor, senior management, Human Resources, or the Compliance Officer must be contacted.
Business ethics – fair competition and anti-trust laws
We always comply with all competition and antitrust laws. We are committed to fair, open and unrestricted competition and do not accept any form of illegal, anti-competitive or derogatory behaviour or unethical practices to win a contract or continue a business relationship.
We pay particular attention to prohibited cartel agreements such as:
- Price rigging
- Agreements on market shares
- Capacity agreements
- Division of regional markets
- Division of customers
- Price fixing
Even concerted actions, informal discussions or informal gentlemen’s agreements which have as their object or effect the restriction of competition are prohibited. Even the appearance of such conspiratorial actions must be avoided. Collusion with other bidders – especially in private tendering and public procurement procedures – is not only prohibited under antitrust law, but also under criminal law. In the case of all (even if only planned) agreements with competitors – even if they relate to areas outside the competitive situation – the legal team must be consulted.
Violations of the antitrust laws applicable in the individual countries, and of the US and European anti-trust laws, can have profound consequences for us as a company. In the case of antitrust violations, there is the threat of severe fines, claims for damages, exclusion from public contracts and loss of image. The employees involved can also be personally exposed to profound consequences, including sentences of imprisonment.
Even if a business has fallen into a crisis through no fault of its own, self-help through cartel agreements cannot be justified.
We apply the same zero-tolerance policy to any direct or indirect bribery, kickback or corruption. This is independent of whether it is practised by employees, clients, or other business partners.
We do not do business at any price. We do not bribe and do not allow ourselves to be bribed.
We convince our business partners and customers with our products and services and not through undue influence. Nor do we allow ourselves to be unduly influenced but make decisions for objective and comprehensible reasons.
We do not tolerate corrupt behaviour by our employees, business partners or customers. Decisions based on corruption distort competition and harm our company and the common good. To avert dam-age to us, we avoid even the mere appearance of undue influence.
We also act in accordance with our corporate principles when in contact with employees of the government and government authorities as well as public officials and politicians. We avoid even the mere appearance of improper influence, for example through payments, contributions, or other advantages.
We also adhere to these principles when such benefits are expected or allegedly customary for official acts. With regular training and controls, we ensure that corrupt behaviour is prevented, uncovered, and punished.
Our guiding principle is always: we would rather forego business and the achievement of internal goals than violate the law.
Money laundering prevention
We fulfil our legal obligations to prevent money laundering and do not engage in money laundering activities. Each employee is requested to have unusual financial transactions, especially involving cash, which could give rise to suspicion of money laundering, checked by the responsible finance department in case of doubt.
Gifts and entertainment
When dealing with business partners and customers, gifts and invitations are customary and permissible within reasonable limits, as they serve to maintain relationships. However, they must be proportion-ate.
For example, travel, services, tickets to sporting, musical or other cultural events, bonuses and dis-counts are considered gifts.
Receiving gifts and entertainment
As employees, we must not solicit, request, or demand gifts, entertainment, personal services, or favours from business partners, either for ourselves or for others.
We refuse to do so if there is even the mere appearance of improper influence. We also pay attention to the appropriateness of discounts and benefits.
We may accept voluntarily granted promotional and occasional gifts of reasonable value. We only accept invitations from business partners to meals or events if they are unsolicited, serve a business purpose, and not repeated unreasonably often and if the invitation is in proportion to the occasion.
As an order of magnitude of what can be considered appropriate, we are guided by a value of 60 euros for gifts from third parties and a value of one hundred euros for invitations from third parties.
In case of doubt about the appropriateness of gifts or invitations, we consult with the direct manager or company management. If we receive benefits that exceed our guidelines, we disclose this and document the receipt.
As a matter of principle, we do not accept monetary gifts.
We must comply with the legal regulations of the country in which we work.
Gifts from us to our partners & customers
Also, in the case of gifts and invitations to our business partners and customers, we adhere to the principle that even the mere appearance of undue influence must be avoided. Their acceptance must not place the recipient in a position of compelling dependence. Benefits are only permissible in reason-able amounts and within the scope of ordinary business activities. In this context, a maximum amount of EUR 60 is also assumed for gifts in kind and EUR 100 for invitations.
In the case of gifts and invitations to employees of public authorities and publicly owned companies as well as to public officials and politicians, we are cautious and examine the appropriateness particularly critically.
Monetary gifts are inadmissible.
In cases of doubt, the decision of a superior or the company management must be obtained.
These principles also apply to mailings to private addresses.
Country-specific legal regulations must also be considered here.
Donations & Sponsoring
Donations are defined as charitable, non-commercial contributions in the form of money, goods, or services. We are committed to social causes, donate to charitable causes, and encourage our employees to participate in ethically worthwhile activities. The same applies to sponsoring measures implemented by the company.
Donations & sponsorships are only made after approval by the management.
Export and import laws
We are required to comply with all applicable export and import laws, including, among others, sanctions, embargoes and other laws, regulations, government orders or directives.
Politics and legislation influence the framework conditions for economic activity. CARUSO influences society through its participation in economic transactions and can specifically introduce the company’s positions into decision-making processes (e.g., in legislative projects) within the framework of political lobbying.
In principle, in the case of political representation of interests – regardless of whether it is undertaken by an individual/an employee or on behalf of the company (e.g., via an association) – it applies:
- that this be done or would be done openly and transparently, and
- that it is always clear whether the interests involved are those of the individual person or those of the CARUSO.
We conduct lobbying in accordance with the principles of openness, comprehensibility, and accountability. Neutrality in dealing with political parties and interest groups is a matter of course for us. Unfair influence on politics and legislation is not permitted.
No individual employee attempts to influence political decisions on behalf of the company unless he has been authorised to do so.
If he has been authorised to do so, he shall comply with the relevant internal guidelines in the performance of his duties.