Company Corporate Compliance


General Business Principles of the Diehl Corporate Group

 

Preliminary Remark

Diehl carries out its business activities both in agreement with the laws and regulations of public authorities in the countries where its employees work and in accordance with the principles described here; all employees on all hierarchical levels are to comply with them without exception. Unfair or even illegal practices are not compatible with our business principles.

1. Proper Business Practices

Diehl bases all business activities on the principles of integrity and fairness. All business documents must be in accordance with both national laws and Diehl’s own guidelines. No assets are permitted which are not recorded on the company’s books.

1.1. Bribery / Corruption

Diehl forbids every kind of bribery. No employee may offer, provide, or accept bribes. Bribery is a criminal offense; this includes bribery in business transactions as well as bribery of any holder of office. As a consequence, every direct or indirect offer, promise, provision, or acceptance of inappropriate benefits, whether material or of any other kind, for the purpose of acquiring orders or procuring unlawful advantages is forbidden to all employees.

1.2 Competition / prohibition of cartels

All employees must comply with legal regulations governing antitrust laws and business competition in each case. In particular, employees may not enter into or propose any agreement whatever as follows:

  • with competitors regarding the provision of goods or services to third parties;
  • with customers regarding prices or conditions of supply under which the customer will resell Diehl products or services to third parties.
1.3 Business relations

Relationships with other companies and between employees and its business partners, suppliers, customers, and with governmental offices and their personnel must be characterized by transparency, especially in the areas of purchasing and sales. This also applies to relationships with former employees and in particular to family members employees who supply our corporate group directly or indirectly with goods or services.

Employees who are involved in contractual negotiations with public authorities must be familiar with guidelines governing the process of submitting business offers in each respective country and may not violate them.

Diehl competes for business orders by fair and legal means and carries out contractual negotiations in compliance with our company’s legal provisions.

1.4 Observation of export and import control laws

Employees involved in the import or export of goods, services or technical information must know and observe the relevant regulations, Furthermore, they have to ensure that the import or export documents are complete.

Where the export of products and technical data to a particular country is regulated, the employees must obtain the necessary licences and other state permits prior to the export.

1.5 Avoidance of conflicts of interests

All employees must avoid any situation which could result in a conflict between their own personal interests and the interests of Diehl. A conflict of interest can result when an employee takes a course of action or pursues interests which can hamper him or her in objectively and effectively carrying out his or her duties and meeting his or her responsibility to Diehl.

Gifts and other benefits may be accepted or given only after approval by the respective company superior or responsible person and only under the condition that the gift(s) or benefit(s) do not contravene prevailing laws or guidelines, are within proper limits, and are not intended to influence business decisions in a dishonest manner. The question of whether gifts or invitations are appropriate is to be decided according to normal business practices and with due consideration, if necessary, for the special customs of each individual country. Every appearance of dishonesty and incorrect behavior is to be avoided.

1.6 Business secrets, protection of intellectual property, data protection

Every employee is obliged to treat business information about Diehl or its business partners that is not public knowledge with the strictest confidentiality and to protect it from unintentional disclosure.

One of Diehl's most significant assets is its intellectual property. This includes patents, business secrets, trademark rights and copyrights. It is corporate policy at Diehl to exercise all rights to economically significant intellectual property, and to use, maintain, protect and defend them in a responsible manner. Diehl respects the intellectual property of other natural persons and legal entities and uses the relevant information, computer programs or processes only in accordance with the respective licence agreements or within the framework of the legal provisions.

Personal data are only collected, processed and utilised insofar as this is permitted by law, serves legitimate purposes and is necessary for the fulfilment of duties.

2. Employees / colleagues

2.1 Harassment (respectful relations)

The personal dignity, privacy and personality rights of each individual are to be respected. Employees must not be subject to corporal punishment or physical, sexual, psychological or verbal harassment or abuse.

2.2 Non-discrimination

Cultural differences are recognised and respected. All employees shall be fundamentally assessed only on the basis of the abilities and qualifications required for the job, i.a. in questions of recruitment, promotion, remuneration, additional benefits, further training and qualification, dismissal and termination of the employment contract.

2.3 Health & safety

All employees are guaranteed working conditions meeting the requirements of occupational health and safety, with the relevant statutory regulations representing the minimum standards to be applied. Appropriate measures are taken to prevent accidents at work and occupational diseases.

3. Social environment / public relations

3.1 Working hours

The working hours shall conform to the statutory regulations or the regulations applicable in the relevant branch of industry, whichever are more stringent.

3.2 Remuneration

Wages and salaries, including payment for overtime and bonus payments, must correspond to the level of the relevant laws and regulations.

3.3 Child labour

Child labour in any form is rejected. If no higher age limit is prescribed by law, no person of school age or under 15 years of age may be employed (exceptions in accordance with the Agreement on ILO Convention No. 138).

3.4 Prohibition of forced labour

Forced labour of any kind is forbidden. This includes involuntary prison labour, bondage and similar forms of labour (in accordance with ILO Conventions 29 and 105).

4. Environmental protection

All employees are obliged to observe the regulations and standard on environmental protection. Environmental impact is to be minimised and environmental protection continuously improved.

5. Observance of the business principles

Superiors and management staff are obliged to ensure that their employees are familiar with the content of the above business principles. All employees at all hierarchical levels are individually responsible for compliance with the above business principles. Notwithstanding further civil and/or criminal consequences, violations can be punished with disciplinary measures.

A Compliance Committee has been established in our company, headed by the Corporate Compliance Officer (CCO), in order to audit our business processes with respect to compliance with these principles, to identify compliance problem areas and to investigate recognised violations.

The CCO in turn is supported by a Group-wide compliance organisation. The CCO can also be consulted in all other relevant matters.

In suspected cases of violations of the "General Business Principles of the Diehl Group" or of laws and regulations, the relevant contacts can be found on the Internet (www.diehl.de under tab "Company" in the sub-tab "Corporate Compliance").


Organization

In order to implement Compliance within the Diehl Corporate Group and to enforce the "General Business Principles of the Diehl Corporate Group", the Executive Board and Supervisory Board have established a Compliance Organization. Diehl's Compliance Organization is headed by Attorney Esser (Corporate Compliance Officer).

A Compliance Committee, also including members of the Executive Board, has been set up to regularly check the business processes for compliance with the "General Business Principles of the Diehl Corporate Group", to identify Compliance issues and to investigate recognized violations. Moreover, the Corporate Compliance Officer (CCO) regularly reports to the Executive Board.

In addition, the Compliance organization includes a neutral, external ombudsman who is obliged to maintain strict confidentiality (Attorney Dr. Rainer Buchert). Diehl employees and third parties may contact him in confidence if they have observed improper business practices within companies of the Diehl Group.

CCO Diehl Konzern

Mr. Axel Esser

Phone: +49 (7551) 89 - 2439
Fax: +49 (7551) 89 - 4114
Mobil: +49 (172) 4589175

E-Mail: axel.esser@diehl-defence.de

Ombudsman

Mr. Dr. Rainer Buchert

Bleidenstraße 1

60311 Frankfurt am Main

Germany

Phone: +49 (69) 710 33 33 0 or +49 (6105) 921355
Fax: +49 (69) 710 34 44 4

E-Mail: dr-buchert@dr-buchert.de

Training

Compliance training courses (on-site events and e-learning) are regularly conducted in all countries where the Diehl Group has a site for employees on all hierarchical levels. Such Compliance training courses provide explanations regarding the "General Business Principles of the Diehl Corporate Group", with emphasis on corruption prevention/competition law. For particular departments, such as sales and purchasing, training courses specifically tailored to them are conducted.