Preamble

As a medium-sized company, we attach great importance to working with our customers and suppliers in a spirit of partnership. We can only achieve our goal of sustainable business through close cooperation in a spirit of partnership. This leads to successful results for customers, partners and ourselves.

These goals, as well as a sensitised public, require a reflection on values and norms such as partnerships between equals, integrity and trustworthiness. We do this not only to avoid damage to our image and penalties, but especially to contribute to improving the cooperation of all partners involved.

These are the reasons FKM management has developed a Compliance Mission Statement to specify the “what” (corporate strategy) and the “how” in this regard and to establish these in a binding way.

Open communication based on partnership provides a necessary foundation for the implementation and further development of compliance in the company. The analysis of the work is done in open discussions with the aim of optimising the processes through corrective measures in a continuous improvement process. One aspect of working with each other is that we allow different opinions.

 

What does compliance mean for us?

  • We understand compliance to mean adherence to the legal obligations, regulations and guidelines applicable to the business field of FKM Elemente GmbH as well as our self-commitment to adhere to our own rules.
  • Our actions are in line with the general social values of morality and ethics in this respect.

 

Our Compliance Mission Statement

  • FKM Elemente GmbH traditionally conducts its business in accordance with applicable laws as well as generally accepted ethical principles. This is linked to our self-commitment to abide by our own rules.
  • Everyone in the company – shareholders, directors, managers and employees – makes a fundamental contribution to this by aligning their conduct and actions with applicable laws, principles and rules.
  • Our self-commitment in this regard will also be a benchmark for us in future for the selection of managers and employees as well as for the establishment and further development of business relationships with our customers and suppliers.
  • All managers and employees of FKM Elemente GmbH are required to counteract violations of laws, guidelines or principles in accordance with our corporate values. The first point of contact for compliance standards is an employee’s immediate supervisor.
  • No one may suffer any disadvantage in the company as a result of adherence to the law and the requirements of the compliance standards.

 

Our compliance standards at a glance

Based on our Compliance Mission Statement, we align our conduct and entrepreneurial actions with our compliance standards on the following topics:

  • Cooperation with customers and suppliers
  • Anti-competitive agreements
  • Handling of company property and assets
  • Social responsibility
  • Illegal employment and undeclared work
  • Environmental protection
  • Transparency and information policy
  • Conflicts of interest and bribery
  • Bribery and corruption
  • Donations and sponsorship
  • Data protection
  • Confidentiality

 

Cooperation with customers and suppliers

Our business relations with our customers and suppliers are characterised by mutual fairness. We are committed to our principles of “Together. Trustworthy. Transparent.” They form the foundation for a cooperative partnership with our customers and suppliers.

We only offer projects that we are proficient in and only promise what we can deliver.

 

Anti-competitive agreements

We do not enter into any anti-competitive agreements. This applies in particular to agreements with customers and suppliers aimed at restricting competitors in their freedom to determine their prices and other conditions autonomously.

Anti-competitive agreements are detrimental to fair and beneficial competition. They prevent us from constantly improving, suppress our technical and commercial competence and ultimately lead to stagnation. In this regard we disadvantage ourselves through anti-competitive agreements.

Anti-competitive agreements are punishable by law and lead to significant fines, claims for damages and/or barring from the award of contracts. We therefore comply with applicable laws that protect and promote competition, in particular applicable antitrust laws and other laws regulating competition.

 

Handling of company property and assets

We all have a duty to use the property and assets of the company, our customers and suppliers expediently, sparingly and responsibly in every respect.

This is an essential condition for securing our independence and continued existence as a medium-sized company.

 

Social responsibility

We ensure occupational safety and health protection in the workplace within the framework of the applicable legal provisions.

This requires compliance with the relevant regulations and adherence to the recognised rules of technology, in particular the regulations of the employers’ liability insurance association and the rules for safety and health at work. We support continuous development to improve our working environment.

We are committed to opposing any form of discrimination within the framework of the respective applicable rights and laws.

 

Illegal employment and undeclared work

We do not tolerate any form of illegal employment such as child labour or undeclared work.

Illegal employment and undeclared work only promote underperforming companies in the market. It promotes price dumping and poor quality, damages the labour market and social security systems.

Illegal employment and undeclared work are punishable by law and, in addition to loss of image, can result in heavy fines and/or heavy prison sentences.

 

Environmental protection

Sustainable management and environmental protection are central to our self-image.

In all environmental protection measures, the primary objective is to coordinate decisions and processes within the company in such a way that legal requirements are met and the sustainable use of natural resources is duly taken into account and continuously improved.

At the same time, environmental damage is to be avoided in the course of our activities, and harm to the environment is to be reduced to a level that is technically and organisationally unavoidable. We support sustainable management and environmentally conscious actions by our managers and employees.

 

Transparency and information policy

We are committed to ensuring the fast and smooth exchange of information within the company. Knowledge relevant to an activity must not be unlawfully withheld, falsified or selectively disclosed.

Information must be passed on correctly and completely to other authorised areas.

 

Conflicts of interest and bribery

We avoid situations in which our personal or financial interests conflict with those of FKM Elemente GmbH.

In particular, it is prohibited to participate in the companies of competitors, suppliers or customers or to enter into business relationships with them in a private capacity if this may lead to a conflict of interest. Such a conflict always exists if the nature and extent of the participation is capable of influencing actions in the performance of activities at FKM Elemente GmbH in any way.

No employee may accept benefits – in any form whatsoever, in particular personal gifts or benefits resulting from business relationships of FKM Elements GmbH – which may reasonably be assumed to be able to influence business decisions or transactions.

Invitations to pay must remain within the limits of customary hospitality.

 

Corruption and bribery

Corruption is prohibited and punishable by law in Germany and abroad, even in private business transactions.

At the heart of bribery and corruption is always the personal enrichment of a person through abuse of power. As a rule, this is done at the expense of fair and supportive competition, which in particular supports efficient and healthy companies such as FKM Elemente GmbH.

We therefore reject any unlawful form of influence on the decisions of our customers and other business partners. In this context, we do not attempt to provide business partners, their employees or other third parties with advantages that are suitable for improperly influencing the recipient’s actions and decisions.

Third parties (for example, consultants, brokers, sponsors, agents or other intermediaries) may not be used to circumvent this rule.

 

Donations and sponsorship

Approved donations and sponsorship must be in line with social values and the corporate mission statement of FKM Elemente GmbH.

 

Data protection

We comply with the legal requirements for the protection of the data of employees, customers, suppliers and other business partners.

The necessary care shall be taken to protect personal data within the scope of the assigned task. Data must be treated confidentially and in accordance with instructions.

In the event of doubt or open questions, the supervisor and/or the responsible data protection officer must be informed immediately.

 

Confidentiality

Company and business secrets must be treated confidentially. This also applies to other information that FKM Elemente GmbH, its customers and suppliers have an interest in keeping confidential.

Such information must not be disclosed to unauthorised persons without permission. This obligation continues for all employees after termination of employment.

 

Wustrow, November 2020

 

Eckart Achauer Stephan Fischer
Chief Executive Officer Executive Partner
Certified Compliance Officer