Code of conduct

(as of 14.03.2024)

1 Scope of application and responsibilities

Alltrade TOPO GmbH is committed to ecologically and socially responsible corporate governance. The Code of Conduct sets out binding rules and applies to all employees. The members of the management in particular are responsible for the active implementation of this Code of Conduct. The Code is a moral compass that must be observed in all internal and external actions. Any employee can approach their line manager or the management with questions and comments in this regard.
The company also expects all suppliers and business partners to observe the principles of ecological, social and ethical behaviour.

2 Dealing with information and data protection

The company’s employees are obliged to maintain confidentiality regarding business secrets and other internal matters. This applies accordingly to information about colleagues, customers, suppliers and business partners that is not publicly accessible. The confidentiality obligation also applies after termination of the employment relationship. It is prohibited to process, disclose, make accessible or otherwise use protected personal data without authorisation for any purpose other than the legitimate fulfilment of the respective task. Employees must ensure that all personal data is handled and protected in accordance with the applicable data protection regulations.

3. Ethical business conduct Corruption

The company expressly opposes any form of corruption at home and abroad and avoids even the appearance of trying to influence business decisions through unfair business practices. No employee may exploit the company’s business connections for their own or someone else’s benefit or to the detriment of the company. This means in particular that no employee grants or accepts unauthorized private advantages (e.g. money, material assets, services) in business transactions that are capable of influencing an appropriate decision. Every employee of the company is obliged to seek advice or help from the managing directors if there are suspicions or legal doubts regarding the existence of corruption.

4. Ethical business conduct

Corruption
The company expressly opposes any form of corruption at home and abroad and avoids even the appearance of trying to influence business decisions through unfair business practices. No employee may exploit the company’s business connections for their own or someone else’s benefit or to the detriment of the company. This means in particular that no employee grants or accepts unauthorized private benefits (e.g. money, material assets, services) in business transactions that are capable of influencing an appropriate decision. Every employee of the company is obliged to seek advice or help from the managing directors if there are suspicions or legal doubts regarding the existence of corruption.

Money laundering
The company does not tolerate money laundering. All employees responsible for financial transactions are obliged to strictly comply with the laws on combating money laundering (GwG, Section 261 of the Criminal Code). They must also immediately report any suspicious forms of payment or other transactions that indicate money laundering to management.

Granting and acceptance of benefits, invitations and gifts
Invitations, such as to business meals or events, that correspond to recognized business practices and are appropriate may be made or accepted if they do not serve to show impermissible favoritism. The same applies to the acceptance or granting of gifts. If there is any doubt as to whether there is a factual reason or whether a donation is customary, the employee must ask management in advance.

Donations and sponsorship
Donations are only made on a voluntary basis and without expectation of anything in return. Donations and sponsorships must not be designed to covertly promote decisions in the interests of the company. The donation must be transparent. The recipient of the donation and the specific use by the recipient must be known. The reason for the donation and the intended use must be accountable at all times. Remuneration similar to donations must be avoided.

5. Health and safety at work

Occupational safety and health management are the highest priority at Alltrade TOPO GmbH and are guaranteed within the framework of national regulations.

Employees are regularly informed about applicable health and safety standards in the workplace and are informed and trained about the long-term impact of work on health and measures to minimize risks and prevent work-related accidents and illnesses.

It is ensured that all workplaces are, for example, properly lit, ergonomic and hygienic.

Employees are given access to drinking water and other beverages in sufficient quantities as well as access to clean sanitary facilities. Suitable safety clothing (e.g. safety shoes for warehouse visits) is provided.

6. Regulation of working hours

The working hours comply with applicable laws or industry standards.
Overtime is only permitted if it is carried out on a voluntary basis and does not exceed 12 hours per week. Weekly working hours must not regularly exceed 48 hours.

The company allows employees to work remotely on two days per week. Two additional days are considered “compulsory office days” subject to individual arrangements. These are always entered in Outlook as “office days”. The third “office day” can be flexibly selected on one of the non-“compulsory office days”. The management reserves the right to adapt the regulation to operational needs if necessary.

7. Principles of social responsibility

Social responsibility is an indispensable part of value-based corporate management and a key factor for sustainable corporate success.

The company respects and supports internationally recognized human rights. In this context, we are also in constant dialogue with our suppliers to avoid our products containing raw materials from conflict regions.

The bans on child labor and forced labor in any form are observed. All work must be voluntary and employees must be able to terminate their work or employment at any time.

Discrimination against employees in any form is not permitted. This applies, for example, to disadvantages based on gender, race, caste, skin color, disability, political opinion, origin, religion, age, pregnancy or sexual orientation. The personal dignity, privacy and personal rights of each individual are respected.

The company promotes equal opportunities for its employees.
The right of employees to establish and join organizations of their choice and to conduct collective bargaining must be respected.

Alltrade TOPO GmbH is a member of the amfori Business Social Compliance Initiative (amfori BSCI). The common goal is the sustainable improvement of social standards in supplier countries as part of the social responsibility of companies in a globalized economy. Alltrade TOPO is committed to complying with the BSCI Code of Conduct and thus to maintaining minimum social standards.

8. Environmental and climate protection

Sustainable environmental and climate protection as well as resource efficiency are important corporate goals for us. Every employee is responsible for treating natural resources carefully and contributing to protecting the environment and climate through their individual behavior.

The focus here is on the efficient use of energy, paper and water. The specific measures can be found in the procedural instructions.

Separating waste while taking recycling into account is a matter of course for us and is practiced on a daily basis.

With the help of modern communication technology, time and environmental resources are saved. Travel activities and the associated emissions of greenhouse gases are reduced in the spirit of practical environmental protection. Where possible, the train is preferred to the car.

9. Compliance with the Code of Conduct

The company familiarizes its employees with the content regulated in this Code of Conduct and explains the obligations resulting from it.

The company takes all necessary steps to implement the basic values ​​and requirements contained in this Code of Conduct through suitable organizational measures and appropriate processes in all business areas.

The company undertakes to regularly monitor compliance with the Code and to set up mechanisms for reporting violations. Violations of the Code of Conduct are taken seriously and can lead to disciplinary measures, including warnings or termination of employment, depending on the severity of the violation.

The Code of Conduct comes into force on March 14, 2024 and applies to all employees of the company.